Beyond the Bin: Harmonizing EPR, Right-to-Repair, and Eco-Design through an ‘Active Triage’ System Model

Main Presenter:    Priya Saikumar 

Co-Authors:                                                  

The transition toward a circular economy for electronics is currently driven by a triad of robust legislative instruments: the Eco-design for Sustainable Products Regulation (ESPR) , the Right to Repair (R2R) directive, and the Critical Raw Materials Act (CRMA). However, a systems perspective reveals significant friction between these policy silos. Current Extended Producer Responsibility (EPR) schemes are historically optimised for mass-based recycling targets, often incentivising the rapid shredding of devices to recover raw materials at the expense of labor-intensive repair processes. This misalignment creates a circularity gap where even if products are theoretically repairable by design they are financially destined for end-of-life processing. This paper addresses this gap by proposing the active triage gateway (ATG) model, a system dynamics framework derived from a systematic literature review of 129 recent studies on circular barriers in the electronics sector. Unlike passive
collection points that serve as waste receptacles, the ATG functions as an intelligent repair and grading node, routing returned products based on utility retention while generating critical data feedback loops for manufacturers.
To validate the model’s viability beyond theoretical mapping, a techno-economic feasibility analysis is being conducted using secondary industry data. The research models three essential feedback loops: (1) a Design Loop, (2) a Repair Loop, and (3) a Financial Loop. The study specifically interrogates the economic viability of these loops across product categories. It hypothesizes that while high-value IT assets may support a self-sustaining triage model, low-value appliances likely face a triage deficit—where diagnostic costs exceed recovered value. The final analysis will determine the precise break-even points, quantifying the structural necessity for EPR fees to evolve from funding end-of-life material recovery to subsidising product lifetime extension strategies.
From an academic perspective, this study advances circular economy scholarship by shifting the unit of analysis from individual product design to systemic routing dynamics, offering a replicable framework for “policy coupling.” For policymakers, the findings provide a data-driven basis for modulating EPR fees, suggesting that future levies must account for the “labor intensity of circularity” alongside material recyclability. Finally, for managers and producers, the ATG model demonstrates how establishing feedback loops from triage centres can lower ESPR compliance costs by identifying high-frequency failure modes early, transforming waste management from a cost center into a strategic intelligence asset.

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