Footwear electronics end-of-life
Assessing the challenges created by footwear which incorporates electronics.
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Footwear is notoriously difficult to dispose of responsibly at the end of its life and, despite sustainability being high on the agenda for most businesses involved in the sector, there are still very few viable solutions that are widely available and accessible. There has been an increase in the number of available schemes to refurbish and repair footwear, as well as a huge uptake in so-called ‘re-commerce’ or ‘pre-loved’ platforms that allow footwear to have a second life when it is no longer wanted by the original consumer. Donations of used footwear to charity are also often made by consumers seeking to avoid sending shoes to landfill. While all of this is a definite step in the right direction, it is only postponing the inevitable end-of-life, when it is no longer viable to repair or resell an item, and it is estimated that of the 24 billion pairs of shoes produced globally every year, more than 85 per cent ultimately go to landfill.
Some form of recycling would be an obvious solution, but several factors make this challenging for most types of footwear. Firstly, footwear is typically made from many different types of materials and components assembled together, and each of those constituent parts is likely to have a different associated recycling process. Secondly. the use of adhesives during production makes it difficult to separate the footwear into its constituent parts to allow them to be recycled. Finally, for some items there are simply no established or accessible recycling streams.
The addition of electrical components and batteries into footwear makes a difficult challenge even more complex. Waste processing facilities that normally handle textile-based products will not be able to handle electronics, and electronics processing facilities will not be set up in order to manage standard footwear materials and components.
Applications of electronics in footwear
It is useful to understand why and how electronics are being incorporated into footwear. Some of the most common applications include light-up shoes for children, in-shoe heating, sports performance tracking (such as for running pace and cadence) and medical applications – for example, tracking positioning and movement over time can be used alongside other data to identify conditions such as type 2 diabetes and its progression. In recent years, Bluetooth and Wi-Fi connectivity have also been incorporated into footwear as a means to extract any data collected and to connect with other devices.
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Children’s light-up footwear is typically manufactured so that all of the electronics – including the lights and battery – are encapsulated into the outsole unit. However, it is often the case with sports and medical tracking that the technology is incorporated into removable footbeds or detachable pods.
As the world becomes increasingly ‘data-driven’ and new technologies are developed, it is likely that we will see more examples of footwear incorporating electronics. It is therefore important to consider what will happen to these items at the end of their useful life and to design them with an end-of-life solution in mind.
Legislation for end-of-life
It is critical that an organisation putting electronic footwear onto the market complies with any relevant end-of-life legislation in that market. The key piece of legislation in the EU and UK is the 2013 Waste Electrical and Electronic Equipment Regulations (WEEE) 2012/19/EU, which was implemented by the member states at that time, including the UK. Any items that are classified as ‘electrical and electronic equipment’ (EEE) need to be disposed of appropriately according to the WEEE legislation. This means that they must be labelled in accordance with WEEE and cannot be disposed of as general household waste. They have to be processed through a specialist recycling centre.
There has been some ambiguity over the years as to whether footwear incorporating electronics should be classed as EEE, with differing interpretations at times across the member states often based on considering the primary function of an item. Recent guidance provided by the UK government states that clothing with novelty lights or sounds that can still work properly as clothing without the electrical function is not EEE, whereas a sports top incorporating a heart-rate monitor is EEE. It is SATRA’s recommendation that all footwear incorporating any electronic components must be treated as WEEE and labelled accordingly to make consumers aware that it should be placed into an appropriate waste-stream, rather than being discarded as general waste.
Another consideration is the 2006/66/EC ‘Battery Directive’. This legislation covers what types of batteries can be used, as well as chemical restrictions and labelling requirements for the batteries themselves. Directive 2013/56/EU amending directive 2006/66/EC also specifies that appliances should be designed so that batteries can easily be removed – if not by the end user, then by a qualified professional, such as at a specialist repairer or waste-recycling centre.
Other legislation relevant to electronic footwear
The legislation below also needs to be considered for footwear containing electronics, although it is not directly applicable to its end-of-life treatment.
- RoHS Directive 2011/65/EU – restriction of the use of hazardous substances in electrical and electronic equipment
- EMC Directive 2004/108E/EC electromagnetic compatibility directive – limits for electromagnetic emissions
- EMF Directive 2013/13/EU electromagnetic fields directive – control of electromagnetic fields.
In order to minimise the potential environmental impact of electronic footwear at the end of its life, there are some key factors to consider. First of all, is it possible to manufacture the item so that the electronic elements can easily be removed – for example, by incorporating them into removable footbeds or detachable pods? This would allow the electronic components to enter an electronics waste stream and the ‘standard’ shoe components to go into a footwear/textile recycling stream. Anything that can be done to facilitate the disassembly of the footwear itself will also increase the likelihood that at least some elements of it can be recycled.
A number of brand owners and retailers are also either setting up their own take-back schemes or partnering with other organisations to process footwear at end-of-life. This is something else that may be worth investigating, to try to ensure that waste footwear is managed in the most environmentally-friendly way possible. Nevertheless, even if footwear is labelled as WEEE, disposed of responsibly by the consumer and sent to a site that can recycle electronics, that site may not be able to process it due to the time needed and the complexity of separating the relatively small electronic components from the shoe. Hence, it could still end up in landfill.
Unfortunately, the vast majority of footwear today is ultimately sent to landfill. For complex footwear containing electronics, it is perhaps even more important to consider what will happen to it at the final stage of its end-of-life, in order to work to minimise the product’s environmental impact and to ensure that consumers are informed of the best way to dispose of the item.
How can we help?
Please contact SATRA's sustainability team (firstname.lastname@example.org) for further information on end-of-life solutions for footwear or for any advice relating to incorporating electronics into footwear, ensuring compliance with relevant legislation and suitable testing protocols.
This article was originally published on page 14 of the September 2022 issue of SATRA Bulletin.