How much mercury is entering Hong Kong's Environment from Discarded Fluorescents?
First published: 26th January 2018
My estimate suggests 469kg of mercury per year.
Noticing the Problem
Fluorescent lamps are a type of energy-saving illumination that has been available for many years, unfortunately they contain mercury. Not very much mercury, between 3mg and 46mg per tube, depending on size and type, but still enough to require careful disposal. The Hong Kong Government's Environmental Protection Department [EPD] runs a Fluorescent Lamp Recycling Programme [FLRP] to provide households with free collection and treatment for all used mercury-containing lamps. They write, "Commercial and industrial premises do not come under the programme because many organizations have already recycled their lamps in accordance with the Waste Disposal Ordinance."
Although the FLRP is a good effort, I've noted some limitations:
- The collection boxes are unsuitable for long fluorescent tubes. Apparently, the EPD believes that long tubes are not used domestically. For the record, I have four fluorescent light fittings of 4 foot or longer in my kitchen and lounge.
- Many commercial and industrial premises do not have facilities to collect, store and recycle fluorescent tubes. According to the FLRP webpage, "As required under the law, any premises that store a significant quantity (eg. over 500 pieces) of used mercury containing lamps have to register with the EPD as a chemical waste producer, and arrange for proper collection and treatment of the used lamps at the Chemical Waste Treatment Centre." This leaves a considerable gap for smaller premises. A small factory building with 4 units on 20 floors might only replace less than 50 tubes a month, and the management company might consider it not worth bothering with the issue. So where are these tubes going?
- I've noticed long fluorescent tubes being discarded in street litter bins, see photos 1,2 and 3 for recent examples. Sometimes the tubes get broken, see photo 4. How are the rubbish collectors instructed to handle these? Do they just end up in landfill? If the tube is broken before collection, then the mercury is already exposed.
Statistics and Estimation
While it is worrying to see fluorescent tubes discarded on the street, and it is easy to be suspicious of lax waste handling on commercial properties, this does not measure the size of the problem. Maybe it is insignificant. I decided to find some statistics.
Chemical Waste Treatment Facility Statistics
According to the EPD, all fluorescent lamps collected under Fluorescent Lamp Recycling Programme (FLRP) and commercial and industrial sector would be sent to Chemical Waste Treatment Facility (CWTF). The EPD provided me with statistics for the last 5 years:
Statistics on mercury-containing lamps handled at CWTF in the past 5 years:
|Year||Lamp Types||Source (equivalent number of lamps)|
|FLRP||Government Departments||Others (Commercial & Industrial)||Subtotal||Total|
|2013||Straight Fluorescent Lamp||156338||122844||832303||1111485||1982404|
|Compact Fluorescent Lamp||337600||58584||200288||596472|
|High Intensity Discharge Lamp||1662||23434||249351||274447|
|2014||Straight Fluorescent Lamp||142860||120144||768009||1031013||1822796|
|Compact Fluorescent Lamp||323487||60080||201088||584655|
|High Intensity Discharge Lamp||2996||45542||158590||207128|
|2015||Straight Fluorescent Lamp||148707||150783||688364||987854||1810130|
|Compact Fluorescent Lamp||343292||59937||185062||588291|
|High Intensity Discharge Lamp||4842||36620||192523||233985|
|2016||Straight Fluorescent Lamp||147735||134114||655255||937104||1675338|
|Compact Fluorescent Lamp||303845||64801||141005||509651|
|High Intensity Discharge Lamp||3098||52248||173237||228583|
|2017||Straight Fluorescent Lamp||154105||145306||640921||940332||1608871|
|Compact Fluorescent Lamp||278792||70470||138640||487902|
|High Intensity Discharge Lamp||4390||28388||147859||180637|
- Equivalent number of lamps = the weight of batch / Nominal unit weight.
- Nominal unit weight of Straight Fluorescent Lamp is 0.16 kg.
- Nominal unit weight of Compact Fluorescent Lamp / High Intensity Discharge Lamp is 0.10 kg.
So, almost 2 million lamps were recycled in 2013, reducing to 1.6 million in 2017. That's a lot of lamps. Not surprisingly, the FLRP (i.e. domestic sources) account for most of the CFLs, and commerce and industry account for most of the high intensity discharge lamps.
The totals are graphed in Graph 1. There is a clear downward trend of recycling mercury-containing lamps.
Import, domestic export and re-export statistics were provided by the Trade Analysis Section of the Census and Statistics Department. The lamps are recorded under HKHS code 85393100, "FLUORESCENT LAMPS, HOT CATHODE". Apparently, there are no statistics on the manufacture of fluorescent lamps in Hong Kong. However, the domestic export statistics are less than 1% of the total exports, so local production of fluorescent lamps is a rounding error. Perhaps imported bare tubes are being incorporated into lighting units that are re-exported under the same code.
Statistics on the Import and Export of Fluorescent Lamps, Hot Cathode in the past 10 years:
|Quantity||Value (HK$)||% Change||Quantity||Value (HK$)||% Change||Quantity||Value (HK$)||% Change|
The quantities are graphed in Graph 2. A notable feature is that in 2013 more fluorescents were re-exported than were imported. The figures show a steep decline in the numbers of fluorescents. This is probably attributable to the rising popularity of LED lights.
Comparison and Limitations
The figures for recycling and trade are not counting the same thing. The recycling figures are for mercury-containing lamps, and the numbers are measured by weight divided by the nominal unit weight of different types of lamp. The trade figures are for units of "fluorescent lamps, hot cathode", as reported by the trader. It is not clear whether a unit always represents one tube, it might be one light fitting, containing several tubes in some cases. Even within the trade figures, the imports and re-exports in a single year do not, necessarily, relate to the same lamps. This is clearly demonstrated in 2013, when more lamps were re-exported than were imported, which would be impossible if they were the same lamps. Many of the lamps re-exported in 2013 must have been imported in earlier years, and stored. Lamps will not, in general, be recycled or discarded in the same year they are imported, a fluorescent tube has a life of 7000 to 15000 hours, at 8 hours a day "office" usage, this is between 2.4 and 5.1 years before the tube fails. A tube in an occasionally-illuminated warehouse might last decades. However, in many (most?) cases, a new tube will be replacing a failed tube.
Bearing in mind these limitations, we can estimate the numbers of fluorescent tubes that are improperly disposed of in Hong Kong. The net imports are the imports minus the re-exports and domestic exports (this assumes that the domestic exports are imported tubes incorporated into lighting units). Assuming that each net import is replacing a failed tube, then the tubes that are handled by the CWTF are properly disposed of, and the remainder are assumed to be improperly disposed of:
Estimated Improperly Disposed of Fluorescent Tubes
|Year||Processed at CWTF||Net Imports||Estimated Improperly Disposed|
|Average||1.8 million||12.0 million||10.2 million|
This is illustrated in Graph 3.
The anomalous quantity of re-exports in 2013 makes the estimate for that year unrealistic and unreliable, and recycling statistics before 2013 were not available. For the years 2014 to 2017, between 2.7 and 9.9 million tubes per year were improperly disposed of. By taking the average recycling over 2013 to 2017, and comparing it to the average net import over 2008 to 2017, then about 10.2 million tubes per year were improperly disposed of. If those tubes each contained 46mg of mercury, this represents 469kg of mercury per year.
Conclusion and Suggestion
The current arrangements for recycling mercury-containing tubes are not ensuring that most tubes are recycled.
Perhaps inspiration can be taken from the successful plastic bag levy. If a bounty, of say $1 - $2 per tube, depending on the size or mercury content, was awarded for each unbroken (that is, with the glass envelope intact) tube delivered to Government collection points, then the existing army of casual recyclers will do the work. The cost can be offset by imposing a similar levy on tubes sold in Hong Kong. The amount should be sufficient to incentivise recycling without being high enough to encourage theft of working tubes or smuggling of failed tubes from across the border. A long fluorescent tube is more difficult to carry or conceal than a tin of milk powder, so this should not provide much of a challenge for the Customs Department.
Updated: 13th February 2019
In response to my email enquiry, the Environmental Protection Department (EPD) has responded.
2. We appreciate that your blog has expressed environmental concern on disposal of a type of mercury-added product, specifically fluorescent lamp. With a view to adopting a more holistic approach in protecting human health and the environment from anthropogenic emissions and releases of mercury and mercury compounds, we are working on a new piece of legislation prohibiting the manufacture, import or export of those mercury-added products as listed in Part I of Annex A of the Minamata Convention on Mercury after a specified phase-out date. For robust control on mercury-added products, the supply and sale of the mercury-added products will also be prohibited after three years from a specified phase-out date. Use of the listed mercury-added products is not an offence. Compact fluorescent lamps (CFLs), linear fluorescent lamps (LFLs) for general lighting purposes exceeding certain mercury content (5 -10 mg depending on types) and high pressure mercury vapour lamps (HPMV) for general lighting purposes will be subject to control. You may wish to refer to the following webpage for more information: https://www.epd.gov.hk/epd/english/resources_pub/policy/consultation_mercury.html.
3. Despite the relatively low concentration of mercury in fluorescent lamps, we have exercised control on collection and disposal of used lamps in bulk (e.g. over 500 pieces) which are classifiable as chemical waste under the Waste Disposal (Chemical Waste)(General) Regulation (CWR). Any operators or premises owners that generate or store a large quantity of used mercury containing lamps have to register with the EPD as a chemical waste producer, and arrange for proper collection and recycling of the used lamps at the Chemical Waste Treatment Centre.
4. To better protect the environment and cater for householders or occasional minor generators whose waste is exempted or not subject to control under the CWR, a Fluorescent Lamp Recycling Programme (FLRP) has been established with support from the lighting industry to collect and treat mercury-containing lamps. The FLRP provides free collection and treatment for all used mercury-containing lamps generated from households, including compact fluorescent lamps (CFLs), fluorescent tubes and high intensity discharge lamps, aiming to reduce the environmental risk from improper disposal of these lamps and to recover resources. Householders may also bring their mercury-containing lamps to their estate's collection point and public collection points under the FLRP for recycling. However, due to the space constraints of some of the public collection points, large sized collection boxes for longer fluorescent tubes cannot be accommodated. In such a case, householders are recommended to bring the longer tubes to their estate's collection point if their estate is a participating estate under the FLRP; otherwise the householders may go to the Community Green Stations (CGSs) that accept longer tube for recycling. In this regard, please see the following webpages for the lists of participating estates under the FLRP and the locations of the CGSs.
- The list of participating housing estates under the FLRP: https://www.wastereduction.gov.hk/en/household/flrp_detail.htm#estate_bldg
- The list of CGSs with location details: https://www.wastereduction.gov.hk/en/community/cgs_intro.htm
5. The voluntary nature of the FLRP implies a portion of the lamps will be inevitably disposed of along with general household or municipal waste, these small quantities of waste fluorescent lamps, attributed to their long service lives, are handled together with general waste. Nevertheless, according to international trend, mercury-containing lamps have been progressively replaced by other types of lamps, e.g. LED lamps, as reflected in the statistics in your blog.
6. Thank you for your support in environmental protection.
In short, there are a small number of collection stations for long fluorescent tubes and an international convention (the Minamata Convention on Mercury) will lead to the phasing out of most fluorescents in a few years.
Updated: 05th March 2019
After the EPD's response, I asked two follow-up questions:
- If I understand Annex A of the Minamata Convention on Mercury correctly, Hong Kong will cease importing most fluorescent lamps in 2020, and they will therefore disappear from shops soon afterwards. Is that correct?
- In your paragraph 5, you write, "a portion of the lamps will be inevitably disposed of along with general household or municipal waste, these small quantities of waste fluorescent lamps". From the statistics, approximately 85% or 10.2 million of the fluorescent lamps are disposed of improperly each year, are you characterising 10.2 million as a "small quantity"?
The EPD responded:
- Fluorescent lamps will not entirely disappear from shops after 2020. Since according to the Minamata Convention, Parties are not allowed to manufacture, import or export three categories of mercury-containing fluorescent lamps, as listed below, after a specific phase-out date; but are permitted to manufacture, import or export mercury-containing florescent lamps other than those listed below even after the specified phase-out date :
- Compact fluorescent lamps for general lighting purposes that are ≤ 30 watts with a mercury content exceeding 5 mg per lamp burner.
- Linear fluorescent lamps for general lighting purposes:
- Triband phosphor < 60 watts with a mercury content exceeding 5 mg per lamp; and
- Halophosphate phosphor ≤ 40 watts with a mercury content exceeding 10 mg per lamp.
- Mercury in cold cathode fluorescent lamps and external electrode fluorescent lamps for electronic displays:
- short length (≤ 500 mm) with mercury content exceeding 3.5 mg per lamp;
- medium length (>500 mm and ≤ 1500 mm) with mercury content exceeding 5 mg per lamp; and
- long length (> 1500 mm) with mercury content exceeding 13 mg per lamp.
- Regarding fluorescent lamps from general householders, a number of factors contribute to the differences in imported/disposal figures, e.g. the sales figures of the lamps, whether the lamps are still in use, the replacement of incandescent bulbs with fluorescent lamps, the increased number of lamps being installed due to economic growth and establishment of new buildings, etc. In this regard, we do not currently keep a statistics on the number of fluorescent lamps disposed alongside general refuse. In essence, under the current legislation, chemical waste originated from households are exempted from the various statutory requirements. We are not in a position to comment on your proposed methodology and the figures in reaching the estimates and your conclusions that 10.2 million of the fluorescent lamps are disposed of improperly each year.