The Consumer Electronics Association (CEA) today announced a new national voluntary program to recycle electronics. Well at least they announced a goal, and promised to tell us about their national program at some point in the future.
CEA proclaimed a goal of collecting a billion pounds of e-waste a year by 2016, five years from now. They said the industry collected 300 million pounds in 2010. By my calculations, 200 million of that was in states with laws that require them to do so. (Many more state programs began in 2011 or will begin in 2012, so of course their volumes are not reflected yet.)
Of course, any effort by this industry to do more recycling is a good thing. Frankly, these companies’ voluntary takeback programs have been , with a couple of exceptions (particularly Dell). Most of the company programs require you to mail back your old products, which most people simply won’t do. For TVs (which can’t be mailed back) the collection sites are few and far between in most states. So in theory, a sincere, robust, long-term recycling effort by this industry should be a good thing.
But here’s why today’s announcement is seriously underpowered:
1. Where’s the beef?
CEA gave almost no other information about the program or how they are going to meet their goal. They won’t even say which companies are participating. What will each company be responsible for? What products will they take back – everything they make? A big announcement of a new program should have included at least some details.
2. Where can we bring our old stuff?
Here is a map of supposedly 5000 industry collection sites according to CEA. You can see dots on the map, but you can’t actually get the name or location of any of them. (California is missing entirely.) Instead, they provide a link to another site, that links eventually to the Earth911 site, which lists all kinds of recycling sites and not just e-waste collectors that are part of the CEA effort. Is that CEA’s answer – to send people to sites that the industry isn’t involved with, monitoring, or paying for? Or are we supposed to look at each individual company’s own website? Talk about a patchwork of solutions!
3. What’s the commitment to not export e-waste to developing countries?
If this is truly a “leadership initiative” as CEA calls it, then this effort must include a very clear commitment that the toxic products collected will not simply be exported to developing countries, where they have been proven to cause great harm to people and nature. CEA’s “principles” statement falls short of that commitment. Their press release today said the initiative would “prohibit the use of recyclers and downstream processors who dump end-of-life electronics in developing nations.” But we want a much clearer statement that makes it clear that untested and non-working electronics wont’ be sent to developing countries – since a lot of e-waste exporting is under the guise of “reuse.” Most of the leading companies have themselves published specific policies that they won’t export e-waste to developing countries, including untested, non-working products and parts. So why wasn’t that a core part of principles released today?
4. Where’s the commitment to high standards?
CEA makes generally supportive statements about using recyclers with third party certifications. But there are two very different certification programs now, one which has a much stronger standard than the other. The e-Stewards standard is the only one which does not allow exporting toxic e-waste to developing nations, or using prison labor, landfilling or incinerating e-waste. The industry should be embracing this standard, and encouraging their vendors to become certified to it.
CEA Wants States to Stop Passing Laws
CEA’s strategy with this announcement is to stop the States from passing laws on e-waste recycling. Today’s announcement was, I believe, the first step towards convincing States that industry will step up on its own, so no need to keep passing those pesky state e-waste laws. Then they intend to make this program the basis of national takeback legislation. They don’t even hide this strategy. But with no details provided today on CEA’s program, it seems unlikely that legislators contemplating an e-waste law will be convinced that industry is on the verge of solving this problem.
Ultimately, we want to see from the industry’s takeback program:
- No exports of toxic e-waste to developing countries, including untested or non-working products,
- Vendors certified to e-Stewards Standard, the highest standard available
- Transparency to show this is a whole industry effort, not just a few companies. Reporting on collection goals and volumes by each company each year.
- Go beyond complying with state laws, and provide robust programs in all states.
- Show that this is a permanent program, not just a PR announcement intended to discourage more states from passing takeback laws.
- Maintain top environmental management systems that include accountability for toxic materials, worker safety, responsible reuse, data security, and export controls that conform with international law and best practices.
- Don’t allow any hazardous e-waste to be sent to solid waste (non-hazardous waste) landfills or incinerators for disposal or energy recovery.
We’re looking forward to seeing more details from CEA soon.