EPA’s voluntary program for “safe management of used electronics” won’t prevent unsafe e-waste exports to developing countries

September 20th, 2012

Today the EPA announced its new “Sustainable Materials Management Electronic Challenge,” a voluntary program to encourage electronics manufacturers and retailers  to launch or improve their takeback/recycling programs for used electronics, and in particular to send more of their e-waste to certified recyclers.  Good intention, not necessarily good results.

Manufacturers and retailers may join the program at one of the three tiers, bronze, silver or gold, pledging to meet the requirements of the tier within a year.  The levels primarily reflect how much of the e-waste collected under the program is sent to certified recyclers. At bronze, they are sending less than 50%, silver 50-95%, and gold 96-100% by weight is sent to certified recyclers. There are some additional requirements for silver and gold levels.

Some good elements

There are things we like about the EPA’s new program. It borrowed some elements from our own Electronics Recycling Report Card metrics.

  • It covers all collection streams, including business (something companies rarely report on publicly).
  • It requires annual, public reporting on collection volumes, collection sites, and efforts to publicize their program.
  • At the gold level, programs must show increased volumes in one or more state without a takeback law, a good idea, but which won’t have much impact if it can be met by showing an increase in only one state.

Ignores biggest problem in the industry

The EPA could have done the right thing on e-waste exports in a couple of ways:But we are very disappointed that the EPA has basically ignored one of the biggest problems in the recycling industry – the fact that so many recyclers export at least some categories of e-waste to developing countries. While the EPA’s press announcement today called for “Safe Management of Used Electronics,” exporting e-waste to developing countries is anything BUT safe – at least for the workers and residents near the locations where crude, dangerous, “informal” processing occurs.  This is bad for both people and the environment.

  •  The easiest way would have been to require use of recyclers certified to standards that prohibit the export of toxic e-waste, including untested or non-working products, to developing countries. Currently, there are recyclers in 92 locations across the U.S. certified to the e-Stewards standard, which has that important requirement that prohibits the unsafe exports. Many more recyclers are in the process of getting certified to the e-Stewards standard. The other standard, called R2, does allow export of e-waste to developing countries. But the EPA, under different leadership, helped convene the R2 standard stakeholder process, so for political reasons, the EPA seems to be unable to favor the clearly stronger e-Steward standard.
  • Still, the EPA could have set this program up to reward companies, perhaps at the higher tiers, who can show that they are only using vendors who are not exporting e-waste to developing countries, without specifying e-Stewards.

Incentives to export are high
ponse to our report card, but not always their business vendors.Also, the EPA programdoes not require public disclosure of which vendors the manufacturer or retailer is using. They must report this to the EPA, but public disclosure is optional.  Some have begun to disclose their consumer in response to our report card, but not always their business vendors.

Why are we so focused on who the vendors are, and what standards they are using? Because we know that some of the manufacturers are paying extremely low rates to their recycling vendors, at least for certain streams. This is particularly true for the price per pound paid to recyclers to process used  CRT TVs or monitors (with cathode ray tubes). Recyclers who are paid such low prices per pound would have to lose money on these streams if they managed them responsibly, so the incentive to export them to developing countries instead is very high.

We continue to be disappointed by this Administration’s failure to draw the line at dumping our toxic e-waste in developing countries, especially in their voluntary efforts like this one and for how they are managing their own e-waste. Because market pressures stronly encourage these kinds of exports, by not including measures to prohibit them, the EPA is basically condoning e-waste exports to developing countries. Some of the manufacturers have already taken positions stronger than the EPA is promoting here with its gold level tier.  If the EPA is going to establish a voluntary program with tiers of performance, shouldn’t the highest (gold) level be at or above what the leaders in the industry are already doing?

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