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Today’s report focuses on the results from the trackers inside devices delivered to Goodwill stores. BAN delivered 46 of the total project’s 200 tracker-enabled electronic devices to Goodwill stores around the US— 28 of them at Goodwill stores that are collectors for Dell’s Reconnect program and 18 of them at Goodwill stores not associated with the Reconnect program. Only one of the 18 devices dropped at the non-Dell Reconnect stores, only was recorded as being exported. But six of the 28 devices (21%) dropped at Goodwill stores that were part of the Dell Reconnect public e-waste takeback were exported.
Where did the Goodwill items go?
Of the seven devices dropped off at Goodwill stores, four went to Hong Kong, (one printer and three LCD monitors), one went to Mainland China (one printer), one went to Taiwan (one LCD monitor), and one went to Thailand (one LCD monitor). According to the report, all of these exports were likely to be illegal under international law, and the importing countries’ laws.
Dell partners with many of the Goodwill e-waste recycling programs under their Reconnect Program, whereby Goodwill collects the e-waste and Dell takes it and recycles it. But the exports to China, Hong Kong, and Thailand found in this report clearly violate Dell’s policy of not exporting e-waste to developing countries. Dell has always had the clearest and strongest policy on e-waste exports in the industry. They were the first electronic manufacturer to announce such a strong policy in the U.S. So it’s particularly disappointing to see these results. But not entirely surprising.
There have been several reports from recyclers over the years complaining that Dell (along with some other manufacturers) squeeze the recyclers they work with, paying them as little per pound as possible – less and less every year. Because commodity prices have fallen significantly in the last couple of years, already squeezed recyclers are challenged to manage these products (which contain toxic chemicals) responsibly without losing money. The three product categories in this study – LCD TVs, CRT monitor, and printers – are all money losers for recyclers at this point (assuming the panel from the LCD has no reuse value). So it’s not a big surprise to see these items go down the low road. While Dell has one of the toughest audit programs in the industry for their takeback system, no audit program can compensate if you don’t pay recyclers enough to manage the commodities responsibly AND make a little profit to stay in business. Not unless you are monitoring every single shipment.
So if this is happening to Dell, the company with the highest standards and toughest audits, should we assume that other manufacturer takeback programs’ e-waste is also being exported to developing countries, even if they have a policy forbidding it? Stay tuned to BAN’s e-Trash Tranparency Project’s upcoming reports.
Amazon, do we really need these little devices?
Amazon, retail’s undisputed King of Laggards on sustainability and environmental efforts, has just added another jewel to its tarnished laggard crown by expanding its Dash button program. Last week, on the one-year anniversary of the introduction of the Dash button, Amazon announced it was tripling the number of buttons to include a wider range of products and brands.
In case you’ve missed it, a Dash button is an electronic, Wi-Fi connected device that lets you order a specific product from Amazon by just pushing the button. The idea is that you stick the button for that product next to the place where you use that product. When you see that you are running low, you just press your dash button, which immediately reorders that item from Amazon for you using your Wi-Fi. You must be an Amazon Prime member to buy the Dash button. Of course, delivery comes via Amazon Fresh, its home-delivery service.
Setting aside our bewilderment about why anyone would be willing to glue these fat plastic lozenges bearing corporate logos around the house, we can’t help but notice that these buttons seem more like future e-waste than must-have devices. The buttons each do only one thing – order a very specific product, in a specific size, from a specific retailer. You will have a few options of which Tide product you can configure your Tide button to order, but you can never switch it from being a Tide button to another brand’s button.
So what happens when you decide to use a different brand of product? Or you decide to buy from Costco instead of Amazon? Or realize you can just write the item on your shopping list? Or use your phone to make a one-click order on Amazon? Or the (non-rechargeable) battery runs out? What will consumers do with the now useless Tide button?
Our guess is that most people will just toss it into the trash, unaware that there is a AAA battery inside, plus a circuit board and electronics – things that should be recycled, not trashed.
They should be recycled because they likely contain some of the toxic chemicals commonly found in electronics, which shouldn’t end up in the landfill. Plus they contain metals and plastics which should be reused, not trashed, as they are not renewable resources.
Amazon Won’t Recycle Dash Buttons
Yet there is no information on Amazon’s website about returning a Dash button. I contacted Amazon’s customer service department, which told me they do not accept them back for recycling or reuse, but that I would be free to recycle one on my own. I doubt that a recycler will even want this, since the cost to take it apart to remove the battery probably exceeds the commodity value of the parts. So the Dash button will become a trash button anyway.
Amazon, seriously, you need to take these things back to reuse and recycle them. Or even better, focus on other strategies for customer loyalty that don’t add to the e-waste pile.
Worsening economics of recycling drives changes
Best Buy today announced some significant and unfortunate changes to their electronics takeback and recycling program. First, they have instituted a steep fee of $25 for every TV or monitor collected for recycling. This applies to CRT (tube) TVs/monitors as well as flat panel TVs. They will continue to take other products back for free. Second, they have removed the requirement that their recycling vendors be certified to the e-Stewards standard, which is the highest standard in the marketplace particularly on requirements for worker health and safety and exporting e-waste to developing countries. Certification to e-stewards is now optional for their vendors.
Best Buy, the largest consumer electronics retailer in the U.S., stated their goal is not to dissuade customers from bringing back TVs, but they simply need to cover their increasing costs of TV recycling. The Electronics TakeBack Coalition (ETBC) doesn’t dispute the fact that the economics of TV recycling are bad – there is almost no market for used CRT glass, and commodity values for other materials from electronics (plastic, steel, and other metals) crashed in 2015, and continue to slide downward. While we recognize that Best Buy seeks to cover its costs, we believe that most people will find the $25 fee too high, and may be driven to trashing, dumping or using irresponsible recyclers.
In the 25 states with no takeback laws, Best Buy has been pretty much the only recycling game in town, or even entire counties, for electronics recycling, particularly for big stuff like TVs. (Staples has a good takeback program, but they don’t accept TVs. Goodwill (partnering with Dell) also offers takeback in many areas, but again, they are increasingly saying no to TVs.) So in many places, the choices for consumers who want to get rid of an old TV have been: a) take it to Best Buy, b) put it in the landfill (still legal in many states), or c) dump it on the sidewalk or someplace else illegally.
Other big retailers still doing appallingly little
Meanwhile, Amazon and Walmart, who were the number 3 and 4 consumer electronics retailers in 2014, continue to do nothing very meaningful to help consumers recycle all the products we are buying from them, especially the big stuff like TVs. These retail giants are part of the enormous marketing engine that drive consumers to buy, buy, buy. And they should be doing much more to make sure all this stuff gets reused and recycled responsibly. ETBC did a Retailer Takeback Report Card in 2013, which found that other than Best Buy, Staples and Office Depot, other retailers were doing very little. Amazon and Walmart flunked, getting F’s. Now in 2016, little has changed. We continue to encourage consumers to stop buying electronics from retailers who do little to encourage and facilitate recycling and reuse of old products.
Manufacturers are ultimately responsible
But ultimately, it’s the manufacturers who have the most responsibility here. While many of them do have takeback programs, most do little or nothing in the states where the law doesn’t require them to. Most offer mailback recycling programs, but most consumers don’t use them except for trading in high value items like smartphones. People want to drop off their old stuff at a physical location, and not bother finding a box and packing it up to ship for recycling. This is particularly true for the big stuff – monitors, TVs, printers and multi-function machines.
Many states have passed “producer responsibility” recycling laws, requiring manufacturers to take back and recycle old products. But over time, we have seen that with a few exceptions (notably Samsung, Dell, LG and Best Buy) most manufacturers will do only what the law requires, and nothing more. That means not offering physical collection sites if it’s not required. For states which have annual collection goals, once the manufacturers hit their goal, they stop collecting for the rest of the year.This makes it difficult for consumers who want to have ongoing sites where they can bring their old products.
Another problem is that many manufacturers have been squeezing their recyclers, by paying lower and lower prices per pound, putting enormous pressure on an industry that’s already reeling from the drop in commodity prices – the prices for which they can sell the materials in our old products once they disassemble them. A good example of this is that fact that several recyclers have ended up stockpiling thousands of tons of CRT glass, because (in some cases at least) they didn’t get paid enough by their manufacturer clients to cover the high cost of responsibly processing this lead-laden glass.
Lowering the bar on recycling standards
The second part of Best Buy’s decision was to remove the requirement that Best Buy’s recyclers be certified to e-Stewards. There are two certification programs for electronics recyclers in the U.S. – e-Stewards and R2. Until recently, Best Buy required recyclers to be certified to both standards. Now, they can be certified to either e-Stewards or R2. Best Buy stated that this was a cost-cutting measure, and adhering to the R2 standard is cheaper for recyclers. Of course, there’s a reason for that – R2 is a less rigorous standard. So to save money, Best Buy may be working with vendors who are less diligent about where their stuff goes and how it’s processed. In other words, their costs could be easily externalized to poor communities in developing countries.
What should Best Buy do?
ETBC is disappointed by today’s news from Best Buy, who has been a leader on takeback and recycling for many years. But we recognize the larger economic conditions that have led them to look for cost cutting options. (Although we do think they should not charge consumers who bring back any of Best Buy’s house-branded TVs.) The solution here would be for the manufacturers – particularly the TV companies – to visibly partner with Best Buy to cover some of the recycling costs, and to make sure that responsible recycling occurs. The TV companies, who are always challenged by finding collection sites, could take advantage of the chain’s huge network of stores, which are very convenient collection points for most consumers. This would be an ongoing national partnership program, in every state, in every store, co-marketed by the retailer and the industry. This could also be established with Walmart and their huge network of stores. While Amazon doesn’t have stores, there are many ways in which they could help to be part of the solution.
White House says EPEAT is currently the only tool available that meets its electronics stewardship mandates
The Executive Order had created a problem when it revoked a previous Order requiring that the federal government use the EPEAT label to guide at least 95% its electronics purchases, and then left the door open so that agencies could use basically any standard meeting some very low-bar requirements. The Electronics TakeBack Coalition considered this Executive Order language to be an open invitation for some non-leading electronics companies (or their industry association) to establish a new eco-label that is not as strong as the EPEAT criteria, and would be easier to meet.
Others shared our concerns, and many public and private institutional purchasers, who use the EPEAT label to guide their electronics purchasing, joined us in providing feedback to the White House on the perhaps unintended consequences of the Order.
What the Implementing Instructions Say
The implementing instructions fix the problems and confusion created by the Executive Order by:
- Closing the door it threw open for other weak standards to be used, by clarifying that other standards can only be used if the EPA doesn’t have a recommended standard for the product category. This was a specific recommendation that many of us made to the White House. The EPA already recommends using EPEAT on its greener products website and it’s hard to believe they won’t continue to do so.
“Where there is no specification, standard, or label recommended by EPA, an agency may elect to use other open and voluntary standards in a procurement.” Page 56
- Clarifying that even though it removed the EPEAT mandate, EPEAT is the only label that meets its requirements:
“Unlike prior executive orders, E.O. 13693 does not include a specific reference to Electronic Product Environmental Assessment Tool (EPEAT). However, EPEAT is currently the only tool available to achieve the electronic stewardship mandates of section 3(l) of E.O. 13693. Any future tools shall meet or exceed current levels of sustainable and environmental performance.” Page 65
- Raising the requirement for purchasing products meeting the recommended standard from 95% to 100% of electronics purchases:
“Unlike prior executive orders, E.O. 13693 requires that all applicable procurements, rather than 95%, of purchases for electronic products be environmentally sustainable including those electronic products typically used in office spaces and data centers.” Page 65
The Electronics TakeBack Coalition commends the Federal Environmental Executive Kate Brandt and her team for including this clarifying language in the implementing instructions. We recognize that at some point there may be competing labels that are “as good or better” than the current EPEAT label, and that the EPA may recommend using them in addition to EPEAT.
We only hope that these labels or standards will choose to become part of the EPEAT program (even if they were not developed under the EPEAT system) and place the qualified products on the EPEAT registry. This is important because it’s this one-stop-shopping aspect of EPEAT – having all of the information on qualified products in one place – that makes the EPEAT program so attractive and effective for purchasers.
Order will lead to death of purchasing program for greener electronics
President Obama’s recent Executive Order 13693 set forth some excellent lead-by-example goals for how the federal government must reduce energy and water use, reduce greenhouse gas emissions, and promote alternative energies.
But it contains some seemingly harmless legal jargon, that if left unchanged, will result in the death of the federal EPEAT program for purchasing greener electronics.
The EPEAT program gives purchasers a way to identify electronic products that meet a set of environmental standards. The program has been used for several years by federal purchasers, state agencies, universities, non-profit, and private companies in the U.S. and increasingly in other countries. But now the Obama Administration is turning its back on this very successful program.
While this Executive Order is titled, “Planning for Federal Sustainability in the Next Decade,” it’s mostly about energy, energy, energy, water, and energy. But with this order, the Administration also quietly revoked the two previous Executive Orders (13423 and 13514) which established and maintained the very promising (albeit wonkily named) EPEAT program for electronics and which also required that 95% of the electronics purchased by federal agencies must be registered EPEAT products (for those categories where there is an EPEAT standard).
The EPEAT standards include energy efficiency, but also many other crucial sustainability issues, like limiting the use of hazardous chemicals, design for recyclability, sustainable materials use, use of certified recyclers, and sustainable packaging.
Federal agencies won’t have to buy EPEAT products
The new executive order never mentions EPEAT. It does try to claim to “promote sustainable acquisition and procurement” and specifies two ways for federal agencies to do that, beginning with the new fiscal year (October 2016). One way is to purchase environmentally preferable products or services that meet or exceed specifications, standards, or labels recommended by the EPA.
But it’s the other method (Option B) that spells the beginning of the end of the EPEAT program. With these references, the Executive Order allows federal agencies to buy products that meet practically any kind of voluntary standard, as long as the standard was developed using a so-called “consensus” stakeholder process:
(B) meet environmental performance criteria developed or adopted by voluntary consensus standards bodies consistent with section 12(d) of the National Technology Transfer and Advancement Act of 1995 (Public Law 104-113) and OMB Circular A-119.
“Consensus” process doesn’t mean a fair and balanced process for standards development
That sounds good, right, using voluntary standards developed by a “consensus” process including a wide group of stakeholders to identify what’s a preferable product? But in reality, the use of a so-called “consensus” process is no guarantee that the standard will be a strong standard, or provide meaningful guidance for federal purchasers to identify greener products. In fact, when it comes to sustainability standards, these consensus processes can be quite the opposite. They are easily dominated by companies that make and sell the products (and the chemical companies that supply them) despite other stakeholders participation. And many manufacturers typically don’t support criteria in these standards (even optional ones) that their products can’t already meet. So sustainability standards developed under the usual “consensus” process (without some additional requirements) are not likely to set a very high bar for sustainability.
That’s because most of these “consensus” standards use rules (“essential requirements”) developed by the American National Standards Institute or ANSI, which allow any single category of stakeholders to have as much as half of the votes, and calls that “balanced.” Any industry association can put together a process that technically meets that very low bar of a consensus standard, and then simply take what the industry is already doing and brand it as “green.” If this language is allowed to stand, government purchasing standards will devolve into a “lowest common denominator” approach favored by ANSI rules.
Strongest sustainability standards go beyond ANSI rules
In fact, this is such a problem that the strongest sustainability standards being used today – including LEED standards for green buildings, the Forest Stewardship Initiative (FSC) standard for lumber, and Fair Trade standards for farmers and other producers around the world (to name just a few) were developed outside the ANSI process because the groups developing them wanted to avoid the manufacturer domination that occurs with so many “consensus” processes. You can see the difference by looking at the high-bar standards’ weaker counterparts, developed under the ANSI rules, like Green Globes (for buildings) and the Sustainable Forestry Initiative (SFI) for lumber.
Why would the administration allow such a low bar for environmental standards, when they could easily have pointed to the EPA’s Guidelines for Product Environmental Performance Standards and Ecolabels for Voluntary Use in Federal Procurement? The EPA has done some very good work over the last four years developing guidelines for what kinds of standards and labels are worthy of the federal government’s use. Their current draft (about to be piloted) includes not just attributes of how the standards are created (like transparency, and balance), but also other critical things like whether there is an entity attached to the standard that can actually verify whether those claiming to conform to the standard actually do so.
Did the Administration unwittingly make these changes that spell the end of EPEAT? Or did the Obama Administration yield to pressure from the electronics industry? We know that the federal government has been the target of a relentless lobbying campaign by the industry association, the Information Technology Industry Council (ITI), who is unhappy with the EPEAT program, which has some additional guidelines that go beyond ANSI . In fact, after much debate, ITI lost a key internal struggle in 2013 when the EPEAT stakeholders voted to leave IEEE as their standards development organization (SDO) because of their unfair rules and switched to NSF as an alternative that provides a more level playing field and a more balanced process. Fearing a loss of their control of the process, ITI retaliated and started their lobbying campaign against EPEAT. Given the current language in the Executive Order, their campaign seems to have been successful. Even though there has been a robust stakeholder group (including ETBC) working productively over the last 18 months to resolve the concerns raised by the electronics companies with EPEAT program administration and verification, their lobbyist has continued to press for steps that will kill the program.
Will this Administration be remembered for killing EPEAT?
We are surprised that Obama Administration would want to be known (among other things) as the Administration that killed the EPEAT program. What a shame, after so many years of time and effort by so many people to help the government use its purchasing power to promote sustainability.
But that will be their legacy if they don’t take some immediate action to undue the harm they have set in motion. Today, we sent the Obama Administration a letter outlining the changes they could make to stop this unfortunate trajectory:
- They could modify the Executive Order to remove Option B and add in EPEAT; or
- In their implementing instructions to agencies for carrying out the order, they could:
- Recommend the use of EPEAT for electronics purchases; and
- Allow purchasers to use the consensus standards option ONLY if the EPA cannot recommend another standard or label for that product category
This can be fixed but only if the Whitehouse takes swift action.
NOTE: If you are with an organization, company, agency, school, or a certified electronics recycling company who would not like to see the EPEAT program disappear, please let the Whitehouse know. Send a letter to the Federal Environmental Executive, at the Whitehouse.
Click here for a sample letter.