Last November, CBS’s 60 Minutes
opened millions of eyes and minds
to the problem of a Denver recycling
company exporting container loads
of whole electronic goods to the
town of Guiyu in southern China,
where primitive recycling was graphically
shown to cause serious health and
environmental hazards. While it sensationalized
the unscrupulous practices of one
exporter and the frightening dangers
of primitive recycling techniques,
it also gave a black eye to the American
electronic recycling industry. It
also failed to mention that China
has some of the world’s most
innovative, sophisticated recycling
parks located throughout the country.
For example, Chinese scientists recently
developed a way to recycle printed
circuit boards into a strong material
to make park benches and fences.
Circuit boards account for approximately
three percent of the weight of
all electronic waste. Current recycling
methods primarily recover only
metals, while resins account for
70 percent of the circuit boards
that currently go to incineration
or landfills.
All countries, whether highly developed
or developing, face a common challenge
when it comes to e-waste – how to
recycle or responsibly export used
electronic products that have value.
What one country considers garbage,
another may see as gold. Televisions,
computers and cell phones are often
thrown out, not because they do not
function, but because they have been
surpassed by better technology. The
era of the electronic repair shop
has faded. Busy, advanced economies
find it is troublesome and expensive
to have something fixed, and convenient
to discard and replace.
Many items can be easily repaired
and refurbished to extend useful
life. This is recycling of the highest
order – getting ultimate value out
of labor and material that went into
a product while reducing demand on
raw materials.
It is also sound business to export
used electronics to foreign recyclers
that operate safe, environmentally
sound facilities. Just as many Asian
countries have revolutionized consumer
product manufacturing with low labor
costs and modern plants, their attention
is being refocused on the profitable
demanufacturing of electronic goods,
wether imported or their own increasing
e-waste.
“We have to look to the most sustainable
solution. A ban on the export of
whole units is not the solution.
What we need are the tools to find
a responsible recycler anywhere in
the world. Then we must ensure that
materials only go to those types
of facilities,” said Eric Harris,
director of government and international
affairs at the Institute of Scrap
Recycling Industries (ISRI).
If every country could handle its
own electronic recycling within its
borders in a safe and environmentally
secure manner, the problem would
disappear. The most difficult issue
is the cost of recycling and who
pays for it. Items that have positive
value such as laptops, cell phones,
CPUs and copiers are easier and profitable
to refurbish or recycle and less
likely to be exported from the United
States. Other items such as computer
peripherals and particularly televisions
and monitors with CRTs and miscellaneous
household electronics usually have
a negative value to recycle, unless
performed by a savvy recycling company
using high technology equipment with
a tight reign on overhead costs and
ready markets for the recovered materials.
Taking bigger bites out of electronic
exports are a quickly growing number
of United States e-waste material
recovery operations. Often requiring
a multimillion dollar capital investment,
these behemoth machines can ingest
tons of electronic waste per hour
to shred and separate components
such as ferrous metal, copper, aluminum,
precious metals and plastics.
Many believe that Homeland Security,
EPA and other government agencies
need to do a better job to control
the export of e-wastes through stronger
enforcement and more comprehensive
regulations. The EPA’s 2006 CRT rule
was an early attempt to discourage
the export of CRTs by simply making
it difficult and cumbersome to do
so.
The rule requires that recyclers
notify EPA when they plan to export
used or broken CRTs. EPA then notifies
the receiving country of the shipment.
If the CRTs are intact and for reuse,
the recycler must send a one-time
notification to EPA before export.
In this case, there is no requirement
to notify the receiving country.
Failure to meet the complex conditions
of the CRT rule is subject to enforcement
action under the Resource Conservation
and Recovery Act (RCRA). The rule
also covers recycling done within
the United States when recyclers
disassemble CRTs for glass, lead
or plastic and exempts CRTs from
all hazardous waste requirements,
if the recycler complies with certain
conditions. At the same time, CRTs
have a conditional exemption from
the EPA and can be put in the majority
of United States landfills with the
exception of those states that have
banned it.
So it seems that exporters are on
an honor system in regard to CRTs.
Those with the patience to understand
complex regulations, invest time
and energy filling out forms and
willing to assume enforcement exposure
can freely export. It is up to United
States Customs to monitor, or inspect
cargos being exported. Of all imported
and exported cargo, Customs only
physically inspects approximately
two-percent – inspection meaning
actually opening a container and
looking inside.
With heightened homeland security
concerns, most attention is focused
on imports, not exports. Ninety-eight
percent of containerized cargos are
approved electronically by Customs
relying on the reputation of the
freight forwarder and the description
of the cargo on the declaration.
Sneaky CRT exporters can, and do,
provide nefarious descriptions of
cargo to avoid detection by Customs.
Containers arriving at foreign ports
face the same problem and many developing
countries have looser custom’s inspections
than ours. Hong Kong officials intercepted
and returned 26 containers of illegally
exported CRTs to the United States,
but this is likely a small fraction
of what is being shipped.
After the CRT rule went into effect,
the United States General Accounting
Office (GAO) did a study on used
electronic exports. GAO operatives
posed on the Internet as foreign
buyers from Hong Kong, India and
other countries and offered to buy
broken CRTs from the United States.
Forty-three United States companies
responded and expressed willingness
to export these items. EPA acknowledged
compliance and enforcement problems
with its CRT rule, but said that
given the rule’s relative newness,
their focus was on educating the
regulated community.
Beyond dealing with stricter enforcement
of the CRT rule, the EPA is currently
evaluating a number of options recommended
by the GAO – expanding hazardous
waste regulations to cover other
exported used electronics; submitting
a legislative package to Congress
to ratify the Basel Convention (International
treaty addressing cleaner production,
hazardous waste minimization and
controls on the movement of wastes);
and working with departments within
Homeland Security and other agencies
to improve identification, tracking
and enforcement of exported used
electronics.
The fate of e-wastes and exports
is now in the hands of Lisa Jackson,
the recently confirmed EPA administrator.
No doubt EPA has the capability to
write further complicated regulations
to further confuse e-waste exports.
“One of the main issues that needs
to be addressed is an honest examination
of what waste is, what is non-waste
and what hazardous waste is. Our
ISRI members primarily process these
materials into a specification grade
commodity. At that point we don’t
consider those materials a waste.
There are advocacy groups that will
say it’s all hazardous waste. That’s
a disservice and one of the problems
that we are constantly working against,”
said Eric Harris.
Clearly, e-waste is a global problem.
60 Minutes could have easily done
a story on a European country illegally
exporting unprocessed goods to a
developing country. 60 Minutes should
also have given credit to states
like California (seventh largest
economy in the world), eighteen other
states and New York City that have
enacted e-waste recycling laws. The
surest way for any country to prevent
export of e-waste is to collect and
recycle within its borders. California’s
groundbreaking Electronic Waste Recycling
Act of 2003 sought that goal.
Under the Act, the state collects
fees on the sale of new products
with viewable screens. These fees
reimburse recycling centers that
provide no-charge recycling to consumers
and businesses. Retailers and manufacturers
can be fined for failing to collect
and remit the fee to the state. In
effect, the fee is a tax to pay for
responsible disposal.
In 2009, the fees went up: a 4” screen
went from $6 to $8, and those over
35” from $10 to $25, which are substantial
increases. But someone must pay,
be it the consumer, the manufacturer
or a shared cost.
Another part of the California Act
went into effect in January 2007
and it severely limits the amount
of cadmium, hexavalent chromium,
lead and mercury that can be contained
in electronic products sold in the
state. It applies to all CRT, LCD,
and plasma displays in televisions,
computers, and other electronic equipment
with a diagonal screen size over
4”. Minimizing the amounts of hazardous
materials in products is another
path being widely explored.
Manufacturers have also become proactive
with a wide range of equipment recovery
programs to manage end-of-life products,
either to green their brand image,
or because compelled by state laws.
Some will take old products as trade-ins
on new ones and either resell or
responsibly recycle. Most major manufacturers
offer free take-back programs to
their customers and either recycle
themselves or contract out the service
to responsible e-waste recyclers.
“Ultimately, electronics recycling
will be driven by the fundamentals
of supply and demand. A ban on exports
is a bad idea because the vast majority
of all materials coming out of electronics
have to be exported,” Harris added.
