MARCH 2009

Electronic waste exports monitored

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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.