Widely varying state regulations “generally depress exports” of used electronic products while increasing compliance costs and inefficiencies throughout the industry , according to a new study from the International Trade Commission.
The study, Used Electronic Products: An Examination of U.S. Exports, released March 8, also concluded informal and unregulated recycling of used electronics “remains a concern” and the fear of improper environmental management remains a primary reason why U.S. companies choose not to export more used electronic products.
ITC said the report was the first major attempt to quantify used electronic exports from a wide number of industries. It estimated domestic sales of used electronic products at $19.2 billion and exports at $1.45 billion.
More than 5,200 used electronics refurbishers, recyclers, brokers, information technology asset managers, and other companies handling the products answered surveys used to compile the report. U.S. Trade Representative Ron Kirk requested the report in a February 2012 letter to the ITC (25 DEN A-5, 2/8/12).
Four Main Types of Laws
The report found a “patchwork” of electronics recycling laws in 28 states has created the electronics recycling industry's “fragmented structure,” which does not allow for a nationally integrated collection and processing network.
It identified four main types of laws: producer responsibility laws, which require producers and retailers to fund and develop electronics recycling programs; consumer fee laws, which charge consumers a fee to responsibly manage products; landfill disposal fee laws; and electronic waste disposal bans.
“According to questionnaire respondents, state regulations discourage exports, particularly for processors, metals processing facilities, and recycling services organizations,” the report said. “State regulations do not directly affect exports of [used electronic products], but they do alter the cost structure and underlying economic conditions that companies face. Existing state laws have different rules, targets, processes, and product coverage, which create inefficiencies and additional compliance costs for organizations trying to create integrated national networks.”
Informal Recycling ‘Likely.'
The report said quantitative data on informal recycling of used electronics products were unavailable, but also concluded it was “likely” some portion of used electronics were managed at informal and unregulated facilities “either upon import or after a second or third useful life in the destination country.”
More than 40 percent of respondents said environmental concerns over how the used products might be managed discouraged them from exporting more of them.
The report concluded informal recycling operations use practices that endanger human health and the environment.
“[Used electronic wastes] frequently contain harmful chemicals such as lead, mercury, cadmium, brominated flame retardants (BFRs), and polyvinyl chloride (PVC),” the report said. “Residues containing these chemicals are left over from the extraction process and are oftentimes dumped into nearby fields, irrigation channels, or streams.”
The report noted that environmentalists and industry participants disagreed on the scale of the informal recycling in the industry.
Industry Praises Strong Data
Neil Peters-Michaud, a steering committee member for the Coalition for American Electronics Recycling and chief executive officer of Cascade Asset Management, a used electronics management company, said the report confirmed the size of the used electronics recycling industry while recognizing the limitations of collecting data through surveys.
“There could be an inherent bias in the survey, because it is not likely someone will be writing they're breaking the law,” Peter-Michaud told BNA. “ITC did a good job recognizing the limitations of the findings based on the survey bias.”
Robin Wiener, president of the Institute of Scrap Recycling Industries, welcomed the “very extensive study” and praised ITC for including census data and information from hearings and meetings, in addition to the survey data.
She said the strong data from the report would advance discussions in the electronics recycling industry beyond anecdotal reports that are often outdated.
Barbara Kyle, national coordinator of the Electronics TakeBack Coalition, an environmental advocacy group, said the report did not accurately capture the size of the industry by not including small electronics recycling companies and using a survey as its primary means of data collection.
“The report admits that they didn't include smaller companies, 10 or less employees, for the survey,” she told BNA in an email. “That rules out a whole lot of the brokers, and the people who have exporting as their very business model, so it skews the data. I don't think there is any way a survey will ever accurately capture the kind of e-waste exporting that goes from the U.S. to developing countries.”