Illegal e-waste exports: urgent action required

Both have made an excellent job of exposing the illegal export of e-waste from the UK to developing countries and how it is facilitated by our own legislation. The consequences for human health and the environment in those countries are wholly unacceptable so we hope that the report and the Panorama investigation will help compel the government to take urgent action to put an end to the practice.

The EIA report and Panorama investigation highlight a number of important issues which need to be addressed if the problem of illegal exports is to be tackled effectively. One of these is the requirement for ‘re-use’ in the WEEE directive, which whilst laudable, has inadvertently created a loophole where e-waste can be exported to countries outside the EU under the guise of being for ‘re-use’.  As the EIA and Panorama investigation revealed, much of this equipment is not tested before export and in reality will be mined to recover its precious metals in an unhealthy and environmentally damaging manner when it reaches its destination.

An important finding in the EIA report is the extent to which Local Authorities are allowed to sell WEEE from their CA sites to third parties for export. This practice is the source of most exports for ‘re-use’ and should be stopped immediately and replaced with a requirement to sell to legitimate recyclers only.  At the same time a system should be introduced to allow legitimate exporters to notify the authorities in advance of a shipment so that spot checks can be carried out on containers which have not been pre-notified and checks can be made on containers labelled as equipment for ‘re-use’.

In addition to the practice of selling WEEE from CA sites, we believe that in the UK, the root of the problem lies in the large number of Producer Compliance Schemes – thirty six - more than in any other EU country.  These schemes operate in competition with each other without robust enforcement from government regulatory bodies.  This competition is proving unhealthy because many of the schemes place low-cost ahead of the ability to demonstrate treatment to the appropriate standards and best available technology.

This in turn is putting more pressure on the better schemes to equal these costs which is resulting in down-channel stress in the recycling sector.  As well as lowering prices, this has undermined the legitimate recycling market and provided an added incentive for illegal trade.  In our experience, only a select few of the schemes have demonstrated any desire to effectively audit the supply chain and ensure that the interests of the producers and society are being met.

The EIA report rightfully identifies the duty of care obligations which are flouted through illegal exports.  Action to audit the supply chain to provide a full chain of custody is vital if all players within the chain of WEEE recycling are to fulfil their duty of care obligations and ensure that the requirements of both waste and WEEE legislation are achieved.

Sims Recycling Solutions’ Jon Godfrey said.  “In summary, we believe that by banning the sale of WEEE from CA sites to third party exporters, reviewing Producer Compliance Schemes to change the focus from cost to quality, introducing a full audit trail into the sector by keeping records of all e-waste left at Designated Collection Facilities, increasing spot checks at ports and above all, taking robust punitive action against those operating illegally, the government can make significant inroads into reducing illegal exports of e-waste to third world countries.”

More Information and useful links:

• Find out more about the Panorama episode and watch it again on the iplayer here
• Download the report from the EIA website