Waste or resale?
Currently there are problems distinguishing what constitutes waste. Flemmich Webb finds out how we can determine which items are fit for recycling and reuse
With the advent of the WEEE Directive, new waste acceptance criteria at landfill sites and a redefining of what is hazardous waste under the Hazardous Waste Regulations, waste legislation has never been tighter. Meanwhile, local and international agencies are starting to have some success controlling the export of waste too.
The Dutch authorities recently turned back UK waste exported as fit for recycling which was in reality regular household waste. However, there are also non-waste exports causing concern - those carrying electronic equipment classified as fit for reuse. In most cases there is nothing wrong with this - companies wanting to get rid of old but still functioning electronic equipment can quite legitimately send it abroad for resale via a dealer.
Problems arise, however, when it comes to deciding what classifies as equipment for resale and what is waste. If it needs a minor repair to function again - such as the replacement of a fuse or button - it is considered okay for resale and is therefore not subject to waste transport laws. But a cracked monitor screen would lead to a classification as waste, which triggers waste disposal and handling charges. This provides a huge incentive for companies keen to avoid rising hazardous waste and landfill charges to include waste in shipments intended for genuine reuse.Sham operations
The Environment Agency realises this goes on, but is not sure on how wide a scale. Adrian Harding, policy advisor on producer responsibility, says: "While there is a huge legitimate trade in second use goods which we welcome, there are also sham operations which buy up equipment for resale, don't check it and ship it to whoever. This can be done with or without the knowledge of the receiving company. UK dealers get a double incentive - they avoid landfill charges and the receiving companies or countries might pay for the shipment."
This is confirmed by an industry source, who told Environment Business that brokers are doing deals with companies with waste they're looking to get rid of." Harding points out that for some countries, receiving a shipment of electronic goods of which only 30% works is still financially viable, so keen are they to get their hands on raw materials.
Claire Snow, director of the Industry Council for Electronic Equipment Recycling, agrees there are problems about the definition of what constitutes waste. "We do need standards for what is allowed to be sent for reuse. At the moment, equipment is allowed which require minor repair but what constitutes a minor repair?"Dumping grounds
"What will happen," says Harding, "is that people in developed countries will see non-OECD countries as dumping grounds." This leads to the other problem concerning reuse shipments - one of disposal at the end of its secondary use. Many countries in the developing world do not have the infrastructure to cope with recycling electronic equipment, and some are increasingly concerned about this lack of disposal regulation.
Charity Digital Links has just begun a pilot project to see what can be done with end-of-life computers in Ghana. The project aims to recycle 1,000 computers in a low-cost, low-tech way. The charity is also working on techniques to recycle the glass and cathode ray tubes from monitors.
Chief executive David Sogan says if the exporters are responsible, there is no problem. But many, he fears, are not. "The end-of-life issue doesn't come into it if the exporting is being done with a responsible partner; otherwise they pass the problem to a refurbisher or asset management company, which doesn't know where it is selling equipment to. We want to encourage exporters to consider these issues." But Joy Boyce, head of corporate environmental affairs at electronics company Fujitsu Services, says companies can not be expected to know what happens to equipment at the end of its secondary life, and that: "As part of corporate social responsibility many companies do try to find out what is happening way down the supply chain."Supply chain responsibility
In the meantime, ICER is talking to the Agency about setting minimum standards for reuse, while the Agency, through IMPEL, the European network of regulators, is planning more inspections at ports.
"There is a reliance on everyone in the chain to describe items fully and accurately," says Harding. "We need to raise awareness, and although you may make money and the person at the other end is happy to accept goods that don't work, it doesn't mean its legal. It won't be long before we start seeing the repatriation of electronic waste."
However, the fact remains that it is a difficult area to police and as long as there is an appetite for raw materials, the UK and other European companies will continue to export waste as though it was for reuse and developing countries will have to dispose of it as best they can.