Most electronics recyclers in developed nations — like you — want to do the right thing when it comes to environmentally and socially responsible handling of e-scrap. Many go to great lengths to ensure that their own on-site processes are in compliance and that the storage of materials of concern (also called focus materials or sensitive materials) is conducted appropriately. Often, however, the concerns about the material handling stop once these get to the other side of the dock door.

So, could this abandoned monitor in China possibly be one of your monitors?

The reality is that unless you have a very good downstream due diligence and vendor management system in place, you can’t really be sure where all the materials that leave your facility eventually end up.

Contact smartEE consulting to learn about easy ways to improve your downstream due diligence and establish accountability within your downstream vendor network and check out the detailed descriptions of our consulting services.

Brokers and vendors that merely collect and consolidate e-scrap materials to sell them to the highest bidder often lose track of their materials immediately. E-scrap recyclers with an established, vetted, and maintained vendor network usually have a better transparency — but even most of them stop short at following their materials all the way. This means following materials:

1. to their final destruction (common for materials of concern) while you are issued a Certificate of Destruction (CoD)
OR
2. until they are processed into a raw material stage (fully accounting for residuals)
OR
3. until repair/refurbishment turns them into functioning assets re-entering the wholesale-retail chain while accounting for waste parts and residual materials.

Unfortunately, while nobody openly admits to such illegal shipments, reality shows that today, every day, illegal shipments of containers filled with untested, waste-containing e-scrap arrive at ports in developing countries such as Hong Kong, China, Vietnam, Nigeria, or India, often in violation of the Basel Convention and national import restrictions.

In September 2008, the U.S. Government Accountability Office (U.S. GAO) published a report (click here for the report) that was picked up in a Washington Post article on September 17, 2008. The article detailed how little control the EPA has over illegal exports of electronics, including CRT monitors — and that despite the “CRT rule” having been in effect for 18 months.

On November 10, a CBS “60-Minutes” special on e-waste showed that municipalities — just as corporate and private entities — can be deceived by false domestic recycling claims. Honest and compliant recyclers may be losing bids for materials to brokers that have no control over their downstream material movements.

What would it mean to your customers and potential clients if you could offer documented proof that all of your materials are fully accounted for and processed in compliance with all laws and regulations?

smartEE consulting has extensive experience in helping you:

- Adjust your vendor contract language to better manage risk and set standards
- Evaluate your existing vendor network, if needed, by conducting on-site audits
- Track your material stream to the true point of final disposition
- Assess regulatory compliance of your transboundary shipments
- Evaluate your internal and external logistics processes and safeguards
- Establish a systematic vendor management and internal audit program

Contact smartEE consulting to learn about easy ways to improve your downstream due diligence and establish accountability within your downstream vendor network and check out the detailed descriptions of our consulting services.