The United States International Trade Commission released a report on March 8, 2013 titled “Used Electronic Products: An Examination of U.S. Exports.” (see https://www.usitc.gov/publications/332/pub4379.pdf). This 250 page report details the process the commission took to collect information from organizations involved in the industry (through surveys, public hearings, facility tours and interviews) and also through a review of Customs records of exports of IT devices, which they term “Used Electronic Products” or “UEPs.” It then presents findings from their research.
This is an important body of work that contributes to the overall discussion about the scale of the electronics recycling industry, its contribution to “clean” and “dirty” exports, and what we should do to improve the industry overall.
That being said, the report is honest about the limitations of its data collection methodology to provide an authoritative set of conclusions about the UED industry and exports. For example, the report stated, “Relying on survey data presented several challenges to the Commission’s findings. The results of the Commission’s questionnaire have been aggregated and weighted to provide estimates about a broader population, with results that may be skewed towards nonexporters or responsible exporters that responded to the questionnaire, as well as to larger firms, since very small firms were not surveyed.” (Page 1-8).
There are many other instances where the report questions its own veracity and acknowledges biases in its methodology. As a result, readers should be careful about drawing certain conclusions from the report. Anyone who claims that the report says exports of untested or unprocessed UEDs are not a problem did not read the full report. The report states, “Informal and unregulated recycling of exported UEPs remains a concern within the industry. No quantitative data on this segment of the industry are available, but some descriptive information is included in this report.” (p. xviii)
In general, I believe the industry should carefully consider the findings of report, while concurring with the authors that the report has limitations in its ability to ascertain the true amount of export of untested, non-working and hazardous e-waste to developing countries. The report makes some very important findings:
- The amount of exports of used electronic products (UEPs) is significant and Congress should take notice. The report finds that 757,721 tons of UEPs were exported by the US in 2011. (p. 5-2). That number may even be under-reported. That’s a lot of electronics!
- There are a large number of firms engaged in this enterprise. The survey included responses from 2,670 organizations out of a total of 4,701 qualified U.S. firms. Again, this is clearly a significant U.S. industry. They did not even include firms with less than 10 employees in this group.
- The study commented on the Responsible Electronics Recycling Act (RERA) and said, “However, [if RERA were enacted into law] the product mix [of export] would likely change to reflect more tested and refurbished products and fewer end-of-life products [exported]. Conversely, exports of commodity-grade material would likely increase, as more recycling activity would take place in the United States and UEP-derived commodities would be exported to manufacturing centers in non-OECD countries.” (p. 6-8). This is a great argument in support of RERA.
- The testimony from business owners captured in this report who oppose outright bans on the export of electronics to developing countries also admit to exporting tested, working equipment abroad. This activity is actually supported in RERA, since it does not ban the export of tested, working equipment. We need to clear up this myth because a law like RERA actually helps protect and encourage this export of tested, working, and clean processed commodities and would be good for their business.
- The study makes numerous references to the concern from businesses, NGOs and others about the export of electronics to the informal sector in developing countries. It recognizes that e-waste export concerns are not relegated to a fringe group, but are shared by a wide range of businesses.
- ITC recognized that the veracity of respondents to the survey may be questioned and that people may not want to report illegal shipments of electronics overseas, so the findings should recognize that bias.
There are many interesting points made throughout the report that warrant discussion and debate. That’s a good thing. But we also need to be careful to not claim this report draws conclusions that just aren’t there.