Computer Recycling Regulations - A Discussion

Is restricted trade in e-waste "protectionist?"

I've heard opponents to the Responsible Electronics Recycling Act claim that is is just another protectionist trade policy that hurts US business.  Regulation can always impact businesses, but the companies that adapt to comply with these new requirements will succeed.  The purpose of government regulation should not be to hurt or help business, it should be to protect the common good of the people who enact it. 

Our country has historically restricted the trade of hazardous waste and the export of products/information that pose a threat to national security.   That’s what this bill will do. 

E-waste is generally considered a hazardous wastesince TCLP tests demonstrate that most electronics with circuit boards, fluorescent lamps, CRT screens and batteries contain sufficient concentrations of hazardous materials to classify them as a hazardous waste.  In addition, there are documented cases of sensitive and classified information found on recovered media from unprocessed electronic equipment shipped from the US to developing countries.  This represents a real national security risk.  In the past, Commerce has restricted trade of information technology equipment to certain countries who are enemies of America.

It’s also important to recognize that in no way does the bill enact a wholesale ban on the trade of electronics or e-waste.   There is a restriction on what can be exported to developing countries, but any electronic product or e-waste can be exported to other OECD countries where it is more likely there is a sound process for managing this waste and protecting our secrets.

I believe tested, working electronic products should be freely traded, and this practice is preserved by the bill.  I also believe processed commodities that do not contain “restricted electronic waste” should be freely traded. 

A concerned and an informed citizenry must restrict the wholesale export of untested, non-working e-waste to developing countries.  It is just the right thing to do.  Businesses will adapt.

Can a domestic e-waste industry build capacity effectively if exports were banned?

I was surprised when I was again asked by government officials in Washington, DC about whether the American electronics recycling industry can ramp up capacity fast enough to absorb the onslaught of unprocessed electronics that will no longer be allowed to be exported to developing countries if the Responsible Electroncis Recycling Act passes Congress.

First of all, the export ban in the proposed legislation goes into effect 2 years after its enactment.  This affords the industry sufficient time to develop plans, make investments, install equipment, hire staff, and essentially grow to meet the expected increase demands from this change. 

In addition, industry representatives from the Coalition for American Electronics Recycling report that they all currently have significant excess capacity and can add work shifts (employing more people) and increase processing equipment utilization without additional capital outlays. 

Third, the same concern was raised earlier about the industry developing a collection infrastructure to respond to state landfill bans of e-waste.  But this problem (lack of capacity) never materialized because firms were able to quickly set up or grow appropriate resources to meet the new demand.  In California, hundreds of companies registered as Collectors for that state’s e-waste recycling program within two years of its enactment.

In the business world, growing capacity to meet increased demand for products or services is a challenge we are more than happy to solve.  Government officials have no reason to be concerned about whether business wants to make investments, create jobs and boost profits by ramping up capacity to meet increased demand for services.

Launch of website for Coalition for American Electronics Recycling

A new website for a business group of electronics recyclers was just launched today at www.americanerecycling.org.  The website contains a wealth of information about the proposed Responsible Electronics Recycling Act (HR 2284 / S1270) now in front of Congress. 

The Coalition for American Electronics Recycling represents U.S. companies that believe electronics recycling should be performed securely and sustainably, for the benefit of the American economy. It is committed to growing an American industry with the capacity to manage the volume of e-waste generated within our borders, creating good jobs and expanded trade.

The Coalition of independent businesses was formed in the summer of 2011 to demonstrate to Congress that businesses do support the passage of the Responsible Electronics Recycling Act.  Cascade Asset Management is one of the companies directly involved in this campaign.