Resource Recycling
  • The Latest
  • Podcast
  • Analysis
    • All
    • Certification Scorecard
    • Industry Announcements
    • Opinion
    e-Stewards to develop an ITAD-specific standard

    Certification scorecard — week of Nov. 2

    Groups publish national recycling acceptance data

    PC shipments slump as data center investment surges

    Apple: iPhone upgrades soar amid rising memory costs

    Artificial intelligence is altering the marketplace for ITAD providers in numerous ways. | Shutterstock

    AI alters ITAD economics

    Industry announcements for January 2026

    Industry announcements for November 2026

    Auto Draft

    Designing repairability empowers device users

  • Conferences
    • Resource Recycling Conference
    • Plastics Recycling Conference
    • E-Scrap: The Longevity Conference
    • Textiles Recovery Summit
  • Publications
    • E-Scrap News
    • Plastics Recycling Update
    • Policy Now
    • Resource Recycling
    • Other Topics
      • All Topics
      • Brand Owners
      • Critical Minerals
      • Glass
      • Grant Watch / RFPs
      • Markets
      • Organics
      • Packaging
      • Research
      • Technology
      • Textiles
Subscribe
No Result
View All Result
Resource Recycling
  • The Latest
  • Podcast
  • Analysis
    • All
    • Certification Scorecard
    • Industry Announcements
    • Opinion
    e-Stewards to develop an ITAD-specific standard

    Certification scorecard — week of Nov. 2

    Groups publish national recycling acceptance data

    PC shipments slump as data center investment surges

    Apple: iPhone upgrades soar amid rising memory costs

    Artificial intelligence is altering the marketplace for ITAD providers in numerous ways. | Shutterstock

    AI alters ITAD economics

    Industry announcements for January 2026

    Industry announcements for November 2026

    Auto Draft

    Designing repairability empowers device users

  • Conferences
    • Resource Recycling Conference
    • Plastics Recycling Conference
    • E-Scrap: The Longevity Conference
    • Textiles Recovery Summit
  • Publications
    • E-Scrap News
    • Plastics Recycling Update
    • Policy Now
    • Resource Recycling
    • Other Topics
      • All Topics
      • Brand Owners
      • Critical Minerals
      • Glass
      • Grant Watch / RFPs
      • Markets
      • Organics
      • Packaging
      • Research
      • Technology
      • Textiles
Subscribe
No Result
View All Result
Resource Recycling
No Result
View All Result
Home Analysis Opinion

In My Opinion: With trackers, BAN ignores its own advice

byJohn Lingelbach
September 14, 2017
in Opinion
In My Opinion: With trackers, BAN ignores its own advice

John Lingelbach

John Lingelbach

The Basel Action Network (BAN) has issued a second report presenting information derived from its GPS tracking activities. Like the first report from a year ago, this report names electronics recyclers and leaves the casual reader presuming each named recycler is complicit in illegal exporting (part of an “export chain,” as BAN puts it).

GPS trackers can be an effective tool for identifying potential wrongdoing that warrants further investigation. However, GPS trackers alone do not provide sufficient information to indict a recycler in the court of public opinion for complicity in illegal exports.

BAN knows this. Yet it ignores its own advice, as noted in its September 2016 report: “The presence of any particular company being listed as part of an ‘export chain’ by itself is not an indicator of irresponsible behavior.”

It is not surprising that BAN bases its accusations solely on GPS tracking information. The resources it takes to go further and conduct a thorough investigation of a facility identified by a tracker are substantial. And yet this is the only way to determine the degree of guilt, if any, of a recycler. It is irresponsible to name recyclers in connection with trackers that traveled overseas without such investigations.

Even the “apparent exporters” (BAN’s term for the last facility in the U.S. that a tracker passed through) may not be guilty. A few of the “apparent exporters” identified in the first report a year ago were not, in fact, the exporters. Instead, they sold to U.S.-based buyers and some may have believed – even after a good faith effort at due diligence – that their shipments would not be illegally exported.

In its September 2016 report, BAN describes “three primary categories of companies” caught up in its tracking activities:

  • First, there are “those that willfully export” despite knowing that, given the destination country, the shipment is illegal and may cause harm to workers, communities and the environment.
  • Second, there are “those that are not aware of the export taking place downstream of their operation. But this ignorance may be more due to the fact that they do not want to know, or do enough to find out.”
  • Third, there are “those that have taken all steps and have made great effort to ensure against [illegal] export. … However, this ethical actor may nevertheless be an innocent victim of fraud by a downstream vendor they trusted.”

The report goes on: “For the reasons laid out above, it is impossible to assert definitively that mere appearance within the chain of export means that the company is irresponsible or responsible.” Indeed.

Not intending for illegal export

So, is the electronics recycling sector “an industry that far too often lives a lie, cloaking themselves in green and using the word ‘recycling’ as a shameful shield,” as BAN’s executive director is quoted as stating in BAN’s recent press release? Well, there are some bad actors in the industry – companies willing to falsify shipping records or perhaps undertake actions like knowingly presenting an upstream recycler with a Hong Kong “generator permit” claiming that it is an “import permit.”

However, after hundreds and hundreds of hours investigating “export chains” – conducting site visits; sorting through bills of lading, invoices and other documentation; communicating with the Hong Kong Environmental Protection Department; and working with international environmental law attorneys – it appears to SERI staff that most of the electronics recyclers identified in BAN’s tracker reports that we investigated had shortcomings in their policies and procedures but did not intend, nor were they aware, that illegal exporting was occurring downstream.

Effective downstream due diligence can be an incredibly arduous task – and where fraud is involved, it can be virtually impossible. Many companies and auditors need to learn more about what to look for and put more time into their review of downstream documentation. The same goes for the legality of exports. For example, Hong Kong prohibits by law the import of non-working monitors, regardless of the type or whether they contain a hazardous substance. Companies need to fully comprehend the facts pertaining to different destinations.

BAN has a mission that includes stopping the export of hazardous electronic wastes from developed to developing countries. It is a good and important mission. With respect to its use of GPS trackers, however, BAN shows a willingness to throw the proverbial baby out with the bathwater.

The harm caused to many good recyclers in loss of business and reputation is substantial. And it could be avoided. What is needed in conjunction with GPS tracking is solid investigative work. It takes time and resources, but it would lead to better results that, possibly, the industry could get behind.

John Lingelbach is executive director of Sustainable Electronics Recycling International (SERI), which administers the R2 electronics recycling standard.

 

The views and opinions expressed are those of the author and do not imply endorsement by Resource Recycling, Inc. If you have a subject you wish to cover in an op-ed, please send a short proposal to news@resource-recycling.com for consideration.

 

Tags: Trade & Tariffs
TweetShare
John Lingelbach

John Lingelbach

Related Posts

Dow bullish on PE pricing into 2027

Dow bullish on PE pricing into 2027

byAntoinette Smith
October 23, 2026

Executives cited elevated feedstock costs, lower inventories and constrained production resulting from the US war in Iran as support for...

APR, PROs appeal to Ottawa for help

APR, PROs appeal to Ottawa for help

byAntoinette Smith
October 6, 2026

APR and Circular Materials say policy goals risk failure without government actions that acknowledge market realities.

Analysis: Undersupply of PCR is ‘stifling’ brand goals

US lawmakers urge protection of domestic RPET

byAntoinette Smith
September 25, 2026

In a letter to the US Trade Representative, five representatives asked the USTR to consider trade remedies and support verification...

Canada tariffs latest in new normal for RPET

Canada tariffs latest in new normal for RPET

byAntoinette Smith
September 11, 2026

Tensions with the valuable trading partner have frayed nerves for over a year, but North American markets already have tariff...

Bags of collected agricultural twine for Cleanfarms twine recycling contest

News in Brief: August 10, 2026

byIsabella Burke
August 10, 2026

An Alberta twine recycling contest, Pellitteri expands waste and recycling services into the Milwaukee area and the Canadian government awards...

New federal rule restricts black mass, tungsten scrap exports

byStefanie Valentic
August 5, 2026

A new BIS rule requires US sellers of black mass and tungsten scrap to allocate 100% of monthly sales domestically...

Load More
Next Post
Project to shine light on changing e-scrap stream

Project to shine light on changing e-scrap stream

2026 Buyers’ Guide

Equipment, services and technology suppliers serving the recycling industry.

Browse the Guide

More Posts

DOE reinstates $375m Eastman recycling grant

DOE reinstates $375m Eastman recycling grant

October 30, 2026
Apple looks to spark growth of e-scrap recycling

Apple looks to spark growth of e-scrap recycling

October 28, 2026
Paladin acquires R&L Recycling, enters European ITAD market

Following the money in hardware circularity

October 5, 2026
A Republic Services truck picks up a recycling cart in Fort Collins, Colorado.

Republic reports higher recycling revenue

November 2, 2026
Bale pricing mostly flat for September

Northeast recycled commodity prices rise in Q2

October 30, 2026

LYB looks to EU for chem recycling growth

November 2, 2026
Electronics makers pitch EPR playbook ahead of 2027 sessions

Electronics makers pitch EPR playbook ahead of 2027 sessions

October 28, 2026

NJ solar panel recycling rules face legal review

November 2, 2026
E-Scrap Conference honors industry leaders

E-Scrap Conference honors industry leaders

October 28, 2026
New CAA chief talks markets, industry support

New CAA chief talks markets, industry support

November 4, 2026
Load More

About & Publications

About Us

Staff

Archive

Magazines

Work With Us

Advertise
Jobs
Contact
Terms and Privacy

Newsletters

Get the latest recycling news and analysis delivered to your inbox every week. Stay ahead on industry trends, policy updates, and insights from programs, processors, and innovators.

Subscribe

Welcome Back!

Login to your account below

Forgotten Password?

Retrieve your password

Please enter your username or email address to reset your password.

Log In

Add New Playlist

No Result
View All Result
  • The Latest
  • Podcast
  • Analysis
  • Recycling
  • E-Scrap
  • Plastics
  • Policy Now
  • Conferences
    • E-Scrap Conference
    • Plastics Recycling Conference
    • Resource Recycling Conference
    • Textiles Recovery Summit
  • Magazines
  • About Us
  • Advertise
  • Archive
  • Jobs
  • Staff
Subscribe
This website uses cookies. By continuing to use this website you are giving consent to cookies being used. Visit our Privacy and Cookie Policy.