E-Scrap News has now published responses from five of the six companies named in Basel Action Network’s latest export report (“The Scam Recycling Continues”). In their statements, those companies have made some assertions that warrant a response. In addition, one of the company responses noted a geographic error in the recent report, and we wish to publicly correct that fact. The inaccuracy, while regrettable, has no bearing on the findings of export in the report.

Jim Puckett

Jim Puckett, Basel Action Network

What follows is the BAN response to each of the five reactions from e-scrap processors.

Allied Ecovery: The latest company perspective, appearing in E-Scrap News on Feb. 1, was from Allied Ecovery. The processor postulated that the tracker used to pin Allied to a chain of export must have been manually separated from the LCD monitor it was installed in, then placed into the plastic stream, added to a bale, and exported as plastic waste in compliance with laws and the R2 standard.

In an extended explanation we have posted online, we conclude that such a theory is in fact highly implausible. Additionally, if it were possible, this export would clearly be a non-compliant with the law and with R2, as our current trackers do not contain plastic except as shrink-wrap and circuit board substrate but do contain batteries and a circuit board, both of which are “focus” materials.

Advanced Technology Recycling: ATR published a lengthy rebuttal of BAN findings on its website, and an abbreviated version of the response appeared in E-Scrap News alongside three other responses on Jan. 25.

ATR claims that BAN is on a “witch hunt” and is trying to “discredit companies not willing to certify to the e-Stewards standard.” BAN has always denounced companies that export their hazardous e-waste to developing countries, and the organization has created and promoted the e-Stewards Standard precisely because R2 does not always prohibit such exports. However, we do in fact have a full-time, ongoing Performance Verification program that routinely places GPS trackers into the input streams of recyclers certified to e-Stewards, especially “targeting” them in this regard.

To be clear, in our first GPS tracking report, “Scam Recycling,” we endeavored to distribute our trackers statistically in accordance with the existent proportion of R2, e-Stewards, and uncertified companies so we could assess the relative percentage of companies found within export chains within each category. With that balanced approach, we discovered that R2 exported at a higher rate than even uncertified companies, and companies certified to e-Stewards were exposed in export chains at the lowest rate of all categories. Nevertheless, in the course of that study, we caught, exposed and removed a founding e-Stewards-certified recycler, Seattle-based Total Reclaim.

Since that initial study, the intent and purpose for deploying trackers based on our funders’ wishes is different. The new objective is now “citizen enforcement” rather than trade analysis. Our deployment decisions thus are now made on the basis of risk, and our risk profile does not include certification as a criterion.

ATR also expressed confusion regarding geographic coordinates given in our report, and on this point we acknowledge a mistake. The latitude and longitude points listed for the Pakistan destination of the ATR tracker were erroneous. This has now been corrected in the online report. We understand ATR’s confusion in this regard, and we apologize for the error. However, this mistake does not change the narrative reported in any way.

Finally, ATR has asked us to provide the company with more detail on the export chain we revealed. We have provided this information to ATR via email. The company has also asked for a list of all 60 companies in the U.S. where we deployed trackers. We will certainly provide that list for the three states of Florida, Georgia, and Texas when the 60 devices delivered there are no longer active.

Arc Broward IT Asset Recovery: Arc Broward representatives have written that they are going to take corrective actions with respect to their downstream vendor that has failed to comply with laws rules and guidelines. We applaud Arc Broward for using our data in a positive way.

CompuCycle: CompuCycle has written that BAN tried to besmirch the company’s reputation, but that was not our underlying intent. We are simply trying to end unethical, illegal and environmentally damaging exports of electronic waste by providing evidence of export to companies and to the public and law enforcement.

Raki Electronics Recycling: Raki expressed surprise and disappointment and have initiated an internal audit to conduct due diligence on the matter. We also applaud Raki for using our data in a positive way.

Ready to help firms with downstream tracking

BAN continues to find that the use of GPS trackers to expose illegal and unethical exports of electronic waste is a powerful tool and motivator. Our first commitment in this regard is to conduct such tracking within our own e-Stewards certification program. But it is our goal also to ensure that the entire industry and all standards respect human rights and the environment and comply fully with the Basel Convention and its decisions.

Responsible recycling companies can be plagued with downstream vendors that cheat on their no-export commitments. For this reason, BAN encourages all electronics recyclers to contact BAN to privately contract for our tracking services. We are ready and willing to help all recyclers and enterprise companies to audit their downstream partners.

Progress is being made. We need everyone’s help to finally eradicate unethical actors that, via export, create an uneven economic playing field while promoting real planetary harm.

Jim Puckett is the executive director of the Basel Action Network and can be contacted at [email protected].


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 [email protected] for consideration.

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