A certified recycler stamp is not proof of ethical downstream management. That’s the core point Jim Puckett, founder and chief of strategic direction at the Basel Action Network, brings to this episode of the Resource Recycling Podcast.
Host Uriah Kiser talks with Puckett about the Brokers of Shame report, which tracked more than 10,000 containers of U.S. e-waste (roughly 169,000 tons, valued at more than a billion dollars) shipped mainly to Malaysia and other Southeast Asian destinations over a 26-month window. BAN estimates about 2,000 containers a month leave U.S. ports. Eight of the ten brokers called out held R2 certification. Puckett explains why e-Stewards does not certify brokers and why yearly audits alone are easy to game with selective paperwork and unverified downstream claims.
Because the United States has not ratified the Basel Convention, exporting hazardous e-waste is not illegal here even though most of the rest of the developed world treats it as such. Puckett walks through what happens when innocent customers drop devices at recyclers, retailers, or take-back programs, and why the cheap route often ends in primitive processing that harms workers and communities.
The conversation also covers the AI waste wave and data-center equipment. Hyperscalers say they will reuse everything, but much of the gear is not designed for reuse or responsible recycling. Cooling systems can incorporate PFAS and other toxic fluids. Refresh cycles are rapid, secondary markets look doubtful, and the same export patterns risk repeating. True circularity, Puckett argues, requires both ethical handling and design-for-circularity from the start. Legislation may be needed because voluntary manufacturer promises have not delivered.
Puckett will be on the export panel with BAN at E-Scrap: The Longevity Conference in New Orleans, Monday, October 26, 2026, 2 to 3:30 p.m., and also on a data-center/AI waste discussion with a major hyperscaler representative. Kiser, a first-time attendee, asks Puckett for advice, and Puckett says the hallway conversations are often worth more than the sessions.
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Transcript of episode 6: The Resource Recycling Podcast
Host: Uriah Kiser, Resource Recycling | Guest: Jim Puckett, Basel Action Network
Certification, audits, and circularity
Uriah Kiser [0:04]: If a company is certified and calls itself a recycler, is that enough, or can the paperwork hide the real destination?
Hello, and welcome to the Resource Recycling Podcast. I’m Uriah Kiser, and on this episode, we’re going to be talking with Jim Puckett. He is the founder and chief of strategic direction at the Basel Action Network. He started BAN in 1997 after running toxics work at Greenpeace International. He has been in the room at every UN Basel Convention COP since 1989, and he oversaw the creation of the e-Stewards Standard.
Last October, BAN’s Brokers of Shame report tracked more than 10,000 containers of U.S. e-waste, about 169,000 tons and more than a billion dollars of material, shipped mainly to Malaysia and the rest of Southeast Asia. He’ll be on the export panel with BAN at E-Scrap, the Longevity Conference, in New Orleans, Monday, October 26th, from 2 to 3:30.
The idea he brings to today’s podcast: a certified recycler stamp is not proof of ethical downstream management. Jim, welcome to the Resource Recycling Podcast.
Jim Puckett [1:12]: Thank you, Uriah. I’m very glad to be here.
Uriah Kiser [1:17]: You and I have been going back and forth and having some great discussions before we recorded this session today. But the first question I have: when somebody in the U.S. turns in an old device at a recycler, how confident should they be that they actually know where it ends up?
Jim Puckett [1:36]: Yeah, unfortunately, they should be confident. All these years we’ve been trying to make things better, largely because the United States is the only country in the developed world that has not ratified this treaty called the Basel Convention, for which we take our name, Basel Action Network.
It really causes a problem, because the rest of the world knows this type of dumping of electronics offshore is illegal, but in the United States, it’s not illegal. And so it’s very likely to happen when innocent customers bring their material to a recycler or to a take-back program at a retailer or a church or wherever. It’s more than likely going to go the cheap and dirty route, which is export to developing countries where things are not managed properly at all and cause great pollution and harm to the workers.
Uriah Kiser [2:35]: Can you talk a little bit about what you’ve learned about the movement of used and end-of-life electronics that people inside the industry still misunderstand?
Jim Puckett [2:44]: Yeah. We created the certification movement when we first discovered all this waste going to China, and we said, we’ve got to do better. We have to have best practices. We have to have something that’s audited and certified. So we created e-Stewards at about the same time the R2 certification was underway, and we ended up with two standards.
We kept e-Stewards going. We saw R2 was weak in a lot of areas. And unfortunately, people think now that there’s equivalency between the standards, and that if you have that standard and that logo on your website, then you’re golden. But unfortunately, it’s really easy to gain these standards.
We’ve learned that you can’t just rely on the yearly audits. You have to do a little more than that. You have to do unannounced inspections. You have to track the waste using GPS trackers if you can, and things like that. You have to go beyond the normal audit system.
And that’s what we learned with Brokers of Shame. There were 10 brokers we called out, and eight of those were R2 certified. Now, e-Stewards doesn’t allow brokers to be certified. We think it’s very problematic, because they make their money almost entirely on finding the cheapest avenue, and they don’t recycle. So we said, we’re just going to certify recyclers.
But R2, unfortunately, gave certifications to eight of these brokers, and it’s caused a tremendous problem, because everyone just says, oh, they’re good, they’re certified. The large enterprise users, whether it be a bank or a medical institution, say all we need is a certification, we’re good. Unfortunately, we’re not.
So we’re trying really hard to work with R2, and to their credit, they have knocked some of those eight brokers out of their program. And we’re trying all the time to go above and beyond the audit system. Unannounced inspections are a great way to do it, and so are whistleblower avenues where people can call us and say, this is going on. These are really important, because there’s a lot of cheating going on, and there’s a lot of money to be made cheating. And again, it’s not against the law in the United States. That’s why it’s really problematic.
When you’re a person who just wants to recycle your equipment the right way, find the right avenue. We encourage people to use e-Stewards. Certification, certainly, we stand behind.
Uriah Kiser [5:26]: Certification is supposed to close the gaps. And you mentioned audits. So how do the audits get gamed?
Jim Puckett [5:32]: Well, it isn’t too hard. When the auditor is coming, you know what they’re going to look for. They always look at the paperwork. They say, show us your last bills of lading, or anything that’s gone out of the building. And so you can keep double books quite easily. You just show them the papers you want to show them. The auditor doesn’t have a clue. You can say, these are our downstreams, and the auditor doesn’t have time to call all of them and verify that all that material really went to those downstreams. It’s just too easy to cheat. That’s what we’ve learned, sadly.
So you’ve got to do some kind of verification process, performance verification, we call it. It’s extremely important that you add that layer as the manager of your program. The auditors are important too, but there’s nothing quite like a little GPS tracker in your stream to tell you exactly what’s going on.
Uriah Kiser [6:27]: You argue that true circularity is ethical circularity plus design for circularity. What does that demand of recyclers, and what does that demand of manufacturers?
Jim Puckett [6:36]: Yeah, very good question. The whole circular economy movement is pretty much meant to be recycling on steroids: do everything you can to circulate materials, and not have them go to the dump or get burned, of course. But you’ve got to do more than just talk circularity. You have to see where things are really going.
What’s been happening, as I mentioned, is people say, don’t worry, it’s going to be recycled, it’s all circular, we can report this as recycling in our ESG reports. But it gets recycled in a horrible way in Malaysia or Vietnam or Indonesia, and nobody really looks at that and says, no, that’s not proper, responsible, ethical recycling.
Likewise, the whole circularity concept seems to be missing in practice: the idea that manufacturers have to design things to be circular. So much of this electronics is not designed to be circular. It’s really hard to recycle. It’s really hard to reuse. It’s really hard to repair. They don’t even give you the instructions for how to repair it, or the materials involved. You have to drag the manufacturers kicking and screaming to allow people to fix their equipment.
So design is the main thrust of circularity. Things are not going to magically be circular, and be created so we can truly recycle them, if you don’t plan that in advance. We’ve learned this over the years with so many waves of waste, like the CRTs, the old clunky televisions. Nobody designed those for end of life. So they just stacked up everywhere. They were toxic. Nobody knew what to do with them. So, of course, they ended up on a lot of boats going to China.
We see this over and over again, and now with the new data center waste, I’m afraid we’re going to repeat the same mistakes. A lot of the equipment they’re planning to use in data centers is not really created to be properly reused, and it is toxic. So we started reporting on the AI waste wave, as we call it. This is going to be problematic if we don’t act now to ensure that this new equipment is designed to be properly recycled or reused at end of life.
And end of life in the data center world is going to be really rapid, because there’s going to be such massive innovation and competition to move fast. So we’re going to see waves of equipment coming offline and going, hopefully, into a reuse market.
Uriah Kiser [9:16]: How strong is that market in the U.S. and in other parts of the world? Especially, as you mentioned, since the refresh rate at these data centers is incredible.
Jim Puckett [9:25]: Yeah, we’re really worried. We did the first part of our white paper on the AI waste wave, quantifying how much stuff we’re really talking about. It’s a lot more than anybody has dreamed, because we looked at the whole issue of all the infrastructure involved, not just the servers. It’s going to be a lot of stuff.
The next part of our report is going to be: OK, can we repurpose it? Can we remanufacture it? Can we sell it to a secondary market in the developing world, or what have you? And our preliminary look is looking really doubtful, unfortunately.
So far, the hyperscalers have said, don’t worry, we’re going to reuse it all. But they’re not designing it to be reused. To give you an example: the servers have to be cooled. So they put in all these cooling devices and hoses with certain cooling liquids, and we’re not talking about water. Some of them are very toxic. Some of them are PFAS, the forever chemicals that are very persistent and toxic. And this stuff is all intermixed. Who is going to be able to use that?
Typically it’s one model that’s going to be phased out in a few years, and most people want the latest model. So it’s looking pretty grim, because we already have an e-waste crisis on our hands, and there’s an industry trying to respond to it. Recyclers are trying to make things more circular. But if you don’t design things to be properly reused, they won’t be. And I’m so worried they’re going to be going offshore as before.
Brokers of Shame, the future, and E-Scrap
Uriah Kiser [10:52]: Now, I mentioned that Jim is going to be a panelist on the BAN at E-Scrap panel at the Longevity Conference, coming up in New Orleans. I’m excited about it. It’s my first time coming to the conference, and actually my first time in New Orleans. I’m going to talk to you a little later about the conference and what you’re looking forward to, and I’ll drop all the conference information in the description of this podcast. So make sure you get to the E-Scrap Conference. You won’t want to miss it.
Jim, I mentioned the Brokers of Shame report that you worked on in 2025. Talk to me more about the impetus for this report and what surprised you. I mean, 10,000 containers of e-waste. What are we talking about? When we look inside these containers, what’s inside? What were you surprised to find?
Jim Puckett [11:39]: Yeah, well, that was the amount we were actually able to document in a 26-month period. What we estimated is about 2,000 containers a month going offshore. We weren’t able to really nail down what percentage of American e-waste is going this direction. But in my own personal opinion, I think it’s the majority.
Sadly, these brokers of shame, as we call them, are so good at getting companies’ business, because they do it cheaper. They can fly under the radar. They can change their name overnight. They misdeclare their shipments so it sounds like they’re just shipping aluminum scrap when it’s actually e-waste.
And unfortunately, they have the friendship of certain elements in the receiving countries. There are powerful players in countries like Malaysia and Indonesia making a lot of money doing this, and they’re contributing to political campaigns. They are powerful in that way, and they don’t want to see this change. It’s really like a cartel in a lot of these countries. It’s run primarily by Chinese businessmen who used to bring it to their own country. Now they’re bringing it to places like Malaysia, Indonesia, Thailand, etc. So they have opened the doors from that end.
It’s really hard, because we go tell the Malaysian government, you’ve got to stop these, and you can feel it in the responses. They’re very conflicted, because one part of the government wants to do the right thing and follow the Basel Convention. Another part of the government is part of the corruption and part of the cartel. So this is the problem we have.
Until the United States really bans this, I think we’re going to continue to rely on the public, and on companies that want to be leaders, saying, no, we’re going to do it through e-Stewards. We’re going to check, not just rely on the certification. Even e-Stewards does its own checking. We’ll use our own GPS trackers as need be, and our own unannounced inspections. But we are not going to pretend to be ethical circularity leaders if it’s not truly ethical.
One of the things that really grinds my gears is the movement now for ESG and being corporate responsible companies. They’re all looking at carbon as if the carbon footprint and climate are the only issues. But then you’re poisoning people directly. That is not ESG. So we need better programs to measure that. We’re working with some folks to create report cards that really infract [?] the toxicity, not just the carbon you’re putting out in the world.
When you go to these places, they really are harming people. There’s a whole subclass of workers, not always legal, who get the brunt of this type of dirty recycling. They’re breathing in the mercury when they smash the tubes, and they’re breathing in the fumes from the burning and smelting done in such primitive conditions. And then the fallout of all that goes into the community. So it is really harmful. There’s a reason the Basel Convention exists, and it’s a reason for people to pay attention when it comes time to offload their old computer or phone or what have you.
So we’ve still got a lot of work cut out for us. I think certification is the right way to go. We need to clean up our act, both R2 and e-Stewards, and make sure that what our recyclers say they’re going to do is actually what they do. We’re proud that at e-Stewards we have a GPS tracking program. We have truly unannounced inspections, where we just demand to go in and see everything that’s happening, the loading docks, et cetera. That’s the kind of verification activity that’s really important.
Uriah Kiser [15:23]: As we offload those electronic devices, and as interest grows in recovering critical materials from those electronics, how do we capture that opportunity without shifting the environmental and human costs somewhere else?
Jim Puckett [15:38]: Well, we do have really precious metals. We do have critical metals. Even copper is considered a critical metal; we’re running out of it. So there are the environmental impacts of people getting poisoned, but we’re also running out of resources. So it’s a no-brainer that you have to do the best you can to collect this material, bring it back, and do the materials recovery.
It should all be designed that way from the outset. Everything should be designed to be reused, and if it can’t be reused, easily recycled. And the first element of that is making things non-toxic. We should never be putting PFAS into equipment. I don’t care how fast you have to create new servers and accelerators, we cannot be putting poisons into electronic equipment. That’s design, done from the beginning.
So we really have to work on the manufacturers. Right now they’re busy trying to get exemptions for using PFAS. They want to move in that direction because the AI waste wave is so competitive. Nobody wants to slow anything down and really think about the future anymore. So we really have to work with the recyclers, the manufacturers and all the stakeholders to say, hold on, we’ve learned these lessons before. Let’s not go backwards and create more of a problem for ourselves in the future.
Uriah Kiser [16:53]: Well, let’s think about the future there. Looking five or 10 years out, what single change in design rules, leasing, toxics policy, ESG or the AI build-out would make the biggest difference?
Jim Puckett [17:06]: Well, again, no toxicity allowed. Just start right there. You cannot build electronics with poisons like PFAS in them. There are alternatives. They might be slower to put into place. They might be more expensive. But we cannot afford to be putting up all this equipment when the recyclers can’t even recycle it without fear of being contaminated and poisoned. This is not good at any level.
It’s going to harm people in the future, for sure. Particularly, it’s going to harm those in developing countries, because right now the planet doesn’t have the capacity to do proper recycling. So unfortunately, some of that material is going to go to the Global South, and they’ll get the brunt of it. So that’s a huge step.
Design for recycling and reuse has to be legislated, I believe, because manufacturers have talked about it, but they are not doing it. That’s what we’re building up for with the AI waste wave, the data center boom. So I think that has to be legislated. It’s a combination of market strategies and legislation, and the consumer can play a big part. If we give consumers a proper avenue to follow, whether it be e-Stewards or R2, they need to have that avenue in front of them. They can’t sit down and do all the research themselves. They need to rely on an avenue for doing things the right way.
So those are some of the things I’d change. I’d certainly slow down if I could. The data center build-out is completely scary to me, the more I read about what we’re doing. And I’m just looking at the e-waste aspects of it; there are so many more. So we need to slow that down. Even the manufacturers, the perpetrators of AI, are saying, hey, we want to slow down. I really think we have to, on so many different levels. That would be very prudent. If the future holds that nobody’s slowing down, then we’re in trouble.
We have so many environmental and social problems looming from AI. It’s an amazing tool. I’ve used it to write my reports, I confess. If it were only a research tool, you’d be so thrilled with it, right? But unfortunately it has a lot of impact, and it’s becoming more ubiquitous by the day.
Uriah Kiser [19:26]: As we wrap up here, I promised a little fun talking about the E-Scrap Conference. I’m very excited about seeing you and meeting you in person, as you’ll be on the export panel. This is my first time at the conference and my first time in New Orleans, and I’m looking forward to it, as I said. Have you been to the conference before? What are you looking forward to most at this upcoming 2026 E-Scrap?
Jim Puckett [19:51]: I think I’ve been to every one of them, believe it or not. We got into this whole thing when we did our report, Exporting Harm, years ago, back in 2002 or whatever it was. That was when we first discovered e-waste being processed in China. When we went to the conferences, it was even before E-Scrap; there was another conference that preceded it. So I’ve been to every E-Scrap. I’ve been to every Basel Convention meeting.
I’m thrilled, too, that I’m slated to be on a panel with Michael [?] from Google. So at E-Scrap, not only will I be doing the exporting bit, but I’m also going to be on a panel to talk about data centers and the AI waste wave with someone from one of the major hyperscalers. So that should be very interesting.
Uriah Kiser [20:39]: As someone who’s been as often as you have, what one piece of advice do you have for someone like me who’s coming for the first time? What should we be looking forward to at this conference?
Jim Puckett [20:49]: Well, it’s really a great mix of finding the best presentations and the conversations in the hallway. In hindsight, I’d say the conversations in the hallways are always a little more valuable. But of course, it’s who you talk to. Try to line up the people you want to talk to ahead of time, because it gets crazy at these meetings. There are so many people, it’s really hard to nail people down and find them. So try to set those up ahead of time.
But yeah, there are some good presentations, so pick and choose those, and don’t forget to have conversations with people. If you don’t know anybody, just talk. You’re going to learn so much. Unfortunately, at these meetings, there are people whose hearts are in the right place, and there are also people who just want to make a buck as quickly as possible. They’re the ones who end up using exporters. So it’s a mixed bag in the room. But it’s a great avenue. That’s why I go every time.
Uriah Kiser [21:48]: Jim Puckett is the founder and chief of strategic direction at the Basel Action Network. Jim, this has been a lot of fun. Thanks for coming on the Resource Recycling Podcast.
Jim Puckett [21:58]: Absolutely. I look forward to seeing you there, man. There’s this thing called… I think it’s the pickleball. [?]
Uriah Kiser [22:05]: Yeah, the pickleball tournament. I’m very excited about that. Some of the guys are actually picking teams. I’m seeing online who’s going to line up with who, and who’s going to play with who. [?]
Jim Puckett [22:11]: That’s so cool. Oh, yeah. e-Stewards are going to have their presence. We’re going to bring quite a few people there.
Uriah Kiser [22:20]: I can’t wait. I can’t wait.
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