Undercover investigations into e-waste smuggling

With the global proliferation of technology continuing to snowball at an exponential rate, the issue of electronic waste has become a global problem of epic proportions. According to estimates by the United Nations Environment Programme (UNEP), around the world some 50 million tonnes of e-waste is produced annually, of which only 10% is recycled. Government statistics suggest that the UK alone is responsible for producing some 1 million tonnes per year of e-waste, which has become the fastest growing waste stream in the country.

With such a large volume of waste to treat, and strong EU regulations in place governing the proper disposal of e-waste, it comes as no surprise that the illegal export of much of this waste is a growing problem in the UK. And the UK is not alone in facing this problem. Work carried out by the U.S. Environmental Protection Agency (EPA) suggests that it is 10 times cheaper to ship a CRT monitor to Ghana than it is to recycle it in the United States.

However, over the past three years the UK’s Environment Agency has become more proactive in tackling the problem. Intelligence led enforcement involving collaboration with the Police and Customs, as well as increased international co-operation with over 40 other countries, has been developed.

As part of this approach, the Environmental Investigation Agency (EIA) has recently embarked on its most thorough investigation to date into the illegal e-waste smuggling business. As a result of the 18 month undercover operation, the agency has recently published a report - System Failure: The UK’s harmful trade in electronic waste - that sheds light on the lucrative international black market for e-waste, and more specifically CRT screens.

According to the report, the trade involves players from every level of the waste food chain, from sole traders, right up to local councils and even central government institutions.

Undercover

Following the successful prosecutions of several councils for selling potentially harmful e-waste to unauthorised traders, the EIA decided to launch an investigation into how such waste, collected at civic amenity sites, ends up smuggled to dump sites in developing countries. From mid 2009 until early this year, undercover EIA investigators held a series of meetings with recycling companies and waste brokers to scrutinise the handling of e-waste at several civic disposal sites.

In spring 2010, EIA investigators posing as students carrying out recycling projects visited six civic amenity sites chosen at random throughout the Greater London area. Discussions with a site worker revealed that TVs and other electrical goods such as video players were being taken away separately by an outside company to be packed into containers and shipped to Nigeria. At least seven tonnes of TVs were being sold to the company each week, at a cost of about £1.50 to £2 per set. The investigators uncovered similar occurrences across many of the council sites it visited.

However, it is not against the law in the UK to export electronic equipment such as TVs, as long as it has been tested and found to be working. To find out if such checks were being made the EIA made a deposit of their own at the site.

Two deliberately disabled television sets equipped with sophisticated tracking devices were dropped off at two of the offending sites. After a few days the sets began to tour the UK, before the signal from one set being lost. The signal from the second set continued for sometime before it too was lost. Following a month of radio silence, transmissions from the first set were suddenly re-established - from Lagos, Nigeria. The tracking device indicated a location close to Lagos’s notorious e-waste trade centre, Alaba Market. Hot on its heals, the second TV set also soon reappeared, only this inoperable television had made it as far as Tema Port in Ghana.

The EIA tipped off Ghanaian authorities, but by the time they arrived at the port the TV had slipped away, and was once again on the move. It next reappeared in the town of Temale, where it remained for a further month, before the tracking device’s tamper device was triggered, suggesting the set had probably been dismantled. The tracking device on this set was later found by BBC documentary makers. The person who had bought the set told them that when he realised it was broken, he had stripped it for parts before dumping it.

Middlemen

Based on the results of the results of the tracker investigation, the EIA was able to conclude that illegal e-waste exports were passing through a number of hands between being dropped off by the public, and arriving in the developing world. To dig deeper, and uncover some of this network of middlemen, the agency set up a front company looking to source non-functional CRTs for shipment to China.

From a list of target companies drawn up using research on internet trading platforms, the EIA began the next stage of its enquiries, meeting face to face with a number of suppliers in south east England. The investigations revealed that while some companies were directly involved with exporting CRTs, many others simply sold them to the exporters.

At a meeting with one Environment Agency licensed waste carrier, investigators were told that the company, which at the time was bidding to secure 10,000 CRTs from the Ministry of Defence - does not have the time to test individual units. Instead they are visually inspected, with obviously defective sets, such as those with a broken screen, sent for recycling. The company itself does not export CRTs. However the managing director did admit to having customers in a number of countries in Africa and Asia.

At another company also marketing untested CRTs, investigators were offered regular shipments to China of 1000 CRTs per month for £3 each. The company claimed that the units would be coming from a ‘very large’ UK recycling company that sourced the sets from the UK and abroad. Investigators were told that the large recycling company was not allowed to sell untested CRTs to China, but that by acting as middlemen the traders could circumvent this issue. This picture was repeated at numerous other waste traders on the EIA’s target list.

The EIA says that its investigations reveal a widespread illegal trade in CRT monitors destined for the developing world. Some companies posing as recyclers are selling on e-waste with no regard for the final destination, breaking the duty of care to deal responsibly with e-waste. Investigators have demonstrated how broken CRTs deposited at council sites ended up in the hands of EA licensed outside companies, from where they were subsequently diverted into export streams to West Africa.

According to the EIA, until local councils and their contractors take responsibility for ensuring e-waste in their care does not leak onto the black market, the problem will persist.

Recommendations

With the aim of dealing with all illegal e-waste exports, the EIA makes a number of recommendations. Amongst those recommendations it says that all WEEE left at designated collection facilities should be quantified before leaving the site, and audit records kept. Additionally, producer compliance schemes holding the contract for site where e-waste has been proven to be illegally exported should lose their license upon a successful prosecution.

Furthermore, the UK government should conduct a full review of the producer compliance scheme, with the aim of reducing the number of schemes in operation. An increase to the number of random spot checks would also help alleviate the problem. The EIA is also calling for the establishment of recycling facilities and producer responsibility in developing countries to deal with the increasing volume of domestic e-waste being produced.

In spite of the inroads it has made into exposing those responsible for the illegal export of e-waste, funding for EIA’s specialist e-waste intelligence unit ended in March, and it is uncertain whether progress in curbing e-waste smuggling from the UK will be maintained.

Perspective

Dr Margaret Bates, manager of the Centre for Sustainable Wastes Management at Northampton University has travelled to Nigeria several times in the course of her research, and has seen and talked to the people who deal with the electronics once they arrive. Commenting on the EIA report, Bates explained that the illegal trade in e-waste has a significant impact on both the environment and people in Nigeria, but stressed the need to be very careful to differentiate between legal and illegal trade in second hand electronics.

“In Alaba market, Lagos, the dealers and traders are very keen to have any equipment from the UK as even the broken/ illegal can be harvested for components. The tested / untested theme is consistent throughout the supply chain and if you ask in the marked for the price of a TV or computer you will be asked if you want tested or untested, therefore it seems odd to the importers that we worry so much about the difference,” she said.

Bates goes on to explain that Nigeria is developing its own guidelines to ensure environmentally sound management of e-waste, and is in discussions with a UK based WEEE recycler to establish a facility in Lagos. The development of a recycling solution, rather than banning legal export, will provide a sustainable solution not only for EEE that was imported second hand, but also for that which was brand new or manufactured in the developing world.

“In general I agree with the recommendations of the EIA report and feel the need for effective regulation and accurate data and records is key to stopping the illegal activities. I am wary of suggesting that that export activities should be stopped whilst investigations are ongoing as this could put legitimate exporters out of business,” Bates concluded.

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