Basel Action Network Tracking Study

Basel Action Network Tracking Study

In 2004 Dell partnered with Goodwill and started Reconnect, their e-Waste reduction plan. They encouraged people to drop off their old computers and accessories, of any brand and condition, to one of over 2,000 participating Goodwill locations, and promised that, “we’ll make sure your system and accessories are refurbished or recycled responsibly.”

Dell advertised Reconnect as being doubly responsible – good for the environment and good for business. Whatever electronics were not at the end of their life – meaning they could still be refurbished and resold, supported Goodwill’s endeavor to provide jobs for the disadvantaged while furthermore making electronic devices more affordable to low-income people through resale.  Whatever electronics would not be reused would be “broken down securely and recycled responsibly” in accordance with Dell’s “extensive and strict Electronic Disposition Policy.” This means that no electronic waste would be sent to landfill or exported to developing countries.

When recyclers refer to ‘developing countries’ they are usually referring to the UN’s OECD ( guidelines, which are massively complex and far-reaching, but essentially demarcate which countries meet the minimum environmental and safety standards and which do not. The recycling industry standard, along with the UN, deems it unacceptable to export e-Waste to non-OECD nations, because there is very little guarantee that the waste will be dealt with responsibly. However, there is difference on the question of exporting to candidate OECD nations. Dell does not export to non-OECD/EU nations, a policy they refer to as “Be a Responsible Neighbor.”


Dell describes their e-Waste policy as “the strongest in the industry,” and conducts internal audits, and audits of their recycling partners to make sure they are continuing to live up to this claim.


Since the launch of Reconnect, Dell and Goodwill claim to have kept, “427 million pounds of e-waste out of landfills. That’s the equivalent of over 49 million Inspiron laptops – one for every person in the states of California and Ohio.”


The Basel Action Network (BAN), a self-described environmental watchdog and advocacy group, took notice of Dell’s claims. Having heard rumors that Reconnect devices were in fact being shipped overseas, BAN specifically targeted them in their e-Trash Transparency Project.


In 2014 BAN began their e-Trash Transparency Project, the goal of which was to gain actual hard data on the issue of e-Waste shipping overseas. Where previously most evidence had been anecdotal – relying mostly on reports from eye witnesses describing e-Waste that appears to have originated within the US. Pointing out that people cannot be expected to rely on the recyclers themselves to report illegal shipping. So BAN launched the project in order to qualitatively answer this question: Does the public still need to fear that their e-waste, when delivered either to a charity or to a recycler, has a strong likelihood of being exported to a developing country instead of being recycled here in the United States? The answer, according to BAN’s is yes.


BAN placed 200 tracking devices into electronic devices like printers, LCD flat screens, and CRT monitors. These were then dropped off individually and by hand at publicly accessible drop sites.


In response to reports that Dell’s claims were a less than entirely accurate representation, BAN deliberately focused on these Goodwill drop-off points. The first report of the e-Trash Transparency project was, therefore, entitled Disconnect. Of the 200, then, 46 went to Goodwill, 6 of which took part in the Dell Reconnect program (the other 40 presumably refurbished and sold by Goodwill? And tracked to living rooms across America? Or perhaps just not moved in the year between the trackers being inserted and the report being published), and 15% of those Goodwill devices (7) were shipped overseas, most likely illegally.


Out of the 200 trackers, 65 were exported outside of the United States, and BAN estimates 62 of these were shipped illegally, which BAN extrapolated to claim that 32% of American e-Waste is illegally shipped overseas, predominantly to Asia.

There are many industry standards that regulate e-Waste specifically, and BAN has its own – e-Stewards. Created in 2009, the program intends to help both consumers and businesses decrease the “toxic footprint left behind by their old electronics.” The e-Stewards standards are, in BAN’s own words, the most rigorous industry standards. E-Stewards makes separate recommendations for recyclers, enterprises and consumers, but the standard revolves around six core tenants: that all data stored on devices be completely destroyed, that toxic waste be dealt with in accordance with policies that protect both workers and the environment, that the downstream life of toxic materials be tracked and accounted for, that only ethical labor be employed (no use of child/prison/coerced labor), that international law (namely the Basel Convention) be followed with regard to the exportation of e-Waste, and finally that all facilities belonging to a company must uniformly meet the standard in order for that company to be counted as e-Stewards certified.


Consumers are, more simply, urged to support e-Stewards certified companies and recyclers whenever possible.


In order to ensure compliance, BAN conducts annual audits, and any violations are reported to the EPA and any other relevant organizations. E-Stewards is the only e-Waste recycling certification that utilizes electronic tracking in order to ensure compliance. As of this posting, e-Stewards has 57 registered recyclers and at least 44 enterprises.


(Full disclosure: this blog is funded by R3eWaste, a recycling company which holds R2 certification. I have linked to BAN’s website and both of the reports where they have published their conclusions, and I encourage people to look at them and tell me if I’m biased here. Furthermore, this blog will explore R2 standards in greater depth in the future.)


Several companies involved with e-Stewards certification were implicated in the e-Trash Transparency project, and BAN was not happy about it, calling them cheaters and reassuring readers that, “we have revoked their certification with all urgency.” I did not find any official response from Dell or Goodwill regarding the findings of BAN’s tracking study.


BAN’s e-Trash Transparency rides a fine line, on the on hand providing hard data that was otherwise absent, while, on the other hand, sometimes coming off as an advertising tactic, used to malign their competitors.For instance, BAN expresses concern in Disconnect about ‘Greenwashing’ – as enviromentalism has come into popularity, more and more companies want the ‘green’ branding in order to appeal to customers, but many seek the path of least resistance. BAN explicitly names a competitor here, implying that their certification provides such an opportunity.


In their second report on the e-Trash Transparency Project, Scam Recyclers, BAN makes the claim that Responsible Recycling (R2) certified recyclers have a higher-than-average rate of exported e-waste, while e-Stewards has a less-than-average rate. In fact, while R2 is said to have, “about 5 times more certified recyclers than the e-Stewards program (a more rigorous standard), it was found that ‘R2’ members had a higher rate of being associated with export than even uncertified recyclers.”

SERI (Sustainable Electronics Recycling International), R2’s organizing body, issued an official response, acknowledging the fact that R2 certified recyclers were implicated in BAN’s tracking study and discussing the validity of trackers as a potential method of policing their certification, and promising to “aggressively investigate” those implicated. SERI’s statement rather pointedly makes clear that any future tracking endeavors would not be conducted in secret, however.


The e-Trash Transparency Project primarily brings public awareness to an important topic – responsible e-Waste management. BAN’s website is easy to navigate and full of easily digested information about the various problems associated with e-Waste. The rigorousness of their e-Waste export regulation, and perhaps their tenancy to secretly track their own associates, has reduced the e-Stewards participants.

The group seems to lean more toward environmental advocacy, calling for federal intervention into the export of e-Waste to non-OECD/EU nations and maligning certifications which do not comply. BAN was overtly political during the 2016 campaign season, posting a heavily edited video, for example, of Donald Trump championing the environment, and selling “Make the Environment Great Again” hats. BAN had wanted President Obama to sign an Executive Order restricting the amount of American e-Waste shipped overseas, but their petition never became popular enough for an official White House response. What BAN’s advocacy will look like under the current administration remains to be seen.

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