Simple due diligence Model for "ewaste" exports

No export for disposal. Example: 89 sea containers of hospital waste sent to Brazil (BBC) misidentified as "for recycling". There really are cases of hazmat dumping on foreign beaches. But this rule should also cover "negligent sorting" of electronics (not hiring enough people to remove the bad stuff to meet the specs of legal exports, defined below).

Establish Rules for Export for recycling. Conditional exemption of sorted commodity grade CRT glass, as well as plastics, metals, etc. means it cannot include more than de minimus quantities of TAR (Toxics Along for the Ride). Export for recycling requires commodity agreements which are legal in the country you are exporting to. Recycling should not be held to a higher standard than raw material extraction, but if we "close one eye" to the byproducts, society will turn back to mining.

Establish Rules for Export for repair and refurbishment. EPA already requires 3 years of recordkeeping that demonstrates the CRTs sent for reuse as a condition of "commodity" status. WR3A requires that de minimus (replaced parts, incidental breakage) be recycled properly downstream, and proof that a significant percentage of CRTs were recycled in the USA. The overseas facilities should be audited and BOLs inspected to make sure that material is properly screened (no one is refurbishing imploded, screen burned, monochrome monitors or 20 year old TVs or cracked LCDs). This is legal under Basel Convention Annex IX B1110, but has been an "excuse" to export CRTs to China. Our industry needs to regulate this trade or we will lose a great, affordable environmental option.

Export of "fully functional" for direct reuse should be completely exempt. There can be definitions and rules, e.g. that the be under certain age, require 3 years of record keeping that the material was in fact reused, material is under waranty (full refund, no de minimus for broken). Any laws bearing on legality of shipping (e.g. USA restrictions on export of high tech to unfriendly countries, protectionist laws in China) to any country are presumed not to be environmental laws, and EPA and ISRI should probably stay silent on those.

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