Elective Upgrade as an E-Waste Generator

It is impossible for WEEE or E-Stewards or R2 to design a system which prevents generation of scrap from elective upgrades  Examples of elective upgrades are replacement of RAM with faster RAM, replacement of 110 volt power supplies with 220v (rather than adding an adapter), upgrade of CRT monitors into monitor-tv combination.  "Fully functional" can produce the exact same fallout as "repair and overhaul".

This German report (page 18) envisions  a need to prevent exports where
"d) the appearance is generally worn or damaged, thus reducing the marketability of the item(s)"
This appears to assume that exporters from the USA or EU primarily trade directly with retail and reusemarkets.  EPA's 2008 Report on used CRT exports documented that this is a relatively small portion of the export market;  "white box" market re-manufacturers constitute the lion's share of exports.  And if you send the factory below two computer monitors, one a fully functional Dell D1226H 19"inch UltraScan with a pristine casing (per instructions in the German report), and a second no-power Dell 19C02-MON-WMSV049S  with scuffed, scratched, cracked, ugly plastic casing, the result will be:

                 THE NICE WORKING ONE IS WASTE, THE SECOND IS IN DEMAND

Both were assembled by contract manufacturer AOC, but the second (non functional) is a type the factory needs.   If an E-Steward sends the second one "tested working" and pristine, however, it will be torn down exactly as if it had damaged plastic.   This is because the factory voluntarily, electively upgrades all the products it buys to like-new condition.

FULLY FUNCTIONAL - export for reuse - UPGRADE = REPLACED PART


Refurbished from 1 part tested working, 2 parts repairable
Large scale operations typically decide to upgrade the computers they get and make them even better than the computer which was donated.  Trying to control "waste" generation of half-inch capacitors displays a gross misunderstanding of the buyers who perform these refurbishment upgrades.  These repair and overhaul entrepreneurs are educated, smart businesspeople.  They are not primitive wire burning wretches.   They are capable of properly recycling the upgraded parts if given the incentive and opportunity to do so.

Objective analysis will show that the people with the most expertise are the most likely to replace and upgrade parts.  Sending these people "fully functional" devices won't stop this.   We should embrace these "Techs of Color", because their demonstrated efforts to properly recycle the pieces they electively upgrade shows that they are the best thing going in the countries Watchdogs claim to protect.  The most able technicians are also the best recycling partners.  Putting them out of basis is... choose your adjective.

Is this a ruse, a "reuse excuse", a "self serving" diagnosis which perpetuates "digital dumps"?   We have repeatedly offered to compare our actual records of exports and proper recycling at manufacturing takeback factories, to compare with any E-Stewards downstream analysis of their "tested working" product.  It would be great if Vermont winds up airing the discussion, which I  believe will reveal that most E-Stewards are either doing the same as my company by selling tested working units which are nevertheless electively upgraded in the same process, generating the same scrap capaacitors (working or not).  Or, in more instances, they are destroying everything.  And probably generating as many capacitors clingning to boards affixed to steel and plastic.

Those who raise money based on perpetuating dogmas of  have criticized my operation (Seven Days magazine), or have stated that they "have not analyzed it" and therefore have no choice but to recommend Vermonters use my competitors (which hearabouts meant either a) those which exported more non-tested product than we did, according to their own claims (60%) in articles posted on BAN's own website, or b) exported nothing for reuse, as zero intact unit, shredding operations.  We have provided our data and our fair trade end markets, invited reporters to visit Retroworks de Mexico and our facilities overseas.  I challenge Basel Action Network to a comparison, a scientific comparison of data.  Not a comparison of the rhetorical "fully functional", which of course sounds better than "repair and refurbishment".  Not a comparison of poster child photos, which we have all engaged in this year.

The words, repair and refurbishment, are in the legal language of Basel Convention "Fully functional" and "tested working" are not in the Convention!  This is because the Convention studied this a decade ago.  Then EPA researched it, and produced the CRT Rule. Then R2 studied it, and produced the R2 standards.  You run with your fancy words from jurisdiction to jurisdiction, but everyone involved with you ships working units that are electively upgraded, or shreds reuse.

Time and again, UNCTAD, Basel Secretariat, EPA, R2 stakeholders see the evidence and vote to allow repair and refurbishment, asking for proper recycling of the incidental replaced parts.  Time and again, anywone who spends time and visits the Geeks of Color comes back and says they are cool.  And time and time again, I am asked to defend our fair trade partners, who lived in my house and broke bread at my table, and took me to tour their operations... people who are attacked as "primitives" based on absolutely nothing but their race, their color, and their ethnicity.  

Happy Sunday morning.  I am reading the German report today.

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Transboundary shipment of waste electrical and electronic equipment /
electronic scrap – Optimization of material flows and control
by
Knut Sander Stephanie Schilling
├ľkopol GmbH, Hamburg


One thing I like already... in referring to the same Guidelines that BAN has used to insist on their version of the "California Compromise" protocals, the German report - which agrees with BAN on how the goods should be prepare, does clarify that the Guideline is NOT LEGALLY BINDING under Basel.
"2.5 Revised Correspondents’ Guidelines No 1 for Shipments of Waste Electrical and
Electronic Equipment 

These guidelines are directed at authorities responsible for implementation of Regulation
1013/2006, and discuss the subject of shipments of waste electrical and electronic equipment.
One essential element is the distinction between used equipment and waste equipment. These
guidelines are intended primarily as a support for enforcement.
Paragraph 7 of the Guidelines – which, as already mentioned, have no legally binding character – states that, where the holder of the material claims that he intends to ship or is shipping used EEE and not WEEE, the following should be provided to back up this claim to an authority on its request:"



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