My Pitch for R2 over E-Stewards

The R2 standards for "e-waste" recyclers require proper documentation of all the reuse and recycling streams.  If you export for repair or reuse, per Basel Annex IX, you must also keep records of what happened to every piece that wasn't reused, make sure it was properly recycled, and make sure the buyer is both audited and fairly compensated.  You need to have your records audited and keep them for three years.  Our first reaction to R2 Consensus was to hire an inspector and audit our reuse buyer, to make sure  all the incidental breakage, elective upgraded parts, etc. were recycled properly and that the reuse records were accurate.

E-Stewards began with an objection within R2 that proper recycling of e-waste (incidental breakage, above) overseas was a form of disposal, and that Basel Convention Annex IX requires "pre-repair" - identification and removal of the piece to be replaced.  No matter how well the recycling of the piece occurs overseas, they define "proper recycling" itself as "illegal disposal".

R2 simply left the phrase "must be legal" in order to leave a window open for the E-Steward standard bearers to make their case... if they were right and proper recycling overeseas was illegal, then they could stop it under R2 and no alternative standard was required.  Of course, the watchdogs had already written the Basel Secretariat a letter of protest over Annex IX, so they know perfectly well that proper recycling can be allowed of elective upgrades, maintenance upgrades, and repairs overseas.

The Watchdogs then began circulating a standard that would sabotage the factory scale refurbishers overseas, by making anyone who trades with them "pre-repair" the device.  Imagine that before you could take your car for a repair, that you had to remove the brake shoes in your driveway and then take your car for the new brake shoes to be applied.

The telling fact is that NO ONE DOES IT.  No E-Steward, no Pledge company.  It isn't done anywhere by anyone.  The purpose of the standard is to destroy the approach of giving existing refurbishing factories overseas the tools and fair trade incentives they need to properly recycle.   Since several reports (UN, ASU) have now documented that the e-waste is already being generated overseas at higher levels than in the USA ten years ago, this is short-sighted.  We need the professional, ISO14001, ISO9000, R2 audited refurbishing factories to properly recycle fallout (and elective upgrades, which E-Stewards is silent about), because that is the infrastructure those nations need to jump-start their own "e-waste" infrastructure.

This isn't just theory.  My company's partner in Malaysia now takes back old CRT monitors from across their province, from schools and offices, and even from competiting CRT repair factories.   Today, E-Stewards wants that factory to be declared illegal.  They offer that my company will respond by opening monitor refurbishing factories in the USA.  Yet they do not have a single such example among all of their Stewards to point at.

Ten years after Basel Action Network visited Guiyu, who has done more to improve conditions in Asia?  Take back your white man's burden, watchdogs.

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