R2 Responsible Recycler Certification Vs. E-Stewards Certification: Synopsis

What is the difference between Responsible Recycler (R2) and E-Steward Certification?

There are already several posts this year about the technical aspects of the Basel Convention, EPA Export Rules, and differences in perspectives on "fully functional", "tested working", and "elective upgrade" of used computers and components.  A list with links follows below/bottom.

I've been involved with "legalese" since my days as a regulator.  When is a product "discarded"?  What is "original intended use"?  Does Basel Convention Annex IX allow an overseas buyer to "electively upgrade" (replace and improve parts) and refurbish?  What is "major reassembly"?

Dialogue with the groups opposed to international trade was rational and factual during the R2 Stakeholder meetings, and so continued when BAN.org organized a competing "E-Stewards" Certification program.  However, when BAN's marketing of that campaign, and of their views about the contract manufacturing or SKD facilities, turned negative, I became negative as well.  I hoped R2 Solutions and ISRI would continue the level headed dialogue with the protest organizations, and from time to time I could use the blog to express the opinions of "geeks of color", which was increasingly disgusted with the way Watchdog groups equated their elective upgrades with "primitive wire burning".

The central difference between E-Stewards and R2 comes down to this:  In non-OECD nations (China, Singapore, Taiwan, Malaysia, etc.), can a material be legally recycled if no toxic constituents are released per Annex III? Who answers that question? The ayatollah of e-waste, or the competent authority (EPA)?    
For example, can a computer refurbisher in Singapore send upgraded circuit boards to Japan for refining, or send them to the same circuit board refiner in Singapore that off-spec newly manufactured product and warranty return product is sent? If so, the professional warranty-return, manufacturer takeback factory, in an ISO14001 factory, could keep its jobs, buy tested working product, and electively decide to replace working but worn parts, replace 110 volt boards for use in 220v countries, degauss cathode ray tubes for changes in hemispheric magnetic conditions, remove analogue boards and replace them with digital tuners, etc.

- R2 says yes but demands 3rd party certification that the non-reuse constituents were in fact legally recycled in a manner which did not result in release of Annex III constituents.

- E-Stewards says that even if the part is properly recycled, and no toxic is released, that the part must have been removed prior to shipment.

Confusion reigns among E-Stewards. Most of the product going through most e-Steward companies is shredded into pieces... The largest E-Steward companies find it too difficult to certify exports for reuse, and employ "no intact unit'... something advocated neither by Basel Convention or even BAN.org. When tested working product is exported by E-Stewards, there is no required WR3A type of reconciliation - QA/QC. For all BAN knows, the tested working product might be purchased and electively upgraded. But officially, BAN considers that illegal. They just assume that the contract manufacturers purchase nothing but non-working product, or untested product. The definition of "tested" within E-Stewards centers around plugging the product into a wall... ignoring the fact that the power supply is irrelavent to the outcome. Buyers are more interested in CRT type (SSG vs. trinitron), age of cathode ray gun, and screen size. If it's tested working or not has nothing to do with the outcome of the computer. They are hospitals, not morgues, and they perform elective surgery on healthy as well as sick.

By forbidding E-Steward Companies from selling fully functional, tested working product to factories which electively upgrade and improve the white box or off-brand PCs, BAN has not saved anyone from any poison. BAN has not done anything for the poor. BAN has made recycling more expensive for Americans with consciences. And BAN has employed marketing of their case which equates proud, intelligent, responsible technicians with illiterate, unwashed, slum dwellers.

BAN has also, unintentionally perhaps, stunted the growth of their own adapted overseas recycling operations. Ethiopia's program, visited by USA EPA Director Lisa Jackson, is accepted because they import "tested working" and "fully functional" computers, and then take back and recycle them when people in Ethiopia no longer use them. In Indonesia, the factory takes the same tested working product, and identifies the pieces which will likely fail in the future, and proactively upgrades them, properly recycling the part. Indonesia brings more money and produces product at higher scale, for wider distribution. It uses the geek knowledge to create affordable computers which last longer than "tested working" and work better than "fully functional", and create a factory which can do contract manufacturing. Ethiopia's techs desperately need the same jobs and development.

I'm not always sure how to balance the technical and diplomatic approaches with the humor and outrage. Some readers prefer a little feeling, others really just want to know the facts. The most popular posts are usually positive, hopeful depictions of fair trade recycling vendors... helping put a rational face on the people who want to do business with us before we grind our computers into little dusty pieces.

Speaking of dusty little pieces, here is a list of recent posts which try to explain "elective upgrade". Africa doesn't need hospitals which only treat healthy or dead patients. Africa needs hospitals which can also heal those in between - the sick patients. This can lead to health tourism. E-Stewards is trying to force importers to treat only healthy patients and to dispose of cadavers from in country. The problem is, your average techie in Accra or Lagos cannot even tell whether a PC came from a local or import, they see the speed and age. They prefer newer ones, because they can sell them and make more money for their families. Rich nations throw away newer computers than poorer contries do. BAN, SVTC, CTB, NRDC, Greenpeace and others need to create a space where elective upgrade has a right to exist, and is not equated with accidentally racist stereotypes of primitive informal recycling.

Electronics Export Decision Tree: Point of Disput...Ewaste exports electronics computers NGO BAN reuse Basel Convention
Decision Tree: Basel Convention on FunctionalityBAN WR3A Basle repair diagram decision tree reuse repair export e-waste ewaste recycling computers
"E-Waste" Is Never Reusedbasel convention rules export decision tree diagram ewaste reuse repair recycling e-waste legal
Legal Dual Party Intent, Part II E-wasteLegal Dual Party Intent e-waste recycling basel convention second
My Pitch for R2 over E-StewardsR2 Certification E-Stewards certified recycling e-waste ewaste
Elective E-Waste: Decision Trees Downstreamtested working R2 e-stewards fully functional


Anonymous said...
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Anonymous said...

excellent article...thanks for your insight!

regs, like most other things, need to be implemented in a step-wise fashion so they can be readily modified by improved or new ideas...trying to eat the whole pie in one bite alienates most, and never achieves the lofty goals it proclaim it would reach

Robert Downer, PE
Environmental Engineer