Open WR3A Letter to CWIT / @Interpol on #Ewaste


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Mr. Pascal LeRoy
Mr. David Higgins
Countering WEEE Illegal Trade (CWIT

Dear Sirs,

As you may know, WR3A (dba "Fair Trade Recycling") is an NGO business consortium which seeks to support businesspeople in emerging markets.  WR3A offers discounts on the cost of legitimate used electronic devices as an incentive to create takeback and proper recycling channels in those emerging markets.

We appreciate the advance copies of the CWIT literature [links below] which will guide the discussions in Lyon, France, next week.   While I will be in Lyon (previously scheduled) a few days later, I cannot afford to change my ticket.  Worse, the Association has just completed a major field work in Ghana and does not have the resources to bring representatives of Africa's Tech Sector to the meeting.   Therefore I have prepared this letter to convey our thoughts on this process.

The CWIT report contains a chart (from World Bank) showing electrification rates in several African countries.  We immediately noticed that the first statistic for Ghana was incorrect, perhaps because it is frequently updated.   Understandable, since the statistics on electricity and teledensity in Africa are changing at double and triple digits each year.

What we would like CWIT to learn from this is that import of used electric and electronic devices is not driven by European shredding costs.  It is actually driven by this rapidly changing statistic.

Stating the percentage of household electrification rates in Africa without stating the rate of growth can lead to wrong conclusions.   The relatively low percentage of homes with electricity (as compared to the EU) might imply, to some, that the sales of used electronic appliances are less likely to be "legitimate".

In fact, it is the rate of growth of electrification which predicts demand.

In the USA, for example, the poorest parts of the country were the last to get electricity.  When hydroelectric dams came to the Ozark Mountains, my family members drove to cities like Chicago or St. Louis to purchase used appliances.  Memphis, though closer, had a higher poverty rate, fewer used appliances, and more buyer competition.  If you are poor but making progress, your smartest move is to purchase used goods from wealthy geographies.

Similar modelling accounts for sales of automobiles in geographies which were rapidly paving roads (again, the Ozarks is a good example).   The last place to get paved roads had the highest rates of purchase of both new and used cars, and the ratio of used cars to new cars looked very similar to the rates of used vs. new sales of electronics in Africa.

The CWIT Interpol literature uses works like "illegitimate" and "informal" and "criminal" to describe well established supply and demand patterns.  Perhaps when Germany was reunited, the demand for used cars in East Germany and Poland was driven by a desire in Western Germany to avoid the cost of properly recycling autos...  But if Interpol had targeted auto mechanics in East Germany and Poland, it would have been a poor use of limited enforcement resources, discouraged agents of conscience, and thus attracted criminal enterprise to an otherwise mundane exchange of "good enough" products.

The growth of teledensity (internet, television, cell phone) in Africa is a marvelous story, and one written by canny Africans in the Tech Sector.   The best and brightest students are reading tech repair manuals, hacking phones, and finding the cheapest display devices (ones which last 20 years but are replaced in the West after 4 years are a ripe target).

Language with biblical and "halloween" references, and many photos describing "e-waste" businesses, tend to marginalize, exoticize, and otherize these technicians.  The UNEP's recent use of Agbogbloshie photos to describe Africa's Tech Sector was thoughtless and ill considered.  Similar propaganda was used to describe Simon Lin, Terry Gou, Lee Byung-chul, Chung Ju-jung, and others who repaired and tinkered their way into multibillion dollar economies which lifted the living standards of their compatriots in the most sustainable and environmentally sound manner available - through sustainable reuse, repair and refurbishment.   

If Africa is to meet its own potential, mining ores and shredding working devices is the least sustainable path.  But the demand will be met... there is no "Eden" to shepherd Africans to, and no "Sodom and Gomorrah" to take them away from.  It is fruitless and pointless to try to arrest all the geeks and nerds in Africa.  They are too many.  Crackdowns on internet cafe investors have already occurred in Africa, using "e-waste" as an excuse.   As we say in the Ozarks, "We don't have a dog in that fight."

Export for reuse and repair is explicitly legal in the Basel Convention, Annex IX.  The title of the UNEP Report contains a line about "inconsistencies", which describes well the challenges Interpol will face in enforcing EU interpretations which create new interpretations of the Convention, lined against the forces of supply and demand.   We would ask why, when rhino poaching and child labor and sex trafficking and arms trafficking and conflict metal mining are such a blight, Europe would want to add reuse and repair of electronics to the list that only criminals would succeed at.  Africans have real problems.  Reusing goods is not one of them.

Unintended consequences, collateral damage, friendly fire... These have been offered as excuses for false descriptions of statistics for ten years.  We are asking Interpol to suspend the enforcement of Project Eden until you have met the technicians who not only import used electronics, but have raised Africa's teledensity far beyond the wildest goals set by the most aggressive UN ICT or UNCTAD planners in the 1990s.   Decriminalizing things which should not be criminal is the most difficult, but wisest, challenge for regulators. 

Robin Ingenthron


Founder, WR3A


CWIT Conference Brochure

Here are links to documents sent out to attendees of next weeks "white 'hood" meeting in Lyon (the European neighborhood where attendees can come, which is why it's so hard for us to get Africans there to speak.  They are paying Mike Anane by the way...)

CWIT Analysis and Findings Integrated 2015
"From analysis, we can ascertain that the amount of WEEE illegally exported lies somewhere between 3% as a minimum and 20% as a maximum of the total e-waste generation of 9.500.000t in the EU28+2 for 2012. "
The bright spot is that all the reports showing that BAN and Greenpeace exaggerated and hyperbolized the problem are being read by the enforcement experts. But here's the kicker... they have a plan to increase the illegal statistics... by making MORE trade illegal...  It is a crime lacking legislation, they need legislation to prosecute criminals for violating.
"The lack of specific legislation governing the punishment of such crimes in many countries, and its inadequate enforcement in those where it does exist (often only fines that are insignificant in comparison to the profits that can be made from this activity) creates an environment susceptible to the involvement of international crime groups. The close connection between legal and illegal markets of WEEE has been underlined during the analysis. Offenders belonging to the private sector include company owners, company staff or individuals cooperating with companies. " 
But in the same paragraph, the "close connection between legal and illegal markets of WEEE" creates an environment for criminals.   Because it should be a crime to export for repair, which is unfortunately legal.   Read the whole report, it is Orwellian.  Pesky innocence!

CWIT Recommendations Themes Integrated 2015
"Roll out communication campaigns to raise awareness around proper disposal and separate collection among actors that generate WEEE and among actors that handle and manage WEEE, such as traders, logistics companies, pre-processors and organisations involved in preparing for re-use activities. Many campaigns have been carried out in most EU member states since the implementation of the Directive. However, we also need to raise awareness on the problems related to waste trafficking and improper handling in the receiving countries as well as on the criminal structures and methods involved in waste trafficking. In other words, campaigns should also explain how stakeholders’ acts may support illegal activities."
Basically the document says that while only about 20% of exports of WEEE are illegal (and they consider "for repair" to be illegal), that the discovery of such high proportions of legal reuse make it difficult to enforce against "prospective" criminals.  All those innocent people in the way.    So, they want more campaigns (like Kevin McElvaney photos) to scare people from trading, thinking this will simply the enforcement.


See EU Report from February 2014 for the incredible logic behind the inconsistency reports flooding the mainstream press, leading up to this meeting.   They acknowledges the reuse rates in Ghana.  I haven't had a time to review the whole thing, but here is a past report I have read:

Global Circular Economy of Strategic Metals – the Best-of-two-Worlds Approach (Bo2W)
"Nevertheless, 14 % of the imported e-equipment (equalling around 30,000 t) was not functioning in 2009. While half of this volume was reparable, the other half was clearly in a condition beyond repair (see Figure 2). These volumes (both, repairable and non-repairable items) are e-waste and fall under the provisions of the Basel Convention. As the competent authority in Ghana (EPA) did not receive any request for granting e-waste imports in 2009, these shipments constitute violations of the Basel Convention."

The Basel Convention,  Annex IX, B1110 explicitly says that export for repair is definitely legal.  There is no question, and the reports suggest a Basel COP 12 meeting is necessary to change it.  But even if import for repair was illegal, is 14% fallout (7% true fallout) a reason for arrests and imprisonment, when new product has a higher rate of failure???  The solution, apparently, is to raise the percentage by making more activity illegal.

In tons, if 7% of 215,000 tons is a big number, outlawing trade will do nothing to stop it from growing, because most of the stuff at Agbogbloshie and other dumps was imported more than a decade ago.

From the "Best of 2 Worlds" Report:

Since non-working scrap metal has no "avoided disposal cost", but the CRTs do, they presume that CRTs make up the largest share of illegal imports.   That's just crazy logic.   Africans PAY for the CRTs and pay to ship them, and the CRTs have no value in Africa if they are not working.

The same report speculates that repaired devices will fail sooner.   This is absolutely contradicted by the testimony of African consumers, technicians, and a MAJOR STUDY that found failure rates of new devices were FOUR TIMES HIGHER due to fluctuations in Africa's electric grid.
‘Different continents, different attributes’
“We found that the products we were selling to the advanced market don’t work as much as we’d expect here in Africa and also the people in the different countries and different continents require different attributes,” Park told Agence France-Presse.
“For example, for TV, in the field test we found that the failure rate is almost four times higher than in advanced markets, in Africa because of the power fluctuation.”
The stat here compares it to failure in the EU, but it's the same as the difference in failure rates in less expensive, used products imported from nations with strong warranty laws.   The real question is how to explain the report authors just making things up, if not to protect the "ewaste" hype that's rapidly eroding with each study?  It's one thing to recommend a study of whether 1990s devices fail faster, it's quite another to state it as a finding if you've simply made it up.

The simple explanation for the pie chart is that 7% fallout comes from human error, accidental breakage, ESD, market timing, rummaging by customs agents, not by a deliberate effort by African Technicians to pay to smuggle "waste" to Africa in order to lower Europeans recycling bills!

It is supply and demand, pure and simple, and the "command and control" boys of Europe keep playing whack-a-mole with revisions of statistics that don't support the Greenpeace and Basel Action Network's halloween descriptions of "toxic ewaste poisoning the poor reuse excuse sham".

Most of the actual illegal goods found in Ghana, according to our interviews with customs officials, are used white goods banned not for environmental reasons, but because of a Ghana subsidized electricity conservation program buying back WORKING used appliances.  Ghana has an electricity shortfall and rolling blackouts - which damage new electronics more than they damage solid state used electronics.  More on that later.

It is true that there are many more used flat screens in the Tema market where we visited, but there are still CRTs, and everyone knows African traders are buying and importing fewer CRTs because there are plenty of used CRTs in Africa for that market, the marketplace is now more wealthy Africans selling or giving away their CRT and buying flats.

If this case was made in court by a prosecutor, and a conviction resulted, what are the odds that the man in jail is an illiterate black immigrant to the UK?


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