Recommendations to CWIT, INTERPOL on WEEE EWaste Project

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June 25, 2015

David Higgins
Pascal LeRoy

Dear Pascal and David,

Thank you for Pascal's response to our initial draft of comments for the CWIT meeting in Lyon in June.   In addition to presenting more factual numbers, it is important that the CWIT group focus on percentages, not tons.

Ghana's secondhand imports, estimated at 215,000 tons, includes approximately 21,000 tons not reused. That's a real problem, but smaller than the generation of once-reused, now discarded electronics (and cars, and other machines) as cities like Accra modernize.  The generation predicted by World Bank and other sources will require in-country solutions, much greater than "informal" scrapyards (like Agbogbloshie) can offer. 

The ratio of fallout from secondhand electronics imports is similar to clothing, new electronics, automobiles, cell phones, broadcasting equipment.  No import container is perfect.  Shipping damage, human error, demand forecast changes, electrostatic discharge, and other fallout cannot be termed "illegal waste transport" without impacting all development. Criminal enforcement should be directed at goods (such as ivory) which is 100% illegal.

We recommend Interpol and CWIT start discussing acceptable "de minimus" quantities, and whether the testing Guidelines (used in prosecutions) is a good predictor of percentages.  And please, incorporate discussions with Africa's Tech Sector.  They are the ones who send contacts to Europe to source proper reuse equipment, they are the ones who pay for the equipment, they are the ones who have created double and triple-digit teledensity growth for Africans this decade.  Their supply to the "good enough" market creates the critical mass of users which makes paving roads, laying internet cable, erecting cell phone towers, etc., economically feasible.

We can introduce you to several speakers, or university research departments, who know these technicians, who would have been a valuable addition to your list of experts.  Here are some articles written by westerners who accepted this invitation, and met with these champions of the Emerging Market.  Fair Trade Recycling (tm) goal is to engage these technicians in managing the takeback of used electronics, and pay for their proper recycling by donating MORE used equipment at lower prices, rather than by driving up price and lowering demand in the current "Prohibition" enforcement model.

I will be arriving in Lyon (previously scheduled business) on July 1, if anyone from Interpol is interested in meeting to discuss a more progressive agenda to the media-driven "export crisis". In the meantime, here are some articles we recommend for distribution to your guests and attendees.


- Robin Ingenthron, 

PS.  The illegal goods reported in Ghana were refrigerators which work, and which are eligible for a subsidized program to replace them with energy efficient models.   Stating that 1/3 of inspections found illegal goods should differentiate between the energy efficiency ban (not widely understood by importers) and illegal dumping.

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