Regulatory Gymnastics: Officials' Time Out for Recycling Waste Offset

Hey, just a quick note to those of you who have been asking what the latest is with the Fair Trade Recycling Offsets.  I remain really excited about this.  But we had a little setback which has stalled the project.

Here's the history, the latest roadblock in RED.

1. Fair Trade Recycling started with Purchase Orders and Fair Trade Contracts.  When we wrote down what overseas buyers DID NOT ACCEPT, it became pretty clear very quickly that they were not buying stuff to burn it or to operate a "Pollution Haven".  Someone paying us 10 times more for a CRT than it's worth in scrap, but paying ZERO for the same make and model which has damage (disqualifying it from the purchase order) is presumed to be a good actor.

regulatory gymnastics (Labadi Beach Accra, Ghana)




2. Fair Trade Recycling tried to scale the purchase orders, with limited success.  Increasing the supply to a buyer was good if they needed more material, but if they didn't need it, every new Cooperative supplier was bumping out an existing member.  So it was good, but not scaleable, and therefore not permanently self funding.

3. Fair Trade Recycling adapted a position as "anti defamation league" for the Tech Sector.  The supply of hyperbole, exaggeration, defamation and racial profiling was noxious. We told the importers stories and got independent researchers to verify that the "80-90% Bad" story about exports was defamatory nonsense.

4. Fair Trade Recycling kept records on the import and export, and also visited buyers overseas. We learned that our suppliers wanted proof that stuff was being reused (SERI and EStewards try to prescribe this with "testing of functions"). We found that no "test" will prevent someone from buying 1000 pieces when they can only sell 800, and that the markets overseas constantly evolve and change just as they do here. By the time the PACE Initiative was printed, it was probably obsolete. In reality, a buyer may be perfectly ABLE to sell your device, but they don't want empty shelves.  A lot of material on inventory in Africa was imported 3 years earlier, and a lot sells off the lot the day it's imported... it isn't a clean "lot" to do mass balance on.

5. Fair Trade Recycling also observed that the Tech Sector shops inherit junk from African/Asian/South American consumers - stuff that was imported "second hand" more than a decade ago, possibly repaired twice, but it's now less expensive for the consumer to "electively upgrade" for a newer import than the cost of repairing it.  The Tech Sector shops were giving these to scrap sector folks on weekly milk-runs, and so had an indirect role in aggregating and then scrapping, after decades of use.



6. Fair Trade Recycling decided to use the 1990s Massachusetts DEP / EPA Region 1 model and treat aggregators of abandoned consumer appliances as "collectors" - incentivizing them rather than calling them names or boycotting what they need for the market today. Putting the well educated valedictorian Tech Sector folks, who employ more women, repair laptops based on schematic diagrams, and troubleshoot software in charge of the wire burning scrappers turns out to be a lot better idea than flying in European grant-happy consultants to save them.

7. Fair Trade Recycling hired a Ghanaian grad student to coordinate paperwork between Tech Sector accumulators and importers, and formal scrap sector re-exporting firms, and got a permit to ship TVs to Camacho in Spain.  Camacho's rep was enthusiastic about the "Carbon Offset" model, and European "big shred" could take back one ton of African (rich in metals, olders scrap) ewaste for every ton of new stuff the Tech Sector imported for reuse.

Europe likes the Offset Model, and I've been trying to sell it to BIR, ISRI, SERI, etc.

Unfortunately, Camacho hasn't been able to complete the import paperwork because of a disagreement over the status of furnace-ready-cullet... the same 'regulatory burden' issue that shut down Mexico's CRT glass recycling markets for over a year (when it's less burdensome to use mined industrial minerals than to reuse waste).

Equally unfortunately, the US Embassy in Ghana has declined to issue visas to two Tech Sector Ghanaians who are aggregators of abandoned repairs (who want to see our operations in Vermont, and also buy parts they need - instead of whole units).

This is a lot of work.

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