DRAFT OPEN LETTER
Please send edits, suggestions, comments either by commenting under this draft or by email or tweet to yourname at wr3a.org.
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
DRAFT
Founder, WR3A
fairtraderecycling.org
Please send edits, suggestions, comments either by commenting under this draft or by email or tweet to yourname at wr3a.org.
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
DRAFT
Founder, WR3A
fairtraderecycling.org
