Now, Here's My Plan...

by Shel Silverstein, 1930 - 1999

What is the right level of tests for a company planning to export for reuse, or export CRT tubes for proper recycling, etc?  There are no CRT glass markets left in the USA, and no secondary copper smelters, and the circuit board refining capacity is all in Europe and Japan.   If it's good to export for reuse, and necessary to export for recycling, how can regulators keep out "toxics along for the ride" (TAR)?

In a past post, I walked through the "decision tree" promoted by some watchdogs to restrict free trade... it shows how a "fully functional" philosophy designed by laymen results in as much or more waste than fair trade agreements.  WR3A and R2 do require standards and tests, and in many ways they are actually stronger than E-Stewards, because they require two-party participation (the overseas refurbisher gets to report that the units were indeed actually working, vs. a USA exporter simply maintaining they are all "tested working").

I've drafted some standards, some borrowed from WR3A, some from E-Stewards, some from R2, and would be interested in getting comments.

The most important thing, which is REQUIRED by EPA for CRT export (and can be applied to other items), is not simply "one time notification".  The exporter must ALSO keep records that the exported material was in fact reused,  and maintain those records for 3 years.  These are also in line with the Basel Convention, which allows exports of CRTs for refurbishment, and circuit boards for recycling, under Annex IX B1110 and B1115.