Two staff members of the Washington-based Institute of Scrap Recycling Industries (ISRI) weighed in on ways Basel Convention trade restrictions may cause harm to recycling efforts, providing comments at the E-Scrap Committee meeting at the Bureau of International Recycling (BIR) Autumn Round-Tables event. That conference took place in Dubai, United Arab Emirates (UAE), in mid-October.
Fred Fischer, ISRI’s assistant vice president-international trade, told delegates the addition of plastic to the Basel Convention’s Prior Informed Consent (PIC) procedures has prompted calls for a review of the way the Convention is structured, its effectiveness and future direction.
In his presentation on the United States perspective on PIC, Fischer remarked that in June, it was agreed that future country-to-country shipments of e-scrap from 2025 would have a notification and certification system similar to that introduced for plastic in 2021. The U.S. is not a party to the Convention but participates as an observer, said Fischer explained, thus limiting the ability of U.S. exporters to trade with non-OECD countries.
ISRI President Robin Wiener said the U.S. government was considering ratifying the Convention. “There are advantages in the ability to influence [by being in it], but there are significant concerns about how it is structured and the way it is going.” She thanked BIR for “its work on the Convention over the years.”
Fischer said it was difficult to quantify the value of e-scrap trade subject to Basel controls but ISRI estimates a figure of $23 billion in 2021, including around $7 billion of OECD exports to non-OECD countries. He expressed concern that electrical or electronic equipment was being defined as “waste” and that that included components, sub-assemblies and consumables that are part of the principal equipment. “Product lists and specific definitions of included products are undergoing discussion in technical and legal expert working groups,” he remarked.
Continued Fischer, “Work is ongoing to determine whether all or only certain categories of goods and ‘fractions’ should be included under the controls of the Convention.” Fischer called PIC a cumbersome procedure that involved large amounts of paperwork requiring prior approval for shipments in all transit countries. “This really has a dampening effect on potential trade. A lot of companies are deciding whether or not to bother with this because it will be so disruptive. Most people would like to see reform. With Basel, everything is waste until it is not. It misrepresents it: scrap has value.”
ISRI also is concerned about possible changes to used equipment destined for repair, refurbishment, or reuse that is not currently considered as “waste” under the Convention if it meets certain assurance, handling and documentation requirements, said Fischer.
The EU has proposed an amendment which ISRI says would allow countries to apply import and export controls on shipments of all types of used goods destined for repair and refurbishment, not just plastics or electronics. “The U.S. government and most industry associations oppose the EU proposal. Given the EU’s outsized influence among Basel Convention Parties – and the U.S. status as a non-party with an inability to substantively influence the discussion and outcome – it means this amendment has a high likelihood of being adopted.”
While the Basel Convention is both an environmental and trade agreement, it is mainly led by environmentalists, said Fischer. “International trade experts and customs officials should be more involved in the negotiations to help improve the effectiveness of the agreement,” said Fischer.
There has not been any fundamental review of the impact of the Convention over the years, according to Fischer. “They have added electronic products with very little discussion or thought about [whether] what they are doing will be effective. We want environmental stewardship of the Earth and responsible businesses, but there needs to be facts and we’d like to see more of that.”
Committee Chair Jan Visser of Germany-based Mirec Benelux/TSR Recycling GMBH and Co. KG spoke about the growing risk of fires started by batteries. He said his company had had a sizable fire in 2018 and it had now cooperated in making a video on fire risk and fire prevention.
The film shows how easy it is for a fire to start, even inside trucks during transportation when no handling is involved. It also provides insight on how changes to the design of recycling facilities and smarter detection technology can lessen the impact of a fire when it breaks out. After the video, Visser said recyclers could meet the challenge by controlling risk at the collection stage, disassembling batteries from equipment, and with stricter inspection and recording of the handling process.
The session also included a presentation on the reuse of electrical and electronic equipment by Stavros Mylonas, managing director of SafeIMS in Dubai. Mylonas set out the approach, systems and procedures necessary for reuse as an effective business proposition. He said recyclers have nothing to fear from greater reuse, arguing it is a complementary activity rather than competitive, and offers extra revenue streams to recyclers.
The BIR Autumn Round-Table Sessions took place at the Intercontinental Festival City in Dubai.