Export of e- from Canada A Story as Told by GPS Trackers

Export of e-Waste from Canada

A Story as Told by GPS trackers

October 10, 2018

A Report from the e-Trash Transparency Project

Basel Action Network

206 First Ave S. #410 Seattle, WA 98104 Phone: +1(206)652.5555 E-mail: http://www.ban.org

Authors: Jim Puckett, Chris Brandt, Hayley Palmer

Editor: Hayley Palmer

Canadian Field Work: David Joseph, Aaron Dirk, Arthur Wood

Hong Kong Field Work: Chris Brandt, Hayley Palmer, Avery Brandt, Nam Chan

Pakistan Field Work: Shakila Umair

Made possible by a Grant from the WYNG Foundation

Table of Contents

Executive Summary……………………………………………. 1 Key Findings……………………………………………………. 3 The Global e-Waste Dumping Crisis…………………………. 4 History of BAN’s e-Waste Tracking…………………………... 6 Ground Zero: Guiyu…………………………………….. 6 Hong Kong’s Role in e-Waste Smuggling……………. 6 China Closes the Door…………………………………. 7 The Promise of GPS Tracking…………………………. 8 The e-Trash Transparency Project……………………. 9 Hong Kong Reacts to GPS Findings………………….. 9 China’s National Sword………………………………… 11 e-Waste in Pakistan…………………………………….. 11 The Canadian Trackers……………………………………….. 12 Introduction………………………………………………. 12 Certifications and Producer Responsibility Schemes in Canada………………………………………………… 12 What we Found Out- By the Numbers………………... 13 Methodology……………………………………………………. 14 Export Overview……………………………………………….. 15 Trackers Deployed March- August 2017……………………. 22 How the GPS Devices Work…………………………... 22 Exported Trackers in Detail…………………………………… 23 ERA Vancouver #1……………………………………. 23 ERA Vancouver #2……………………………………… 25 Uniway (ERA drop site- Edmonton……………………. 28 CDI Markham……………………………………………. 30 Recycle Informatique…………………………………… 31 Evolu-TIC Outaouais…………………………………… 33 Geep, Calgary…………………………………………… 34 Canada’s Most Prolific Exporter……………………………… 36 Continual Exports to Asia………………………………. 36 ERA Vancouver Container Exports 2008-2013……… 37 Data Insecurity…………………………………………... 41 A Non-profit?...... 41 A Recycler?...... 41 Threats and Donations…………………………………. 42 Conclusion……………………………………………………… 43 Recommendations………………………………………. 44

Executive Summary

In 2017 between the months of March and extrapolation would indicate that as much as August, BAN delivered a total of 43 used 116,000 tons of e-waste is exported by electronic devices that contained GPS Canada per annum. And such volumes trackers, to electronics recyclers or recycler would likely represent illegal shipments. collection sites in the provinces of British Columbia, Alberta, Saskatchewan, We followed the Asian bound exported Manitoba, Nova Scotia, Ontario, and devices with field investigations. The three Quebec. We did this to better understand devices that moved to Hong Kong traveled whether Canada and its electronics industry to the New Territories region of Hong Kong-- was complying with the waste trade an area now well documented as being a obligations of the and the global e-waste trafficking and smuggling laws of Canada and of importing countries. hub.2 In New Territories, e-waste junkyards, hidden behind fences, are numerous. All of these electronic devices were They are sites where undocumented rendered non-functional and economically laborers have been recently employed in the unrepairable. The devices chosen were crude and harmful breakdown of the Cathode-Ray-Tube (CRT) type monitors, electronic equipment, often exposing Liquid Crystal Display (LCD) type monitors themselves to dangerous toner dust, and, in (containing mercury lamps) and printers the case of LCDs -- the extremely toxic (containing lead-laden circuit boards). All of metal mercury. the equipment used qualified under the Basel Convention as and Likewise, a field investigation we conducted under Canada's Basel Convention in Pakistan, follow a Canadian LCD to implementation legislation. In each of these, Peshawar. This investigation, revealed we planted a GPS tracker capable of similar harmful breakdown operations of e- reporting to us every 24 hours as to its waste. These operations showed that location. hazardous toners, mercury and lead releases presenting likely harm to workers Of the 43 trackers deployed at Canadian and the general population in the market electronics recyclers and collection sites, area. seven (7) of the 43 (16%) were exported out of Canada. Of the exported tracked 4 of the discovered exports (to developing equipment four of seven (57%) went to countries) were deemed likely to be illegal developing countries -- three to Hong Kong and 3 (to developed countries) possibly and one to Pakistan. The other exports illegal. These assertions arise from the fact went to developed countries, one to that each of these pieces of equipment are Germany and two to the . considered to be hazardous waste under the Basel Convention and four of the five While these amounts can, on the one hand, countries concerned, Canada, China be seen as small, one must not forget what (including Hong Kong), Pakistan, and they represent. Canada generates 724 kt of Germany are all parties to the Basel e-waste per annum. Our sample size is small but if it is representative,

1 http://laws-lois.justice.gc.ca/eng/regulations/SOR-2005-149/page-1.html 2 http://wiki.ban.org/images/1/17/ScamRecyclingContinuesUpdate_2.pdf

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Convention. Under the Convention, all illegal and unsustainable exports from exports by Parties would require that the Canadian shores to developing countries. importing country is notified prior to export In this regard, it is of great concern that the by the government of Canada and Electronics Product Canada consented to by the receiving government of (EPSC), a consortium of electronics China, Pakistan or Germany. And, if they manufacturers operating in Canada, has had been notified to China or Pakistan, removed all references to the Basel Canada would have been obliged to prohibit Convention and issues regarding the the exportation due to the fact that these two exports of hazardous to developing nations forbid the import of hazardous countries from their performance standard wastes from anywhere (in the case of for program recyclers. This fact may play a Pakistan) and from OECD countries (in the role in creating confusion and negligence case of Hong Kong). The shipments to among recyclers in Canada as to the legality Germany and to the US can legally take of their exports. place using other agreements but even under these agreements prior notification The government of Canada needs to do a and consent would still be required. far better job in two respects. First, it needs to ratify and implement the Basel Ban Three of the seven exports, and three of four Amendment, forbidding all exports of (75%) that were shipped to developing hazardous wastes of any kind and for any countries, all came from one company -- reason from being exported to developing Electronic Association (ERA) countries. This agreement is on the cusp of which has had a history of similar exports in going into global force and it provides the past. This report takes a closer look at Canada with the opportunity of being a last- this company and its history and calls for minute hero with respect to promoting global greater scrutiny and investigation of what . And, Canada needs appears to be, a repeat offender. to do a far better job of enforcing the Basel Convention rules that currently apply, The report notes that Canadian industry and particularly in regard to the exportation from government could do far more to rectify the its electronics recyclers.

Port of Vancouver where most of the likely illegal exports leave Canada.

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Key Findings

1. Canada continues to allow exports of hazardous e-waste (16%).

2. Canada continues to allow exports of hazardous e-waste to flow to developing countries (in this case, China and Pakistan). In our study, 9.3% of the deployments were exported to developing countries. These are all likely to be illegal.

3. The export rate of recyclers (16%) is far less than the export rate from recyclers identified 2 years earlier in the United States (34%) but is still of significant concern, especially in light of the fact that Canada has a legal obligation under the Basel Convention and the US does not.

4. Canada generates 724 kt of e-waste per year. Thus, our findings, of the seven units tracked leaving Canada, if extrapolated, could represent as much as 116,000 tonnes of e-waste exported per annum (67,332 tonnes likely shipped illegally to developing countries)

5. Local contamination and harmful exposure in the receiving communities in Hong Kong and Pakistan is likely and would include and exposure from heavy metals, mercury, dioxins, furans, and polycyclic aromatic hydrocarbons.

6. 3 of the 7 exports and 3 of the 4 that went to developing countries were exported by one non-profit organization -- Electronics Recycling Association (ERA) that has a long history of similar exports.

7. 3 of the 7 exporting companies involved in the documented exports were ARMA/EPRA approved processors and R2 Certified. 4 were not certified to any electronics recycling standard.

8. A consortium of electronics manufacturers operating in Canada known as the Electronics Canada (EPSC) does not require Basel Convention Export controls in their standard even though Canada is a Basel Party.

9. EPSC only recognizes the R2 standard, which is not fully compliant with the Basel Convention, but does not recognize the e-Stewards Standard which is.

10. Canada remains one of 23 countries still needed to ensure entry into force of the Basel Ban Amendment, which would prohibit the export of hazardous wastes of all kinds from developed to developing countries. Currently, the Ban Amendment lacks two of these 23 countries to become international law.

The Global e-Waste Dumping Crisis

Due to the ubiquitous use of toxic metals such Asia. These movements take place for as cadmium, lead, and mercury, as well as economic reasons and are instigated by organic compounds such as brominated those wishing to avoid the costs of proper, flame-retardants, e-waste is almost always but more expensive considered hazardous waste under the Basel as required or are norms in Japan, Korea, Convention. The Basel Convention is Australia, New Zealand, in North America designed to strictly control the export of and in Europe. hazardous wastes from developed to developing countries. It is a regulatory The improper processing that occurs in the response to the economic phenomenon of informal sectors found in importing avoiding the costs of environmental protection countries such as China, Pakistan, India, by externalizing them via trade to locations Nigeria, Ghana, and more recently in least able to deal with such wastes and where Southeast Asia, first documented by BAN, its management may be harmful to human has now been quantified by numerous health and the environment. scientific studies conducted in the wake of BAN's investigations. These scientists Since our first groundbreaking report and film have found very serious negative "Exporting Harm: The High-Tech Trashing of environmental and occupational health Asia", released in 2002, impacts, with some of the pollution and (BAN) has continued to observe, document exposure levels rating as the worst ever and campaign against the trade of hazardous recorded. And the identified dangers are e-waste as it has moved inexorably and often not just isolated to the immediate illegally from rich developed countries to victims. Due to the phenomenon of long- poorer global communities, particularly in range transport of atmospheric ,

Boy on Guiyu e-waste dump from the report “Exporting Harm.” This lad came to symbolize the newly discovered e-waste crisis. Copyright BAN 2001. 4

Sampan boats being loaded at the riverbank with U.S. CRTs, in a massive smuggling operation that went on for years at Mong Cai, Vietnam near the Chinese border. Copyright BAN 2010.

as well as international trade in What is not a solution to the problem contaminated food or products, indirect identified is externalizing costs and sending impacts can be felt across the entire harm to the world's desperate workforces in planet. For every computer, phone or disparate, forgotten places on earth. But we peripheral, exported to such a fate, the realize that as long as these quick and dirty world's biosphere becomes ever more false solutions remain un-penalized they will toxic. continue to be exploited. For this reason, it is paramount to continue to mount pressure But to be clear, what BAN has highlighted in to enforce the Basel Convention and the all of our reporting is not the fundamental Basel Ban and prevent all countries from problem, so much as a false solution. The using their global neighbors as dumping problem is that we as a society are creating grounds. The Basel Convention exists to and processing and consuming far too much prevent this outcome and further proposes toxic material -- far too often. We are all to achieve this goal through the complicit, as we continue to purchase implementation of a proposed amendment unsustainable, short-lived electronic (the Ban Amendment) adopted in 1995. products, as are the manufacturers, When in global force, the Ban Amendment including electronics manufacturers who would forbid all forms of exports of give us little choice but to do so. hazardous wastes from the rich OECD and EU group of developed countries to all other The solution with respect to e-waste countries of the world. involves creating and consuming less hardware, using no more toxic materials, However, a handful of other countries known and ensuring that the hardware that is collectively as the JUSCANZ, which include produced is readily upgradable, repairable Japan, the United States, South Korea, and long-lived. And, when all re-use options Canada, Australia, and New Zealand, while are exhausted -- readily and safely remaining Basel Convention Parties (except recyclable. In other words, the solution to the US), fight vehemently against the Ban externalizing the costs in the form of Amendment and refuse to ratify it. Today, pollution and wasted resources to the though, that amendment has been ratified vulnerable lies in ensuring and designing for by 95 countries and is but two Parties away internalizing the costs at the outset of from entering into force. product conception. 5

History of BAN’s e-Waste Tracking

Ground Zero: Guiyu the port, their seals being broken, and the e- waste contents unloaded and placed behind In 2002 BAN first published the tall steel fences. Such operators amassed groundbreaking report and film: Exporting large collections of cathode ray tubes Harm: The High-Tech Trashing of (CRTs), printers, computers, lead-acid car Asia. This report, which centered on what at the time, was the world's largest electronic batteries and other electronic scrap from waste dumping ground created the first real overseas. The waste was, in those days, awareness of the e-Waste crisis. The story not dismantled or recycled in Hong Kong but of this first visit was featured in the New rather stored temporarily, then sorted, and York Times and soon thereafter was widely finally reloaded onto smaller trucks and reported around the world. Following these driven across the border into mainland and first discoveries of the world's e-waste piling on to Guiyu and other Guangdong province up in Guiyu, China, (near Shantao in destinations. Guangdong Province), BAN began its investigations into the smuggling pathways In 2008 and in 2009, BAN worked with the into Guiyu and other areas in China and US television news magazines CBS's 60 around the world that receive e-waste from Minutes, and PBS's Frontline respectively to developed countries of the world. These illustrate the smuggling pathway from the investigations continue to this day. US west coast, to Hong Kong port, on to New Territories, and onward again to Hong Kong's Role in e-Waste Smuggling Guiyu. Also in 2008, we worked with the CBC to produce the documentary e-Waste At the beginning of their research BAN was Dumping Ground. able to find pathways by following-up on numerous solicitations being made by Hong Those award-winning reports were widely Kong-based waste brokers to recyclers in viewed and contributed to putting new, but the US all seeking to buy electronic scrap to not decisive pressure on governments in send to China. We quickly became aware of both the United States and in China/Hong the role of Hong Kong as a major smuggling Kong to do something to staunch the illegal port and the use of the New Territories area trade in e-waste from North America to for staging facilities for the scrap China. One of the results was that Hong equipment. In the period between 2004- Kong's EPD became stricter and began to 2009, BAN made numerous visits to the enforce against imports of lead-acid New Territories area to observe and batteries and CRTs entering the document the smuggling operations first country. This was important because the hand. The operations were initially disposal of CRTs (the older large and heavy concentrated in the Ping Che area but over TVs and computer monitors) used in that the course of time began widening in range time, was reaching a peak, as the entire to encompass the entire length of New developed world switched to flat-screen LCD Territories, which stretches across Hong monitors. Kong's northern border with Mainland China. There, one could openly observe During this period BAN conducted much of intermodal containers arriving by truck from its e-waste tracking research by following

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Intermodal containers by their numbers and effort to screen out "dirty" scrap streams cross-referencing these with online shipping with high levels of contamination they company data. In this way, we could heightened customs operations up and determine the ship, the receiving port and down the coast. Further, they required the date of arrival. Consequently, we were inspections of shipments by a Chinese able to alert authorities, including the Hong agency conducted in the US prior to export. Kong EPD of pending shipments. Over the course of the years 2008 to 2013, BAN was These efforts were collectively known as the able to track 283 container exports from the “Green Fence” and were very successful at US and Canada with 72% of these ending reigning in smuggling. Under the "Green up in Hong Kong or Mainland China. Below Fence", laws such as the e-waste one can see a table of the container tracking importation ban that has been the law since results from BAN's work between the years the late 1990s in China were being enforced of 2008 and 2013. and smuggling and the enablers of smuggling were prosecuted. This led to China Closes the Door direct imports of whole electronic equipment no longer possible. The Hong Kong New Territories electronics junkyards were operational as purely In 2015, China took an even more dramatic smuggling depots for at least a step when they finally, after a decade of decade. However, in the period between promises to do so, closed all of the informal 2012-2015, Mainland China progressively and storefront operations of Guiyu began to enforce their border controls down. Most of these operators were against e-waste trafficking. First, they engaged in the highly polluting enterprise of completely shut down the Vietnam border cooking circuit boards, washing and melting pathway with a sweeping customs action at parts, smelting metals and using acids to Dongxiang in 2014. And, nationwide, in an strip gold from the chips. In a joint federal,

BAN Container Tracking from North American Ports to Foreign Destinations 2008 – 2013

Country 2008 2009 2010 2011 2012-13 Total %

Hong Kong 58 32 32 26 28 176 62

China 5 5 10 5 2 27 10

Pakistan 1 4 0 2 8 15 5

Vietnam 6 2 5 1 0 14 5

Indonesia 1 1 10 0 0 12 4

Malaysia 8 0 0 0 0 8 3

Taiwan 1 5 0 1 0 7 2

Thailand 1 1 2 0 0 4 1

South Korea 3 0 0 0 0 3 1

Macau 0 0 0 3 0 3 1

Singapore 0 1 1 0 0 2 1

Countries receiving one container: Belgium, Côte d'Ivoire, Dubai, Egypt, Honduras, India, 12 Japan, Nigeria, Peru, Saudi Arabia, South Africa, Uruguay. 5

TOTAL 283

state and local edict, they declared all such destination country trends, but it could not operations shut down and forced any that provide the precise addresses of the wished to remain in business to move into a consignees; we could not follow the e-waste massive, newly constructed industrial park past the port. Without the consignee just outside of town. Moreover, they address, we could not be sure the fate of the ensured that all e-waste coming into the waste nor allow the importing countries to park would be inspected and that no waste prosecute the illegal importers. It was from abroad would be permitted. Guiyu during our work to try and find the end- today is now fundamentally transformed and points of the container loads crossing into a BAN unannounced inspection in China from Vietnam when we decided to December of 2015 confirmed that no experiment with GPS trackers to ascertain imported waste is allowed through the gates where all of those CRTs were ending up. of the industrial park and the town itself is a ghost town. We worked in this period (2011-2013) with the Massachusetts Institute of Technology's The complete closure of the informal sector SenseAble Cities Labs to develop the best in Guiyu and a prohibition of imports coming means of tracking actual waste. there was a belated, but major victory for the environment. Had it not taken more than a Our work, while not ultimately successful in decade, we would have all celebrated more. finding the endpoints of the CRT glass, did do an excellent job of following the plastic of The Promise of GPS Tracking the CRTs. Subsequent efforts to implant the tracker into the glass CRT were Container tracking was useful to a degree; it unsuccessful. The success of the plastic could give us an indication of the port a housing tracking, however, convinced us container arrived at and show destination that there was a promising future in GPS

MIT SenseAble City Labs computer rendition of the e-Trash Transparency Project. The brighter white line shows transport to Los Angeles harbor in California and voyage to Hong Kong. Copyright MIT SenseAble City Labs and BAN. 2016.

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tracking. If one could properly attach the our municipality uses, the public tracker, provide it with enough battery life, should have the right to know how their the accuracy was truly amazing, bringing us hazardous e-waste is being handled. to hidden piles of e-waste in warehouses In total BAN deployed 205 trackers in the and behind bushes and trees at farms in US with a significant volume of the tracked China, Malaysia, and Indonesia. waste moving directly to Hong Kong, New Territories. 40% of the tracker enabled We became interested in GPS tracking for devices delivered to recyclers ended up another reason as well. Certain industrial overseas. Visits to the end-points revealed interests began to make claims that the that no longer were these sites smuggling waste trade BAN had described was not but rather were involved in dirty really a major problem. Studies funded by dismantling. All of these discoveries and the US and Canadian governments drew data were made available in the publication conclusions based on using surrogate of two major reports, "Disconnect: Goodwill product data, or corporate surveys to and Dell Exporting the Public’s E-waste to conclude that the waste trade problem was Developing Countries"4, "Scam Recycling. not a serious matter. But none of these e-Dumping on Asia by US Recyclers.5” and studies used real data of real waste in real two updates. time. BAN published an article in August of 2015 entitled "Exporting Deception: The The project resulted in a significant Disturbing Trend of Waste Trade Denial," discovery, which could only have been describing the dangers of this new denial. understood by the use of GPS trackers. We Yet we knew that what was truly necessary learned by visiting the tracker end-points to set the record straight, was real data such with follow-up site visits to the reported as that which could be provided by GPS latitude and longitude coordinates, that the devices implanted into actual e-waste. former smuggling depots of old, were now the new locations for the informal e-Trash Transparency Project dismantling that used to take place in Guiyu. It seemed that the enforcement In 2014 BAN received a major grant by the actions initiated by Mainland China on their Body Shop Foundation allowing BAN to border had resulted in a serious impact on launch the e-Trash Transparency Project3, Hong Kong. Guiyu had passed the mantle which was at this time, the largest for dirty recycling and dismantling on to New deployment of GPS trackers to monitor Territories, Hong Kong. trade in history. Central to the project, as suggested by its name, is the Hong Kong Reacts to GPS Findings belief that the public has a right to know how its hazardous waste is being managed and The extensive media coverage of BAN's e- that all recyclers, manufacturers, and Trash Transparency Project in Hong Kong enterprises should not fail to make that created a political firestorm in Hong Kong's information public. Just as we precisely Legislative Council and helped instigate new know where our goes, and which reforms in electronics recycling policy.6

3 http://www.ban.org/trash-transparency/ 4 https://s3.amazonaws.com/ban-reports/Trash+Transparency/Disconnect+- +Goodwill+and+Dell+Exporting+the+Publics+E-waste+to+Developing+Countries+Report+-+Print+Version.pdf 5 http://wiki.ban.org/images/1/16/ScamRecyclingReport-print.pdf 6 http://www.info.gov.hk/gia/general/201607/06/P201607060492.htm

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Already the Hong Kong government was Most effective was a new licensing package preparing new extended producer of operational requirements for the junkyard responsibility legislation -- The Promotion of electronics recyclers under the Promotion of Recycling and Proper Disposal (Electrical Recycling and Proper Disposal (Electrical Equipment and Electronic Equipment) Equipment and Electronic Equipment) (Amendment) Ordinance passed in March of (Amendment) Ordinance. 2016. This new legislative package will apply to That legislation would see manufacturers eight categories of regulated electrical footing the bill for Hong Kong citizens' own equipment: washing machines, refrigerators, e-waste recycling and a new government- air-conditioners, televisions, computers, owned recycling center established at the printers, scanners and monitors. Any EcoPark. However, that legislation was person engaged in the storage, treatment, mute on the imported e-trash finding its way reprocessing or recycling of regulated to New Territories. This was partially WEEE must obtain a waste disposal license, rectified in no small part due to our tracker while a permit will be required for the import project. and export of regulated WEEE by these newly regulated facilities. The aim of the The EPD also engaged in numerous new controls is to ensure environmental enforcement inspections and raids of the requirements are met throughout the e- facilities BAN's trackers found as well as and dismantling process, from site discoveries of their and the discharge generated does not own. Prosecutions and penalties were pollute the environment or cause nuisance levied against operators and while the to the neighboring area. These controls will amounts were minimal, the impact was felt begin December 3, 2018. and well publicized.

HK01 worked with BAN to produce a powerful series on the New Territories junkyards. Copyright HK01 2016.

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China's National Sword manner of scrap, Pakistan appears to be growing in a dubious role of becoming, By far the most significant development on along with Thailand, one of the prime targets the e-waste trade in the Asia Pacific Region for e-waste traders. This appears to be true took place at the beginning of this year -- despite the fact that Pakistan has officially 2018. China sealed its deal to turn away e- notified all Basel Parties via the Basel waste smuggling by implementing its Secretariat that they possess an import ban "National Sword" policy. This policy, which is for all forms of hazardous waste. said to be an initiative authorized by President Xi himself, has gone further than Much of the equipment sent to Pakistan is the former "Green Fence" policy. It is a very labeled or purported to be second-hand strict import prohibition for almost all forms materials destined for , but only some of scrap including e-scrap. It will not likely go of the imported material is thought to be challenged at the WTO as such a ban is actually reusable and marketable. The left- absolutely within the rights of Basel over waste, in the form of unrepairable parts Convention Parties and such rights were or equipment, is then left for local “recycling” agreed on a very large majority multilateral efforts in Pakistan and no doubt contributes, basis. Despite a lot of industry protest, as it did for years in China, to harmful there are no signs that China will relent and residual contamination and human exposure allow scrap flow towards China. They to damaging pollutants. appear to finally be realizing the disadvantage of importing hazardous In this study our tracker has shown us a residues and scrap that is very difficult path through Karachi, the major seaport without causing serious pollution. This receiving intermodal containers from National Sword Policy appears to be overseas onward to Peshawar. Below in the responsible for some of the very recent tracker section, we include pictures taken at trends being demonstrated by the GPS the computer market there. These dirty tracking results -- including the most recent recycling/management operations are very trend -- the Southeast Asia waste invasion similar to what we have observed in China and to Pakistan. and Hong Kong. Pakistan, for its part, needs to do a better job ensuring that their e-Waste in Pakistan borders are enforced against electronic wastes masquerading as electronic goods. Even prior to the closure of China's borders Pakistan also needs to ratify the Ban and markets, and even prior to our GPS Amendment to ensure a strong message is findings, Pakistan was increasingly seen as sent to the global community that hazardous a target for the world's e-waste. Now, e-waste is not welcome there. following China's border closure to all

Pakistan listing of its national laws on waste trade. Basel Convention website.

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The Canadian Trackers

Introduction world's countries including China, Germany, and Pakistan -- three of the four countries Electronic waste (e-waste) is the fastest discovered in this report as recent recipients growing waste stream today and the world’s of Canadian e-waste exports. most globally traded hazardous waste. The most significant global flows of hazardous e- In this latest reporting, made possible by a waste move from the West Coast of North generous grant from the Hong Kong-based America to Asia. Canada is no small WYNG Foundation, we have for the first contributor to the global e-waste mountains, time made use of GPS tracking technology. contributing approximately 724kt of e-waste A description of that technology follows. per annum.7 BAN's past investigations (see ERA data below as an example) have Certifications and Producer shown that a steady flow of illegal exports Responsibility Schemes in Canada continues to move from Canada, primarily via the port of Vancouver, to Asian ports. Rather than follow Europe's lead in legislating producer responsibility for end-of- BAN's investigations of Canadian e-waste life electronics as was done with the EU's trade began in 2002 following our first visit to WEEE Directive, the Canadian government Guiyu, China in 2001. Following the March opted instead to work in public/private 2002 publishing our US report entitled partnership and allow the manufacturers to Exporting Harm, we completed a Canadian manage Canada's e-waste recycling version later that year on what we had voluntarily. learned about Canada's role in the Guiyu discovery. This report was entitled In 2003 manufacturers set up Electronics Exporting Harm: The High-Tech Trashing of Product Stewardship Canada (EPSC) -- a Asia / The Canadian Story.8 Later, in 2007- non-profit organization comprised of 30 2008 we worked with the Canadian leading electronics manufacturers that sell Broadcasting Company in their documentary their products in Canada. EPSC represents production -- The e-Waste Dumping the interests of manufacturers in shaping Ground.9 In 2014, BAN worked with policy and programs to provide electronics investigative reporter Larry Pynn of the recycling solutions. To date EPSC, through Vancouver Sun to expose the e-waste trade EPRA -- the Electronics Products Recycling activities of Vancouver area e-waste Association also created by the recyclers and exporters.10 All of these manufacturers, has established electronic studies revealed e-waste exports from recycling stewardship programs in British Canada in apparent violation of the Basel Columbia, Manitoba, Newfoundland and Convention -- the world's only global treaty Labrador, Nova Scotia, Ontario, PEI, on waste and waste trade, ratified by Quebec, and Saskatchewan -- representing Canada in 1992. The Basel Convention together over 90% of Canada's population. today boasts 186 Parties -- most of the

7 https://www.itu.int/en/ITU-D/Climate-Change/Documents/GEM 2017/Global-E-waste Monitor 2017.pdf 8 http://wiki.ban.org/images/e/e1/Exporting_Harm_canada.PDF 9 https://www.cbc.ca/player/play/1305152453 10http://www.vancouversun.com/technology/Metro+Vancouver+companies+investigated+unlawful+export+was te+Asia+with+video/8458219/story.html 12

EPRA oversees and manages the recycling 15 (34.9%) moved to an unknown location, of end-of-life electronics from consumers in and 10 (23.25%) never moved from the the aforementioned provinces. To ensure place they were deployed. One device is still EPRA programs responsibly manage reporting. consumer e-wastes, EPRA will only work with recyclers that have been approved Of the 43 tracker-enabled devices deployed, through the Recycler Qualification Program 30 went to government/industry-approved (RQP) and in accordance with the program such as EPRA. Electronics Recycling Standard (ERS). Further EPRA lists approved collection Of the exports, the “Canadian Tracked depots. Devices Exported Table” below shows that three R2 certified companies were involved In Alberta, another organization known as in possibly illegal exports to developed the Alberta Recycling Management Authority countries. But no government/industry ARMA was set up separately to accomplish approved or Certified companies were similar take-back and recycling for involved in exports to developing countries. electronics and three other types of waste. It is important to note that our deployment In this report, we have endeavored to cross- involving just 43 e-waste units (assuming an reference our tracker enabled device average of about 5 kg. each) is small in deployments with the EPRA and ARMA relation to the annual national weight of programs. 724,000 tons. This small sample size makes extrapolation an uncertain exercise Likewise, we have noted which of the except for the sake of argument. processing facilities are R2 Certified and which are not. The EPSC has officially Nevertheless, it is clear that seven exported adopted the R2 program as their model for units are arguably indicative of a far bigger responsible recycling and the not the e- total mass than simply seven devices Stewards Standard despite the fact that e- weighing approximately 35 kilograms. If we Stewards is far stricter with respect to extrapolate for the sake of exploring what a exports, occupational safety and health, and scaling of the problem could well mean, we downstream due diligence. can take our definite export rate of 16%, and arrive at an annual figure of 115,840 metric What we Found Out -- By the Numbers tons of hazardous waste exported (very possibly illegally). This is the equivalent of In 2017, between March and August, the about 3,217 40-foot intermodal containers of Basel Action Network (BAN) deployed 43 hazardous waste leaving Canada for export trackers across Canada. 10 were deployed per annum! in British Columbia, 10 in Alberta, 1 in Saskatchewan, 1 in Manitoba, 13 in Ontario, If we wish to approximate the exports to 7 in Quebec and 1 in Nova Scotia. developing countries (4 or 9.3%), we are looking at 67,332 metric tons or, 1870 The record of each of these is summarized intermodal containers per annum. If these in the Tracker Summary Table below. extrapolations represent anything close to the truth, we have a serious problem of likely Of these, deployments 7 (16%) were illegal and harmful export from Canada. exported, 4 (9.3%) moved to a Canadian Recycler, 6 (14%) likely moved to a Canadian Recycler, 1 (4.3%) moved to a , 13

Methodology

Our Canadian study was designed to Proof of recycling was also received (e.g., replicate what can happen in normal receipt) when provided. consumer actions to dispose of their electronic waste. The study was designed to How the GPS Devices Work be random and rely heavily on the government/EPRA/ARMA websites that a The trackers are like a stripped down consumer would likely find and use. smartphone with no keyboard, no screen, no camera, no audio recording devices and no BAN continued to use the same tracking speakers. They can, however, use the hardware as used in the initial e-Trash global cellular phone systems to make text Transparency Project of the US. However, message phone calls, and they have a GPS this time we made a vital battery switch to reader. These trackers are attached to eliminate the potential fire risk from lithium- non-lithium ion battery packs to ensure a ion batteries. life-span of one year or more. The trackers can respond from virtually any country in the The device types were: world.

• CRT (cathode ray tube) monitors or CRT Typically, we program the trackers to "wake televisions up" from a low energy consuming sleep • LCD (liquid crystal display) monitors or TVs mode every 24 hours. The trackers we use containing CCFLs (mercury-containing cold can be programmed remotely. They then cathode fluorescent lamp) "look" for . If they find three or • inkjet or laser type printers more, they can geo-locate the tracker very accurately (within a radius of about 20 These electronic devices were chosen meters). Then they record the latitude and because each contains components that longitude and send that data to our server. qualify the equipment as hazardous waste, If the tracker cannot "find" the satellites, then and thus each should be controlled under they simply send the latitude and longitude international law (e.g., the Basel of the nearest cell tower. That latter type of Convention). Additionally, these devices signal can tell us what city or country the have sufficient room inside to plant trackers tracker is in but cannot provide a reading of and batteries. All units were made non- the property it is on. In the tables below, we functional and not economically repairable only list latitudes and longitudes when actual prior to deployment to make the legality of GPS readings are made. All other location the export issue more certain and listings are from cell tower readings usually distinguish from those claiming their exports within a range of 20kmm. are to support alleged reuse. For more information regarding our tracking To establish and maintain a chain of technology visit BAN's website of custody, and proof of delivery, BAN commercial service of this technology known recorded a video of each tracker installation as EarthEye at www.eartheye.org. in the e-waste equipment as well as each -- usually a walk-up to a loading dock or office.

14

Export Overview

Canadian Tracked Devices Exported Tracker Deployment Originating Receiving Certified Approved Type Number Location State/Province Country Recycler Depot or of Processor Device (R2 or e- Stewards)

BC141049 ERA, British Hong Kong none no printer Richmond Columbia

BC135488 ERA, British Pakistan none no LCD Richmond Columbia AB135645 Uniway Alberta Hong Kong none no LCD ERA, Edmonton AB140629 Geep, Alberta USA R2 yes LCD Edmonton ON154407 CDI, Ontario Germany R2 yes CRT Markham PQ136213 Evolu-TIC Quebec USA R2 yes CRT Outaouais, Gatineau PQ140264 Recycle Quebec Hong Kong none no LCD Informatiqu e, Quebec TOTALS BC (2) Hong Kong R2 (3) yes (3) LCD 7 Alberta (2) (3) (4) none (4) no (4) Ontario (1) Pakistan (1) CRT Quebec (2) USA (2) (2) Germany (1) printer (1)

15

Trackers Deployed

Below is a comprehensive list of all the trackers deployed in Canada between March and August 2017. The Approved Depot column cross-references the following programs: British Columbia: https://www.recyclemyelectronics.ca/bc/where-can-i-recycle/ Alberta: https://www.albertarecycling.ca/recycling-depots/?city=Edmonton&postal_code=&type=electronics, Saskatchewan: https://www.recyclemyelectronics.ca/sk/about-us/, Nova Scotia: https://www.recyclemyelectronics.ca/ns/about-us/, Manitoba: https://www.recyclemyelectronics.ca/mb/about-us/, Ontario: https://www.recyclemyelectronics.ca/on/, Quebec: https://www.recyclemyelectronics.ca/qc/where-can-i-recycle/

The Approved Processor column shows recycling facilities approved under the EPRA program's Recycler Qualification Program (RQP) or the Electronics Reuse and Refurbishing Program (ERRP) found here: https://reporting.recyclemyelectronics.ca/?process=extranet_rqo_list&language=en For ARMA we drew the approved processors from this document: file:///Users/jimpuckett/Downloads/Compliance_Assurance_Summary_Report_2018.pdf

Tracker Deploy Province Deploy Approved Approved Certified Device Last Reported Number Site Date Depot Processor Type Location dd-mm-yr BC Best Buy British 29-03-2017 Yes N/A N/A LCD Moved to 135389 Victora Columbia Edmonton 3450 Alberta Uptown Blvd #200 Saanich, BC BC CRD British 29-03-2017 Yes N/A N/A Printer Moved to 135686 Hartland Columbia Chilliwack, BC 1 Hartland Ave, Victoria, BC BC ERA British 28-03-2017 No No None CRT Moved to 335335 11280 Columbia Grandview, BC Twigg Pl. Unit 125, Richmon d, BC BC ERA British 28-03-2017 No No None LCD Exported to 135488 11280 Columbia Peshawar, Twigg Pakistan Pl. Unit 125 Richmo nd, BC BC ERA British 28-03-2017 No No None Printer Exported to 141049 11280 Columbia New Twigg Territories, Pl. Unit Hong Kong 125 Richmo nd, BC

Tracker Deploy Province Deploy Date Approved Approved Certified Device Last Number Site dd-mm-yr Depot Processor Type Reported Location BC140868 FCM British 27-3-2017 Yes RQP R2 Printer No Recycling Columbia 2015 movement 1020 Cliveden Ave, Delta, BC V3M 5R5, Canada BC140280 Free Geek British 28/3/2017 No No None LCD Moved to 1820 Columbia Hamilton, Pandora Ontario St, Vancouver, BC V5L 1M5, Canada BC348397 Lee Bottle British 28/3/2017 Yes N/A N/A CRT Moved to Depot Columbia Teck 7385 Metals in Buller Ave, Trail, BC Burnaby, BC V5J 4S6, Canada BC140389 London British 28/3/2017 No N/A N/A Printer Moved to Drugs Columbia Calgary, 7280 Alberta Market Crossing, Burnaby, BC V5J 0A2, Canada Drugs BC163473 Regional British 28/3/2017 Yes N/A N/A LCD Likely at Recycling Columbia Bailey 960 Evans Sanitary Ave, Landfill in Vancouver, Chilliwack, BC V6A BC 2L2, Canada AB140363 Edmonton Alberta 24/4/2017 Yes N/A N/A CRT No Eco Station movement 5150 99 Street, Edmonton, Alberta

17

Tracker Deploy Site Province Deploy Date Approved Approved Certified Device Last Number Depot Processor Type Reported Location AB135645 Uniway Alberta 24/4/2017 No N/A N/A LCD Exported to ERA Drop New site 6744 Territories, 99 St NW, Hong Kong Edmonton, AB T6E 5B8 AB141130 Hi Tech Alberta 24/4/2017 Yes ARMA None LCD Moved to Recyclers Cambridge, 14976 Ontario, 114 Ave Canada NW, Edmonton, AB T5M 4G4, AB135371 Best Buy Alberta 24/4/2017 Yes N/A N/A Printer Likely at E- Edmonton Cycle 17539 Solutions in Stony Plain Airdrie, Rd, Alberta Edmonton, AB T5S 2S1, AB140660 ERA Alberta 24/4/2017 No No None Printer Likely 6744 99 moved to St NW, Hi Tech Edmonton, Recyclers in AB T6E Edmonton, 5B8, Alberta AB136387 Technotrash Alberta 24/4/2017 Yes ARMA None CRT Moved to 537 Taber, Manitou Alberta Road SE, Calgary, Alberta T2G 4C4

AB140413 Recycle Alberta 24/4/2017 No ARMA None Printer Moved to Logic Calgary, 8075 49 Alberta Ave, Red Deer, AB T4P 2V5,

18

Tracker Deploy Province Deploy Date Approved Approved Certified Device Last Number Site Depot Processor Type Reported Location AB136114 Shanked Alberta 24/4/2017 Yes ARMA None Printer Moved to Computer Acme Recycling scrap iron Inc. and metals 11602 in 257th St, Edmonton, Acheson, Alberta AB T7X 6C3 AB133715 Staples Alberta 24/4/2017 No N/A N/A LCD Likely at E Calgary Cycle 3030 32 Solutions in Ave NE, Airdrie, Calgary, Alberta AB T1Y 7A9, Canada AB140629 GEEP Alberta 24/4/2017 Yes ARMA R2 LCD Moved to 5505 72 Chino, Ave SE California unit 9, Calgary, AB SK141379 Regina Saskatchewan 26/6/2017 Yes No N/A LCD Moved to SARCAN Metals 1421 Recovery Fleury St, Facility in Regina, Edmonton, SK S4N Alberta 7N5, MB135546 Mother Manitoba 28/6/2017 Yes No None LCD Looks to Earth be at a 771 Main private St, residence Winnipeg, in Thornhill, MB R2W Manitoba. 3N5, ON154407 CDI Ontario 19/7/2017 No ERRP R2 CRT Exported 75 Clegg to Lünen, Road, Nordrhein- Markham, Westfalen, ON L6G Germany 1A9,

19

Tracker Deploy Site Province Deploy Date Approved Approved Certified Device Last Number Depot Processor Type Reported Location ON136262 ERS Ontario 19/7/2017 No No R2 LCD Moved to 2450 Peel Scrap Lawrence Metal Ave E, Recycling in Scarborough, Mississauga, ON M1P Ontario 2R7 ON135272 ADL Process Ontario 19/7/2017 Yes RQP R2 Printer No 301-500 2010 movement Keele St, Toronto, ON M6N 3C9 ON141247 Greentec via Ontario 19/7/2017 Yes RQP R2 LCD Likely at Burlington 2010 Preston Fire Dept ERRP Plastics 4100 Reprocessing Dundas in Street, Cambridge, Burlington, Ontario ON L7M 4K7 ON141239 ERA Ontario 19/7/2017 No No None Printer Likely #15 489 moved to E Brimley Rd, Cycle Toronto, ON Solutions in Mississauga, Ontario.

ON140470 FCM Ontario 31/7/2017 Yes RQP R2 Printer No 2900 2010 movement Loyalist RQP Street, 2015 Cornwall K6H 6C8 ON135603 ReBoot 103- Ontario 19/7/2017 No No None LCD Moved to 550 Combined Bayview Metal Avenue Industries in Toronto, Toronto, ON M4W Ontario 3X8 ON135991 Com2 Ontario 19/7/2017 Yes RQP R2 LCD No Recycling 2010 movement 6145 Ordan RQP Drive #2, 2015 Mississauga, ON. L5T 2C9

20

Tracker Deploy Site Province Deploy Date Approved Approved Certified Device Last Number Depot Processor Type Reported Location ON136304 Revolution Ontario 19/7/2017 Yes No R2 LCD No ITAD movement 33 Capital Dr, Nepean, ON K2G 0E7 ON140843 Harbour Ontario 28/6/2017 Yes No None LCD No Metals movement 1100 Montreal St, Thunder Bay, ON P7E 6T8 ON140579 Arlen Ontario 19/7/2017 No No None Printer Moved to Recycling 601 Tal Metal Canarctic Dr, in North York, Vaughan, ON M3J 2P9 Ontario ON140967 Toronto Ontario 19/7/2017 Yes N/A N/A CRT No Transfer movement Station 400 Commissioners St, Toronto, ON M4M 3K2 ON140272 BFI Transfer Ontario 19/7/2017 Yes N/A N/A CRT Moved to Station 3354 Dorval, Navan Rd, Québec Navan, ON K4B 1H9, PQ653978 Ecocentre Quebec 1/8/2017 Yes N/A N/A CRT Moved to Lasalle Dollard- 7272 Saint- des- Patrick St, Ormeaux, Lasalle, QC Québec H8N 2J7, PQ134267 Bureaux en Quebec 1/8/2017 Yes N/A N/A Printer Likely at gros ECycle 565 Solutions in Boulevard Salaberry- Lebourgneuf, de- Québec, QC Valleyfield, G2J 1R9, Québec

21

Tracker Deploy Site Province Deploy Date Approved Approved Certified Device Last Reported Number Depot Processor Type Location PQ140264 Recycle Quebec 1/8/2017 No No None LCD Exported to Informatique New 840 Rue Territories, Saint-Vallier Hong Kong O #104, Québec, QC G1N 1C9, PQ139274 Insertech Quebec 1/8/2017 Yes ERRP None CRT Moved to 4820 Rue Hamilton, Molson, Ontario Montréal, QC H1Y 3J8 PQ139795 Suntech Quebec 1/8/2017 No No R2 LCD Moved to Recycle Châteauguay, 642 Québec Guimond, Longueuil, QC J4G 1P8 PQ135652 Valoritec Quebec 31/7/2017 Yes RQP R2 Printer Moved to 700 2010 Toronto, Boulevard RQP Ontario Gréber, 2015 Gatineau, QC J8V 3P8 PQ136213 Evolu-TIC Quebec 31/7/2017 Yes RQP R2 CRT Moved to Outaouais 2010 The 438 Rue RQP International Saint-Louis, 2015 Metals Gatineau, Reclamation QC J8P 8B3 Company, Inc. in Ellwood City, PA, USA NS140496 Elmsdale Nova 02/8/2017 Yes N/A N/A LCD No movement Recycling Scotia 75 Park Rd, Elmsdale, NS B2S 2L3

Province Approved Approved Certified Device Last Reported Location Depot Processor Type TOTALS Alberta (10) No (16) N/A (14) N/A (15) LCD (19) -Exported (7) SK (1) No (15) None Printer -Moved to a Canadian NS (1) Yes (27) Yes (14) (16) (14) Recycler (4) Manitoba (1) R2 (12) CRT (10) -Likely Moved to a Ontario (13) Canadian Recycler (7) Quebec (7) -Moved to Landfill (1) BC (10) -No Movement (9) -Moved to Unknown Location (15) 22

Exported Trackers in Detail

1. ERA-Vancouver #1 unrepairable. Canada is a Party to the Basel Convention as is China. Under the Basel Certification: None Convention, Canada would likely consider the non-functional printer as a hazardous Address of Deployment: 11280 Twigg Pl., waste due to the presence of lead-tin Richmond, BC V6V 3C9, Canada soldered circuit boards and the possibility of selenium containing printer drums or inks Website: containing flammable solvents. https://www.electronicrecyclingassociation.c As such, the Basel Convention applies, and a/ thus any exports of hazardous waste would require notifications sent to Hong Kong by Notes: ERA has a long history of exporting the Canadian government for this particular electronic waste (see special section). In shipment, prior to exportation. Before export, this case, the printer delivered to ERA in the Canada would first have to agree to the Vancouver area went to two different export, then they would have to notify Hong electronics junkyards in Hong Kong's New Kong to see if they agreed to the import. As Territories. The first site had previously Hong Kong has already implemented the been visited by BAN (see photos). This site Basel Ban Amendment (Decision III/1 of is larger than the norm in New Territories Basel), Canada would then know that and involves numerous undocumented China's consent would not be possible, as workers constantly breaking apart Canada is an Annex VII country and China equipment. The second site in Ping Che is is not. Under the Convention, Canada is shown in views below. We visited obliged to respect the import bans of the second location in July of 2018, some importing countries. Any exports/imports of months after the importation. The site had hazardous waste moving to a country that been cleaned out, and there was no has prohibited their import by a private party evidence of electronics. without government approval would be considered illegal traffic (Article 9 of Basel) Legality: Likely Illegal. BAN made the and a criminal act. It is Canada's job to printer non-functional and economically enforce this law.

First location where the ERA- Vancouver tracker ended up. When BAN visited in 2015 the site was mostly processing mercury bearing LCD screens, exposing workers to mercury inhalation and skin adsorption. Here one can see the stands from hundreds of imported LCDs. Copyright BAN, December 2015.

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Tracker Type of Date of Date of State/Province Destination Chain of Number e-Waste Deployment Arrival of Export Country Export Summary BC141049 Printer March 22, British Columbia Hong Kong ERA 2017 11280 Twigg Pl, Richmond, BC V6V 3C9

Yuen Long, New

Territories, Hong May 23, Kong 22.45783, 2017 114.01927

Ping Che, New June 26, Territories, Hong 2017 Kong, 22.52706, 114.16870

First location where the ERA-Vancouver tracker ended up. When BAN visited in 2015 the site was mostly processing mercury bearing LCD screens, exposing workers to mercury inhalation and skin adsorption. It is likely that the recent crackdown by the Environmental Protection Department of Hong Kong on mercury bearing LCD imports has now converted this site to working on printers. Copyright BAN, December 2015.

Drone shot showing the final location of where this tracker last pinged. This site had been drastically cleaned up and is likely a holding area for the e-waste before it is shipped elsewhere. Copyright BAN, July 2018.

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2. ERA-Vancouver #2 market appeared to have been imported with many asset tags from the US and from Certification: None Canada found (see photos below).

Address of Deployment: 11280 Twigg Legality: Likely Illegal. Canada is a Party to Pl., Richmond, BC, V6V 3C9, Canada the Basel Convention as is Pakistan. Under the Basel Convention, unless the equipment Website: was tested and deemed fully functional, LCDs https://www.electronicrecyclingassociation. containing mercury backlights (CCFLs) such ca/ as this one are hazardous waste. BAN made the LCD device non-functional and Notes: ERA has a long history of economically unrepairable. As such, the exporting electronic waste (see special Basel Convention applies, and thus any section on ERA). In this case and an LCD exports of hazardous waste would require monitor delivered to their site in the Canada first to see if Pakistan forbids the Vancouver area went first to Calgary, importation of hazardous waste. As noted Alberta -- likely ERA's site there and then above, Pakistan has already notified the onward to Pakistan. It would appear that Basel Parties that they prohibit all imports of an eastern seaboard port was used. Our hazardous waste into Pakistan. Canada volunteers in Pakistan have visited the site would be obliged therefore to forbid any in Peshawar where the device ended up. exports to Pakistan by ERA or any other The coordinates brought us to the Abbas Canadian actor. Any exports/imports of Computer Market area. There, many LCD hazardous waste moving to a country without screens were found along with evidence of notification and consent are to be considered crude dismantling and dumping of illegal traffic (Article 9 of Basel) and a criminal residues. Most of the devices at the act (Article 4, paragraph 3 of Basel). It is Canada's job to enforce this law.

Tracker Type of Date of Date of State/Province Destination Chain of Export Number e-Waste Deployment Arrival of Export Country Summary BC135488 LCD March 28, British Pakistan ERA 2017 Columbia 11280 Twigg Pl, Richmond, BC

V6V 3C9

Mar 31st, Calgary, Alberta 2017

Oct 3rd, Peshawar, 2017 Pakistan 34.00640, 71.50595

25

Closer view of ERA Vancouver export to Peshwar Pakistan. The Long view of ERA Vancouver export to Peshwar Pakistan. red marker shows the entryway to the Abbas Computer Market. Google Earth 2018. Google Earth 2018.

Entry to Abbas Computer Market, an Discarded CRT TV circuit boards in the LCD screens with mercury-containing electronics street market Abbas Computer lamps at Abbas Computer Market. in Peshawar, Pakistan that receives large Market. Copyright BAN, Shakila Copyright BAN, Shakila Umair, 2018. amounts of imported Umair, 2018. electronic scrap. Copyright BAN, Shakila Umair, 2018

Example of asset tag found at Abbas Computer Market showing the scrap was imported from North America -- the Fort Worth (Texas) independent School District in this case. Copyright BAN, Shakila Umair 2018.

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An asset tag for a Seaton House computer monitor found CRT and LCD breakdown site in Peshawar. exported to Peshawar, Pakistan. Seaton House is Contamination by mercury and CRT phosphors, and Toronto's largest homeless shelter. Copyright BAN, leaded glass appears as a likely result of this type of Shakila Umair, 2018. operation. Copyright BAN, Shakila Umair, 2018.

Gaylord labels indicating origins in Ontario, Canada, Dumped and broken CRTs found in a Peshawar, found in Abbas Electronics Market. Copyright BAN, Pakistan electronics market where Canadian exports Shakila Umair 2018. were traced and found. Copyright BAN, Shakila Umair, 2018

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3. Uniway (ERA drop site- Legality: Likely Illegal. Canada is a Party Edmonton) to the Basel Convention as is China. Under the Basel Convention, unless the equipment was tested and deemed fully functional, Certification: None LCDs containing mercury backlights

(CCFLs) are hazardous waste. BAN made Address of Deployment: 6772 99th Street, the LCD device non-functional and Edmonton, AB, Canada (has since moved or economically unrepairable. has changed to an ERA branded location) As such, the Basel Convention applies, and

thus any exports of hazardous waste would Website: require notifications sent to Hong Kong by https://www.electronicrecyclingassociation.c the Canadian government for this particular a/ del shipment, prior to it exportation. Before

export, Canada would first have to agree to Notes: ERA has numerous depots across Canada listed on their website. The Uniway the export, then they would have to notify Computers firm appears to serve as one of Hong Kong to see if they agree to the these in a joint agreement with ERA but since import. As Hong Kong has already our delivery, this may no longer be the case. implemented the Basel Ban Amendment Once again, our tracking finds ERA exporting an (Decision III/1 of Basel), Canada knows that LCD monitor -- this time to Hong Kong, via consent would not be possible, as Canada is Brampton, Ontario. It would appear that an an Annex VII country and China is not. Eastern seaboard port was used. This Hong Canada as a Basel Party is obliged to Kong end-point was visited by BAN in July of respect the import ban and not allow export. this year. There was one worker who refused to Any exports/imports of hazardous waste allow us to enter and claimed there was no e- moving to a country that has prohibited their waste there and nothing was for sale. When we said we could see the e-waste through the fence import by any actor such as ERA would be he said: "it’s not for sale” and to “go away." considered illegal traffic (Article 9 of Basel) However, by flying a drone over the site we and a criminal act. It is Canada's job to clearly saw the e-waste in the small site (see enforce this law. photo below).

Tracker Type Date of Date of State/Provinc Destination Chain of Export Number of e- Deployme Arrival e of Export Country Summary Waste nt AB135645 LCD April 24, Alberta Hong Kong ERA-Uniway, 6772 2017 99th Street, Edmonton, AB 53.504867, -

113.487220

Aug. 23, Brampton, Ontario 2017

New Territories, Oct. 19, Hong Kong 2017

Kai Pak Ling Road, Nov. 21, New Territories, 2017 Hong Kong 22.459197, 113.982764 28

Google Earth Street view shot down the alleyway. ERA truck and forklift can be seen. Google Earth.

Where the ERA-Uniway LCD screen ended up. Google Earth.

Drone shot of site where the ERA- Uniway LCD screen ended up. We were not able to get in to determine what kind of operations took place there. But it could well have been onward shipping e.g. to South Asia or Southeast Asia. Copyright BAN 2018.

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4. CDI Basel Convention. This OECD Amber- Green Council Decision as it is commonly Certification: None, however CDI is listed referred, still requires that CRT containing in the RQO government approved site list equipment exported for recycling, must be (see below) first notified by the OECD exporting country to the importing OECD country and consent Address of Deployment: 130 S. Town is expected from the OECD importing state. Centre Blvd, Markham, ON, Canada. The question arises, did Canada notify Germany and did they receive consent, Website: http://www.cdicomputers.com/ explicit or tacit in accordance with the agreement? CRTs are listed controlled Notes: In this case, a CRT was exported wastes under both the Basel Convention from Canada to the Lünen area of Germany. and the OECD accord and thus unless they are tested and shown to be fully functional It is very likely that it was sent to the TSR this would be a controlled hazardous waste. Recycling GmbH & Co. KG's primary facility BAN made the CRT device non-functional at Brunnenstraße 138, 44536 Lünen, and economically unrepairable. As such, Germany. Despite this export not being sent the OECD agreement or the Basel to a , it is still likely to be Convention applies to this shipment. BAN illegal (see below). has yet to see a shipment of electronic waste between North America and Europe Legality: Possibly Illegal. Canada and that has properly applied the OECD Amber- Germany are both Parties to a special Green Agreement. We, therefore believe it accord allowed under the Basel is very possible that this export did not Convention's Article 11. The OECD group undergo the required notification and of developed countries have developed an consent procedure and if that were true arrangement under which they can trade would be illegal. The Canadian government in recyclable wastes with somewhat less can check this easily. It is Canada's job to rigor than that normally applied under the enforce this law.

Tracker Type of Date of Date of State/Province Destination Chain of Number e-Waste Deployment Arrival of Export Export Summary ON154407 CRT July 19, Ontario Germany CDI, 130 S 2017 Town Centre Blvd, Markham, ON

July 25th, Toronto, 2017 Ontario

Sept. Dortmund, 21st, Lunen area 2017 Nordrhein- Westfalen, Germany

http://www.oecd.org/env/waste/decisionofthecouncilconcerningthecontroloftransboundarymovementsofwastes destinedforrecoveryoperationsc2001107final.htm

30

5. Recycle Informatique exports of hazardous waste would require notifications sent to Hong Kong by the Certification: None Canadian government for this particular shipment, prior to exportation. Before Address of Deployment: 840 Rue Saint- export, Canada would first have to agree to Vallier, O #104, Québec, QC, Canada the export, and then they would have to notify Hong Kong to see if they agree to the Website: import. As Hong Kong has already https://www.recycleinformatique.com/ implemented the Basel Ban Amendment (Decision III/1 of Basel), Canada knows Notes: The LCD dropped at the Quebec that consent would not be possible, as electronics recycler Recycle Informatique Canada is an Annex VII country and China was exported from Canada to New is not. Canada is obliged to recognize and Territories, Hong Kong. We only received respect the import bans of importing one signal from Hong Kong and it was cell countries. Any exports/imports of tower reading. For this reason, we could not hazardous waste by a private party moving visit the end-point. to a country that has prohibited their import would be considered illegal traffic (Article 9 Legality: Likely Illegal. Canada is a Party of Basel) and a criminal act. It is Canada's to the Basel Convention as is China. Under job to enforce this law. the Basel Convention, unless the equipment was tested and deemed fully functional, LCDs containing mercury backlights (CCFLs) are hazardous waste. BAN made the LCD device non-functional and economically unrepairable. As such, the Basel Convention applies and thus any

31

Tracker Type of Date of Date State/Province Destination Chain of Export Number e-Waste Deployment of of Export Country Summary Arrival PQ140264 LCD August 1, Ontario Hong Kong Recycle 2017 Informatique

840 Rue Saint-

Vallier O #104,

Québec, QC

Oct. Toronto, Ontario 11, 2017

New Territories, May 8, Hong Kong 2018

From the website of Recycle Informatique showing drop depot used by BAN, global recycling logo and citing a Certification Écologique of which there is no such thing.

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6. Evolu-TIC Outaouais smoke was a result of the burning of plastic. There is a great deal of plastic in e-waste Certification: R2 stocks.

Address: 438 Rue Saint-Louis, Gatineau, Legality: Possibly Illegal. There is no QC J8P 8B3, Canada doubt that the LCD monitor deployed at Evolu-TIC Outaouais was hazardous waste Note: It appears this device was exported to due to its lack of functionality and the INMETCO, a subsidiary of American Zinc presence of mercury. Canada and the US Recycling (formerly Horsehead, Inc.) and a have entered into a joint agreement company specializing in nickel and zinc regarding transboundary movements of recovery, and the processing of Nickel- hazardous waste, which is recognized under Cadmium batteries. They also collect and the Basel Convention's Article 11 allowing sort Lithium-ion batteries for the trade between Parties and non-Parties (e.g., Call2Recycle industry consortium. It is not the USA). This bilateral agreement requires clear why INMETCO would be importing that the Canadian authorities would notify LCD monitors unless they have opened their any shipment from Canada to the US to the doors to all manner of electronic waste for US authorities before shipment. It is very an additional source of revenue. Storage of doubtful that this took place. However, this such waste, particularly in the presence of can be affirmed by Environment Canada lithium-ion batteries is a fire danger. The who would have been the competent company experienced a major fire in 2015. authority making the notification. It is The fire departments claimed that the black Canada's job to enforce this law.

Tracker Type of Date of Date of Position, Destination Chain of Export Number e-Waste Deployment Arrival Chain of Country Summary Export PQ136213 LCD July 31, First and Ellwood City, Evolu-TIC Outaouais 2017 Last Pennsylvania, 438 Rue Saint-Louis, United States Gatineau, QC J8P

8B3, Canada

INMETCO Jan 22- (International Metals 27, 2017 Reclamation Company, Inc.) 148 Arch Street, Ellwood City, Pennsylvania, United States 40.857882, - 80.275870 GPS

US/Canadian agreement.

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Aerial view of INMETCO, metals recycler in Ellwood City, PA. Black smoke rising at INMETCO fire. Did this come from Is this site importing large quantities of stockpiles of e-waste? Copyright Dawn Wehman for e-waste? From American Zinc Recycling website. Calkins Media. 2015.

7. GEEP This agreement requires that any shipment of hazardous waste from Canada to the US Certification: R2 must be notified by the Canadian authorities to the US authorities prior to Address: 5505 72nd Ave SE unit 9, shipment. However, even if Canada and the Calgary, AB, T2C 3C4, Canada US did not agree that non-functional equipment containing mercury bearing Notes: In this case, an LCD monitor was lamps was a hazardous waste subject to left at GEEPs Calgary facility. It was likely strict control, there is another transported by truck and then by train to problem. GEEP is one of 7 approved Chino, California but we saw no precise processors in the Alberta provincial signals along the way. While it is possible recycling program administered by the that this shipment could have been Alberta Recycling Management Authority accomplished legally, it does not appear (ARMA). ARMA has confirmed to us in likely. Beyond the fact that Chino is the writing that it does not allow whole units to home of several infamous e-waste be shipped from their processors anywhere, exporters, the requirements of Environment and they require hazardous materials like Canada and the Alberta Recycling batteries to be removed before shipping to Management Authority are unlikely to have any downstream destinations such as the been followed (see below). unknown company in Chino.

Legality: Likely Illegal. There is little doubt If the device were opened up to accomplish that the LCD monitor deployed at GEEP the removal of the batteries, it would first was hazardous waste under the definitions become very obvious to the operator that of the Basel Convention and OECD there is a tracker inside as there is a label agreements, due to its lack of functionality on the tracker saying “if found contact and the presence of mercury. In addition to [email protected]”. Second, it would be very its Basel Convention and OECD obligations, obvious that there are battery packs that Canada has entered with US into a bilateral would need to be removed. However, it is a agreement regarding transboundary certainty that if the batteries were pulled out movements of hazardous waste. by hand or other means, that the tracker

34 tracking unit would cease to function there is was never opened at GEEP and was no internal battery on the tracker circuit shipped whole to a Chino facility. Neither board, and thus the tracking unit would ARMA nor GEEP would reveal the name of never have been able to signal to us from the Chino area facility. Chino, California. Indeed, the data we received indicated virtually no loss of battery We believe therefore that it is likely that this power when it signaled from Chino. Further, export from Calgary to Chino represented the wires that connect the tracker to the either or both a violation of provincial rules three battery packs are very delicate and enforceable by ARMA or a violation of the thus any effort to remove the batteries and USA/Canada bilateral agreement. It is the tracker together while keeping it all job of ARMA to investigate and enforce the functional, and then sending it all together likely provincial rule violation and it is the job intact to Chino would have been near of the Basel Convention Competent impossible (even if the Chino facility was the Authority to investigate and enforce the end destination for batteries) which it likely is bilateral agreement. In this latter case that not. Thus, we can assess that the authority is Environment Canada. We look overwhelming likelihood is that this LCD unit forward to the results of the investigation.

Tracker Type of Date of Date of Position, Destination Chain of Export Number e-Waste Deployment Arrival Chain of Country Summary Export AB240629 LCD April 24, First and Chino, GEEP 2017 Last California, 5505 72nd Ave SE United unit 9, Calgary, AB States T2C 3C4, Canada

June 6, 2017 Chino, California, United States

From installation video, showing tracker (with numbered tape on it) and 3 battery packs on right-hand side of opened LCD screen delivered to GEEP in Calgary. Alberta Authority requires batteries to be removed prior to onward shipping. Battery removal would have disabled tracker. It appears that this LCD monitor was shipped whole without being opened and hazardous substances removed as required. Copyright BAN 2017.

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ERA: Canada’s Prolific Exporter

Our study has identified one organization garner evidence and provide Hong Kong responsible for 75% of the tracked devices authorities with the ability to open up the that moved from Canada to developing containers and determine if contraband was countries. This non-profit company, known inside. as Electronic Recycling Association (ERA), bears some extra scrutiny as it has been in ERA also appeared to have used other the forefront of our waste trade research for companies to do a lot of its collection as well some time now. as exportation. They had a relationship with a former Vancouver e-waste recycler For over ten years BAN has found ERA to known as PC Max -- a company from which be a constant and prolific Canadian exporter we had also documented significant of electronic waste to developing countries exportation. While PC Max claimed that they from three different locations in the merely operated as a drop-off site for ERA, Vancouver, BC area. We have also BAN monitored several truck trailer loads of discovered them selling equipment with e-waste that went directly from ERA's residual corporate data on it to the public. facilities in Vancouver to PC Max's facility in Both of these types of activities are highly Vancouver. We believed PC Max was irresponsible and likely illegal. Over these another channel through which ERA years we have reported the exports to exported large volumes of e-scrap to Asia. Canadian authorities. In 2013 we reported exports and data releases to the Vancouver ERA also operated, and we believe Sun for a series of reports authored by Larry continues to operate, inside of the same Pynn. warehouse as e-Tech Management -- another Canadian/US based company that Continual Exports to Asia has been a famous exporter for many years. The exact relationship between e-Tech and Between the years 2009 and 2013, prior to ERA is not known other than their co- conducting GPS tracking, BAN engaged in location, and this took place -- at two intermodal container tracking. This involved different sites in the Vancouver area. photographing containers in the yard of ERA Recently BAN and HK01 News in Hong and then utilizing online shipping company Kong exposed e-Tech in a report,7 regarding databases to anticipate the foreign port the their North American exports to Hong Kong. e-waste container was destined. We would then alert the Basel Convention Competent Below is a table of just the exports from ERA Authorities (CAs) in the receiving countries. directly. We have similar data from This type of tracking allowed us to know the Vancouver's e-Tech Management and PC- ship, the port of entry and arrival time, but Max as well. could not tell us precisely the contents of the containers or where the scrap ended up, or its environmental fate. Nevertheless, this method proved to be an effective way to

7 http://wiki.ban.org/images/2/29/E-Tech_e-Waste_Mismanagement_at_EcoPark.pdf

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ERA Vancouver Container Exports: Observed 2018-2013

Observed Shipping Container Info Vessel / Movement Comments Date Company Route Name 2008-05-18 Maersk ID: CHARLOTTE Departing from: Estimated Time of Arrival MSKU8761378 MAERSK Vancouver, 26-Jun-08

Notified Competent 0806 -> Arrival date: 2008- Owner: Authority? Yes (MY) on CAPE FLINT 06-29 Maersk June 9 0826 Arriving to: Tanjung Pelepas, Johor (Malaysia) 2008-05-25 CMA CGM ID: CSCL Departing from: Estimated Time of Arrival ECMU4344130 BRISBANE Vancouver, 7-Jul-08

SG346W -> Notified Competent Owner: Arrival date: 2008- Authority? Yes (SA) on CMA CGM CMA-CGM 07-12 June 9 JAMAICA Arriving to: Hong THIS CONTAINER HAD RE449W Kong CRTs ON SKIDS INSIDE. 2008-06-15 China ID: CMA CGM Departing from: Estimated Time of Arrival Shipping CCLU4839664 YANTIAN Vancouver, 16-Jul-08

SG354 W Owner: China Arrival date: 2008- Shipping 07-16 Arriving to: Nansha, Guangdong, China 2008-07-20 MAERSK ID: MAERSK Departing from: TTNU9183955 DAMIETTA Vancouver,

0810 Owner: Discharge Full Port TRITON Qasim Terminal, Port Qasim, Pakistan 08-Sep- 2008 2009-02-22 Evergreen ID: GREET Departing from: Reported to Environment EMCU9440348 Vancouver, Canada 0357-003W

Owner: Arrival date: 2009- Evergreen 03-23 Arriving to: Qingdao, China 2009-07-05 Maersk ID: NEDLLOYD Departing from: Pakistan government MSKU9517197 AFRICA Vancouver, responded with some questions and a thank Owner: Arrival date: 2009- you. But failed to act as Maesk 08-25 far as we know. Arriving to: Pakistan

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2009-08-12 Maersk ID: NEDLLOYD Departing from: PONU7360072 AMERICA Vancouver,

0916 Arrival date: 2009- 11-03 Owner: Arriving to: PO Pakistan 2009-08-21 Maersk ID: NEDLLOYD Departing from: GLDU7009612 AMERICA Vancouver,

0916 Owner: Arrival date: 2009- GOLD 11-03 Arriving to: Pakistan 2011-04-04 K-Line ID: GUANG Departing from: Notified HK but KKFU9053592 DONG Vancouver, message arrived May BRIDGE 18 saying CA was on Owner: Arrival date: 2011- holiday and missed 035W K-Line 05-13 it. Arriving to Hong Kong 2011-05-01 CMA CGM ID: MAERSK Departing from: TGHU8703096 KARLSKRO Vancouver,

NA Owner: Arrival date: 2011- US368W TEX 05-30 Arriving to: Hong Kong

2011-05-11 K-Line ID: BREMAN Departing from: TGHU9071553 BRIDGE Vancouver,

061W Owner: Arrival date: 2011- TEX 06-03 Arriving to: Hong Kong 2011-05-17 PIL ID: BERLIN Departing from: PCIU8417897 EXPRESS Vancouver,

QBX53W Owner: Arrival date: 2011- PIL 06-15 Arriving to: Hong Kong 2011-05-22 CMA CGM ID: CMA CGM Departing from: TGHU9464524 CARMEN Vancouver,

Owner: Arrival date: 2011- US380W TEX 06-21 Arriving to: China

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2011-05-29 PIL ID: Hong Kong Departing from: TCKU9830289 Express Vancouver, QHE55W Owner: Arrival date: 2011- Triton 06-29 Arriving to: Hong Kong 2011-05-27 CMA CGM ID: CMA CGM Departing from: FSCU9648246 CARMEN Vancouver,

US380W Owner: Arrival date: 2011- Florens 06-21 Arriving to: China 2011-06-06 CMA CGM ID: CMA CGM Departing from: CMAU5272710 TOSCA Vancouver,

US388W Owner: Arrival date: 2011- CMA CGM 07-04 Arriving to: Hong Kong 2013-02-24 Hyundai ID: HYUNDAI Departure HDMU2149119 CONFIDENC date:2013-03-06 E Departing from: Owner: Vancouver, 519W

Arrival date: 2013- 04-14 Arriving to: Karachi, Sindh, Pakistan TOTALS 17 Containers China: 4 Hong Kong: 7 Malaysia: 1 Pakistan: 5

Container CCLU4839664 being loaded at ERA in Vancouver, July 2008. This container went to Nansha, Guangdong province China. Copyright BAN 2008.

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Another container ECMU4344130 being loaded at ERA's #38 East 69th Avenue, Vancouver, BC location which contained CRTs, July 2008. This container went to Hong Kong. Copyright BAN 2008.

Container number KKFU7663153. Photographed at ERA's site at 455 Industrial Ave, Vancouver, BC August 2012. This container went to Hong Kong. Copyright BAN 2012.

Container number KKFU9071106 Photographed at ERA, #125 - 11280 Twiggs Place, Richmond, BC September 2013. This container went to Hong Kong. Copyright BAN 2013.

Data Insecurity A Recycler?

Additionally, as was reported to the On their website, ERA infers that they are Vancouver Sun, BAN purchased ten recyclers and refurbishers. Indeed, it does computers from ERA in 2009. On the hard appear that the company has been taking in drives of the computers, we found sensitive many thousands of tons of electronic waste and private residual corporate data from from the public and corporations for years. companies such as Petro-Canada, Borden But there is less evidence that the scrap is Chemical, and CP Rail, including payroll, oil actually refurbished and recycled by ERA. drilling data, and personal SINs (Social Insurance Numbers). All of this was easily They are not listed as designated official uncovered despite ERA's promise that processors or collectors in any of the donated computers are handled “safely and provincial government managed collection securely.” programs such as EPRA (10 Provinces) or ARMA (Alberta) Further, they do not, at least A Non-profit? according to their website, operate under any certified environmental management ERA is a registered non-profit society in the system such as ISO14001, nor do they provinces of Alberta and British Colombia (doing possess recycling or data security business as Computer Donations and Recycling certifications (e.g. e-Stewards, R2, NAID) -- of British Columbia Association). The primary that are expected of responsible electronics mission of these organizations is stated as recyclers. repairing and reusing equipment to provide needy Canadian citizens with free or low-cost computers. According to their BC Society On their website, there are many pictures Registration's constitution they are meant to "be but no photographs of onsite refurbishment funded primarily by members." They are not or recycling taking place. Nor do they assert meant to be primarily funded by the selling of to the public on their website that they send many hundreds of tons of donated equipment to all of their incoming scrap to other recyclers scrap brokers on the global waste market. that are certified for recycling. However, from our estimation, this would appear to be a primary source of revenue for them over the years.

From the Societies Act required Constitution of ERA's British Colombia operation.

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Threats and Donations Company (CBC) that BAN was about to release this latest report on our GPS We exposed the above information tracking program and that it implicated them. previously to the Vancouver Sun in 2013. The founder of ERA, Mr. Bojan Paduh, Since that time, we have noted that ERA rather than explaining why he exports, how has been busy issuing press releases much and whether it can be done legally, establishing relationships with a new threatened the Sun with lawsuits and downstream recycler -- GreenTec, as well likewise wrote BAN an angry, threatening as High-Tech and they are re-asserting a letter (see below). partnership with Shell Canada. We note that Greentec does possess an R2 Prior to receiving this letter, Mr. Bojan Certification-- High-Tech does not. The R2 Paduh had threatened BAN volunteers Standard, however, is not compliant with the photographing his property and later sent Basel Convention for exports of e-waste. people to confront and intimidate the volunteers with large dogs. Additionally, without explanation, BAN received a donation of $100 U.S. dollars Later, when BAN refused to retract their from Mr. Bojan Paduh. statements or apologize for them, as was demanded by Mr Paduh, ERA sued BAN in So far, each time in the last decade BAN a Calgary court for defamation, asking for a has endeavored to look into the Canadian e- public apology and $25,000 Canadian. As a waste export situation BAN continues to find result, BAN was forced to prepare a defense and report that ERA is a company showing to defend their free speech. About one year substantial evidence of likely illegal later, Mr. Paduh's lawyer phoned BAN and exportation. BAN’s intent lies in our hope stated that ERA would be willing to settle that we might see a business model from and wondered what our terms would be. ERA that respects international law. And if BAN stated that we stood by our past not then we would like to see the laws of statements to the Vancouver Sun, so the Canada and international law enforced. only settlement we would accept would be Will the Canadian authorities finally conduct that we issue no apology and they drop their an in-depth investigation into the activities of lawsuit. The lawyer, after conferring, this organization? After all, illegal traffic accepted this "settlement." under the Basel Convention is a criminal act which Parties have a legal duty to Most recently, Mr. Bojan Paduh was prosecute. Our GPS tracker evidence gives informed by the Canadian Broadcast Canada a clear obligation to investigate.

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Conclusion

While it would appear that the illegal or developing countries. It no longer includes unsustainable export of e-waste from any language regarding compliance with Canada is taking place at a rate (16%) less the Basel Convention. than that taking place in their neighbor to the South (34%), there appears to still be a level Instead it merely states that recyclers must of export of hazardous electronic waste that adhere to the R2 standard and not the e- warrants concern and governmental Stewards, or WEEELABEX or Cenelec attention. After all, in the United States, such standard. And yet the R2 Standard is the export is not illegal, and the government is only one of the four global electronics not obliged to prosecute it from an recycling standards that does not forbid the environmental law standpoint. In Canada, export of e-waste to developing countries. however, such exports are likely to be R2 does not contain any reference to the criminal acts. Basel Convention and does not utilize Basel Convention definitions nor apply the In this report, we have seen the reason for Basel Convention obligations. Yet it is these laws in environmental terms. We being used in Canada, -- one of the first have seen the sites in Hong Kong's New countries of the world to become a Basel Territories and in Pakistan where the Convention Party. Canadian waste is broken down in harmful, polluting conditions, threatening the lives of EPSC responded to BAN recently on this workers and the health of communities. We matter by stating that the Basel Convention have found multiple Canadian hazardous e- is the law and so it does not need to be in waste devices scattered around a the standard. One would think that while marketplace in the middle of Pakistan, in this might be true three out of the four operations that are crudely breaking down existing standards cited above make it very printers and mercury-laden LCD and lead- clear what the Basel Convention says, laden CRT monitors. And we are seeing this inside their standard. And, one would think in a country that has banned all imports of that as there has been a long history of hazardous waste. One of the devices found recyclers apparently not understanding the was from a well-known Toronto homeless Basel Convention requirements enough to shelter, Seaton House. And, we have not repeatedly be found to be exporting found the leading exporter in this study, hazardous electronic waste, that the EPSC ERA, to be an organization that purports to would have considered it essential to have be providing equipment for social good. language in the ERS ensuring Basel Something is clearly wrong with this picture. compliance; this can be resolved if the Canada can do better. manufacturers believe it is important.

Canadian manufacturers should immediately Additionally, the Canadian government revise the Electronic Product Stewardship would be well advised to recommit Canada's (EPSC) Electronic Recycling themselves to the wishes of the Standard (ERS). This standard, created by international community and shed their electronics manufacturers used to contain unfortunate reputation of global dumper. strong language forbidding the export of This reputation was cemented in recent hazardous electronics products to years following the debacle of the export of

43 hundreds of container loads of household 5. Corporations and governments to the Philippines -- an egregious generating large amounts of violation of Basel Convention obligations. electronic waste are encouraged to They can do this by ratifying the Basel Ban use GPS tracking (see Amendment -- a 1995 agreement to amend www.eartheye.org) to ensure the Convention to forbid all exports of downstream vendors abide by hazardous wastes, including electronic international law. wastes from developed to developing countries. This agreement is supported by the vast majority of countries of the world 6. Electronics manufacturers must insist and has already garnered 95 ratifications. that the organization they created in Canada to guarantee responsible e- And, currently, the Amendment is on the waste management – EPSC, actually cusp of finally entering into the force of promotes a recycling standard that international law. It needs but two more includes compliance with the Basel countries to ratify it. Canada should be one Convention and the Ban Amendment. of those countries. It has the opportunity R2 does not. before it of becoming a last-minute hero to the developing world, and not be seen as a 7. All countries in South Asia, South serial abuser. East Asia, including Hong Kong, and

Pakistan should adopt the same Recommendations import criteria for e-scrap as has

1. Canada should move to ratify the been adopted in China's National Basel Ban Amendment as 95 Sword policy to create a level playing countries and all of the EU countries field and avoid becoming the target have done. for unscrupulous waste traders and dirty industry migration. 2. Canadian authorities, police, and prosecutors must enforce the Basel Convention's export rules possibly with port inspections and by utilizing GPS trackers placed into wastes.

3. The Canadian Authorities must thoroughly investigate the business and environmental practices of the Electronic Recyclers Association (ERA)

4. Electronics recyclers in Canada are encouraged to consider becoming certified to the e-Stewards Standard as the only North American standard that audits and rewards companies for upholding the Basel Convention and the Ban Amendment.

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