The modern world relies on electronic products and equipment every day. From solar mini-grids to smart devices, electronics convey enormous benefits to society and offer new tools to address the energy transition and decarbonization, expand education, deliver health care, elevate communication, refine military operations, advance space exploration, facilitate trade and transport, and more. The consumer electronics market alone is worth an estimated $1 trillion globally and projected to continue growing.
In 2018, 2.7 million tons of consumer electronic goods were generated and managed as municipal solid waste in just the United States. Consumers in the U.S. currently own more than 3 billion electronic products, resulting in a substantial volume of discarded and obsolete electronic devices. These consumer electronics represent only a small subset of the rapidly growing amount of electronics reaching their end of life; businesses and governments are also major users of electronic devices with high turnover. The subsequent electronic waste, known commonly as e-waste, is the fastest-growing component of the municipal waste stream in the country. Altogether, the U.S. contributes approximately 12% of the world’s e-waste.
With the proliferation of the digital economy, the accelerated ambition for electrification, and novel and innovative technologies in the energy, automotive, data storage, cryptocurrency, and other industries flooding the market, the vast array of new and existing sources of e-waste are unaccounted for and unquantified. This presents environmental and social challenges across life cycles and throughout global supply chains — but it also unveils potential opportunities to create value and pursue new economic avenues.
This research paper reviews current e-waste practices and identifies the actions needed to move to a more sustainable, circular economy of electronics. In order to promote such an economy, improvements in tracking and end-to-end supply chain traceability capabilities for e-waste must be implemented throughout industries and across geographies. A sustainable and circular future will also require working symbiotically across life cycles to minimize waste and maximize lasting value. This means that as innovation advances, it will be equally important to partner and collaborate across supply chains and align materials with recovery infrastructure downstream to recapture value. The synergy of activities among all players, from researchers to manufacturers to consumers, is essential along with policy frameworks to solve the e-waste challenge.
If sustainability is truly a societal priority, then it is critical to understand the range of risks, vulnerabilities, and liabilities from social, economic, and environmental perspectives throughout the global network. Not coming to terms with these fundamental realities runs counter to the sustainable and equitable future that industries and governments claim to desire — and will pull society further away from realizing a circular economy.
Many electronic devices reach their end of life after only a few years of use, thanks to technological and societal trends like urbanization, a rising middle class with increased consumer spending power, the rapid pace of innovation and technological advancement and deployment, and growing consumer demand for portable, convenient, and novel products. Consequently, e-waste is the world's fastest-growing waste stream, with an annual growth rate of 3%-4%.
Worldwide, the volume of e-waste generated in 2019 was approximately 54 million metric tons (an average of 7.3 kilograms per capita). Forecasts predict that globally, annual e-waste generation will increase by approximately 30% and rise to 74.7 million metric tons by 2030, and could reach 120 million metric tons per year by 2050. On average, the total weight of global electronic and electrical equipment consumption increases by 2.5 million metric tons every year, a direct consequence of widespread economic development. It should be noted, however, that annual generation estimates vary markedly due to the range of materials classified as e-waste under various policies around the world as well as the diverse methodologies employed to quantify the volumes generated.
China has been recipient to the majority of the e-waste generated around the globe, and it is also the largest producer of e-waste in the world, generating more than 10 million metric tons in 2019. The U.S. and India follow at 7 million metric tons and 3 million metric tons, respectively. The U.S. and China comprise 32% of the world's total, but on a per capita basis, Norway ranks the highest for e-waste generation with 26 kilograms per inhabitant, followed by the United Kingdom and Denmark. Nonetheless, China’s production rate is higher than the global average, and it is expected that in 2030, the country will generate approximately 28.4 million metric tons of e-waste.
A global population expected to rise to 11 billion by 2050 will undoubtedly stimulate technological advancements and drive a strong increase in global demand for electronic goods. It will also create more waste; eventually, everything will reach its end of life and require disposal. Thus, the question of how and where all these used electronic devices will be properly managed is one of increasing importance.
A question at the heart of this issue is: Should used electronics be considered waste, or commodities that could be reused or recycled, for example — or both? Further, if used electronics are classified as waste, are they hazardous waste, universal waste, or nonhazardous waste? If they are hazardous waste, should there be exceptions to their treatment if they can be recycled or resold? The answers to these questions are largely dependent on classification and perspective and can ultimately influence the fate and disposal of e-waste.
What Is E-waste?
“E-waste” describes devices that are unwanted, not working, obsolete, or nearing or at the end of their “useful life” and destined for reuse, refurbishment, repurposing, salvage recycling through material recovery, or traditional disposal avenues such as landfill or incineration. E-waste is defined in many ways across the globe; in some cases, it is described as a broad category of electrical or electronic equipment requiring electrical currents or electromagnetic fields to perform the function for which it was designed and manufactured.
It is impossible to define e-waste in absolute terms, or to narrow it to an exhaustive list of products or devices, since electronic components are being integrated into an expanding, open-ended scope of commodities that were not traditionally computerized but technically qualify as e-waste. The classification has thus evolved into a broad array of products including almost any discarded household or business item with circuitry or electrical components with a power or battery supply. By some definitions, it encompasses all discarded objects embedded with an electronic chip. The categories of e-waste include medical, monitoring, and control devices; everyday consumer products such as laptops, monitors, phones, and other smart devices; televisions; large and small household appliances; lamps and luminaries; and IT and telecommunications equipment.
But e-waste can also include a considerable number of other devices: for example, lithium ion batteries and batteries contained in electric vehicles (EVs), wind turbines, and other equipment; solar panels, cells, modules, and systems; electrolyzers for hydrogen production; cloud/data and energy storage systems; cryptocurrency mining hardware; and orbital debris and spacecraft fragments, including defunct satellites and spent rocket parts. (See Figure 1.) None of these are included in current e-waste projections. The conglomeration of expansive categories under the domain of e-waste further obfuscates its tracking, treatment, and final disposal.
Figure 1 — Examples of E-waste Types by Generator
E-waste, a heterogeneous mix of hundreds of diverse substances, exists in myriad forms with various levels of complexity. Its composition differs considerably depending on the design and functionality of the device, creating challenges for waste management. For example, many electronic products may contain hazardous materials and/or hazardous wastes; valuable materials such as gold, cobalt, silver, copper, and nickel; halogenated materials, plastics, glass, and ceramics; or rare materials that are strategically important to the economy or national security, like indium, palladium, platinum, and gallium. In a resource-constrained world, many of these materials in e-waste could be prioritized for second-life applications. But numerous complications exist; hazardous materials such as mercury, lead, and brominated flame retardants, for example, require special management in permitted waste treatment and disposal facilities.
The Linear Economic Model: No Longer Fit for Purpose
Today, it is clear that the current linear economic model of electronics production, consumption, and disposal is no longer fit for purpose. It is challenged by consumer preference and a greater focus on sustainability and the circular economy — an economy that seeks to eliminate waste and pollution, keep materials at their highest economic value, recirculate products and materials through the value chain, reduce the draw on nonrenewable minerals, fuels, and feedstocks, and create regenerative systems.
Since 2017, annual global primary resource extraction and use has exceeded 100 billion metric tons per year, and estimates indicate that by 2050, annual global material use could be between 170 billion metric tons and 184 billion metric tons. The production of minerals is expected to increase by nearly 400%-600% over the next several decades to meet the demand for electronics and alternative energy technologies like wind turbines, solar power, and energy storage systems. For minerals such as lithium and graphite, which are used in EV batteries, demand may increase by even more — as much as 4,000%. More than 3 billion metric tons of minerals and metals will be needed to manufacture and deploy these systems by 2050. Minerals deemed critical to the economy and national security will increase fivefold by 2040 as the global clean energy transition unfolds.
Vast amounts of resources are wasted across the electronics life cycle during mining, manufacturing, transport, retail, consumption, and disposal. This generates an array of negative impacts throughout the global network. For instance, minerals required for global energy transition strategies are often produced in countries that score below average in measures of corruption risk. Environmental standards and oversight are generally low in these same countries. Aside from political and national security risks, supply chain disruptions, and price shocks, human rights violations associated with the mining, processing, and refining of critical minerals in high geographical concentration production areas with unstable governments are well documented. Yet they are unaccounted for in sustainability profiles and environmental, social, and governance (ESG) reporting. The production and processing of mineral resources gives rise to a variety of environmental and social issues — including hazardous working conditions, child labor, forced labor, and lax environmental laws — that, if poorly managed, can impair local communities and disrupt supply.
There is growing evidence of problems related to the use of scarce metals, such as the long-term risk of high-grade ore depletion worldwide, shorter-term supply deficits, and mineral-related geopolitical conflicts. Recycling, material substitution, and dematerialization (i.e., using cheaper materials or reducing the amount of material and energy used per produced unit of service or utility) measures are being undertaken or encouraged by firms in the manufacturing industry to reduce the impact of scarcity. However, these responses can be costly, take time to implement, are not available to all participants, and can lead to permanent market changes.
At the end of life, e-waste is often incinerated, disposed of in landfills, or exported to developing economies under the guise of recycling, reuse, or repurposing schemes — largely to countries that lack adequate labor, health, safety, and environmental laws. It is well documented that when improperly disposed of or routed to uncertified recyclers, e-waste has negative effects on human health, the environment, and the overall ecosystem. More than 12 million women and 18 million children (starting at the age of 5) are employed in the informal e-waste management sector globally, recovering small amounts of gold, copper, and other semiprecious metals through rudimentary dismantling and artisanal processing techniques such as fire roasting, acid dissolution, leaching and digestion (for metal extraction), or open burning. In these unsupervised and unregulated settings, they face a constant risk of exposure to unsafe conditions and toxic chemicals known to cause cancers, reproductive health issues, and cognitive impairment.
Unregulated practices, deficient infrastructure, and lack of oversight, governing legislation, and regulation also cause wide-ranging disruptions to the ecosystem. Crude recovery practices and the disposal of unsalvageable parts on open land, on shore, or adjacent to surface waters (e.g., rivers and lakes) leach heavy metals like lead, barium, mercury, and other contaminants into surface water and groundwater, sediment, and soil. The resulting emissions into the atmosphere have far-reaching consequences well beyond immediate human health. The contaminants next enter the food chain, giving rise to various diseases and indirectly causing health issues.
Despite the current body of knowledge regarding the impacts of e-waste, there are still significant data gaps in the full spectrum of electronics sustainability. The spectrum includes the effects on biodiversity, human rights, gender equity, quality of life, and environmental justice, as well as how shifting to circular practices will impact corporate and government sustainability agendas.
If linear models continue, so too will our draw on natural resources and the associated impacts along the global value chain. This could lead to mineral resource depletion on a scale that inhibits the global decarbonization effort. The unsustainable and prevailing linear “take-make-use-dispose” economic model increases environmental, social, economic, and political risks globally and is driving a transition to a circular economic model — a pathway to mitigate these concerns.
A circular economy is most effective when working symbiotically across supply chains to create value. However, a strong waste-centric and “end-of-pipe” narrative limits the vast social, economic, and environmental opportunities that newer circular models can offer, such as dematerialization and greater resource optimization. These economic opportunities are far broader and more diverse than those focusing solely on end-of-life activities, especially in an ideal circular economy where products and processes are designed to avoid the creation of waste in the first place. But the current global economy is only 8.6% circular and trending down from previous years. Absent a shift in policies, business and consumer behaviors, and innovation, the amount of e-waste alone could more than double by 2050, driving society further away from realizing a circular economy.
The Challenges of the Future Are Happening Now
With today’s technological advances and innovation, the demand for and production of electronics and electrical equipment is happening now and expected to continue. Meanwhile, the rise of novel e-waste streams is increasingly concomitant with the growth in electronics. The equipment used to enable artificial intelligence, smart devices, digitization, cryptocurrency mining, cloud computing, robotics, space exploration, blockchain, the penetration of 5G cellular networks, autonomous technologies, climate and alternative energy innovations, and other electronic-enabled developments will eventually reach obsolescence and require end-of-life or end-of-use management.
Moreover, innovation may lead to faster obsolescence. Consider how regularly cell phones and other smart devices are upgraded for newer-generation models, leading to the jettison of old models that are still fully functional. With the introduction of advanced products, devices, and technologies, the end-of-life management of emerging waste streams will become a greater obstacle; recycling and recovery facilities will need to adapt their technology, processes, permits, and operations to the expanding and evolving array of e-waste. Even if recovery and recycling processes are developed for the variety of novel and incoming technologies, certain critical factors including economic feasibility, robust secondary markets, and a favorable policy environment will be needed for commercial viability and to reach economies of scale.
The Evolution of Cathode-ray Tubes: Policy’s Failure to Keep Up
Cathode-ray tubes (CRTs) — the glass video display component of an electronic device commonly found in older televisions and computer monitors — are one example of how end-of-life technologies and policies have been unable to keep pace with the rapid development of novel products and their deployment into the market. Older CRTs were once readily recycled into new CRTs, but the demand has collapsed in favor of new flat-panel technologies. In the decades since, CRT recycling has plagued glass manufacturers, recyclers, the waste management industry, and policymakers due to rising costs and negative economic incentives, the cost of collecting and then transporting disused CRTs to central locations, the total supply of waste glass exceeding demand, and shifts in CRT glass markets. Further, the formulation of CRT glass, which includes lead, means it is not well-suited for most reuse options, and CRTs designated for disposal are classified as hazardous waste in the U.S. under the Resource Conservation and Recovery Act (RCRA).
Without significant capital investment or revamping or reengineering their operations, the recycling facilities designed to handle the CRTs in obsolete computer monitors and televisions were not equipped to manage or keep pace with the rapid technological development that led to newer-generation devices, which were migrating to the waste stream at a steady rate. Domestic secondary lead smelting facilities were often prohibited from receiving the glass due to its classification as a hazardous waste, since processing the glass would require costly modifications to their permits.
The high volume and value of the glass did not incentivize the facilities to make the needed investments. Because of rising costs, negative economic incentives, and shifts in CRT glass markets, some CRT processors and recyclers have opted to store CRTs indefinitely or speculatively accumulate them (i.e., accumulate them with no assurance that they will actually be reused or recycled) rather than send them for recycling or disposal. This increases the risk of mismanagement and/or the future abandonment of CRTs.
While the evolution of CRTs to newer-generation technologies offered many commercial and physical advantages for consumers and manufacturers, such as improved image quality, streamlined profiles, minimized weight, and lower energy consumption, it also created new challenges. These included the sourcing of new minerals and materials as the technology became more advanced and the complexities involved in the dismantling and recycling of devices became more heterogeneous in nature. CRTs were gradually phased out and replaced with thin film transistor (TFT) flat-screen liquid crystal display (LCD) monitors, whose backlighting lamps contain mercury. These were followed by light-emitting diode (LED) screens, which, although mercury-free, contain lead, copper, nickel, and silver. LED screens have been followed by the now-favored quantum dot displays, which contain cadmium. Each of these relatively new technologies introduces nanomaterials and RCRA-regulated heavy metals into the e-waste stream, creating regulatory and technical challenges at their end of life. This transition has led to the global accumulation of CRT waste (6.3 million tons in 2014), with only 26% of CRT waste recycled globally.
Cloud Storage and Data Centers Are Set to Flood the End-of-life Market
The installed data storage capacity in the U.S. is projected to reach 2.2 zettabytes by 2025, generating about 50 million units of end-of-life hard disk drives per year. Cloud storage is spread across approximately 70 million servers housed inside 23,000 data centers across the world; combined, they weigh as much as 192 Eiffel Towers. One of the largest centers spans over 1.5 million square feet, a footprint that would accommodate 20 professional soccer fields.
Typical equipment upgrading and decommissioning processes across the cloud storage industry occur every three to five years, at which point devices are physically destroyed by shredding for data security and privacy purposes. The resultant waste undergoes a variety of processes, such as smelting, recycling, incineration, and landfill disposal. This means that most of the 11 million servers that were produced globally in 2017 were decommissioned in 2022. And with 700 hyper-scale data centers set to be constructed around the world over the next three years, more e-waste is set to flood the end-of-life market.
Companies that provide cloud infrastructure, such as Amazon and Microsoft, as well as financial institutions, police departments, and government agencies, undergo “data sanitization” each year, a process that involves shredding millions of data-storing devices to ensure data privacy is maintained. In the U.S., it is estimated that 20 million to 70 million hard disk drives are destroyed annually, despite 60% being viable for reuse and 95% of the magnets being recoverable or intact. Anecdotally, a number of e-recyclers are required under contract with suppliers who are skeptical of current data sanitization processes to destroy hard drives. A part of the service fee covers the cost of recycling and other handling fees. Aside from the vast amounts of energy consumed at data centers and the large share of greenhouse gas emissions produced, the data storage industry’s practice of shredding devices at their end of life due to security concerns — even if they are still fully functional — represents an economic loss for society and counteracts global efforts to decarbonize, reduce waste, and advance the circular economy.
The final fate of data storage devices could be recycling, after other life cycle extension options such as reuse or repair are exhausted; reuse conveys better environmental, social, and economic benefits over destruction, even when accounting for uncertainty, as does material recovery, the next-best option. Ultimately, though, these are contingent on consumer trust in data-wiping software and technologies.
These challenges could be alleviated by creating new technologies and designing devices to have a longer life span; promoting high-value reuse, recycling, repair, remanufacturing, and upgrading; designing out waste or using waste as a resource; substituting materials; redesigning products and processes; and other circular end-of-life pathways. This will require unprecedented partnerships and supply chain collaboration from the design phase across the value chain to end-of-life industries and secondary markets.
The Cryptocurrency Industry Has a Waste Problem
The energy demand and greenhouse gas emissions associated with cryptocurrency mining have sparked a passionate debate about the sustainability of digital currency. The computing power required to mine coins is enormous, with Bitcoin alone estimated to consume 707 kilowatt-hours per transaction in addition to the energy needed to cool its systems. Due to varying levels of energy efficiency among computers and cooling systems, it is difficult to estimate how much electricity Bitcoin uses. But published estimates indicate that crypto assets consume between 120 billion kWh and 240 billion kWh per year — exceeding the total annual electricity usage of many individual countries, such as Norway, which consumes only 124.3 terra-watts per year, as well as the electricity consumption of Google, Apple, Facebook, and Microsoft combined. This is equivalent to 0.4% to 0.9% of annual global electricity usage, and is comparable to the annual electricity usage of all conventional (non-crypto asset) data centers in the world. The U.S. is estimated to host about one-third of global crypto-asset operations, which currently make up approximately 0.9% to 1.7% of the country’s total electricity usage. This range is similar to that of all home computers or residential lighting in the U.S.
The sustainability of cryptocurrency mining also depends on the source of electricity used to power mining operations from one country or region to the next. For instance, the Cambridge Centre for Alternative Finance's Bitcoin Electricity Consumption Index found that in 2020, coal accounted for about 40% of mining power and that 37.6% of electricity used by bitcoin miners came from sustainable sources (compared to 62.4% from fossil fuels). This figure conflicts with that provided by the Bitcoin Mining Council, which reports that 59% of the electricity used by the bitcoin industry originates from sustainable sources.
Consistent with ongoing debates in energy transition and climate policy, most of the research and discourse on the impacts of bitcoin (and similar cryptocurrencies) has focused on energy demand and emissions. It has thus far neglected the environmental and social aspects of the usage and disposal of raw materials contained in the specialized mining equipment, which is what requires energy consumption in the first place. Cryptocurrency miners cycle through a growing amount of short-lived hardware — such as application-specific integrated circuits (ASICs), whose average mining device life span is limited to 1.29 years — which will undoubtedly exacerbate the growth in global e-waste.
The annual global volume of e-waste from bitcoin mining is about 30,700 metric tons, comparable to the amount of small IT and telecommunications equipment waste produced by a country like the Netherlands. And this figure only accounts for bitcoin — not ethereum, tether, binance coin, solana, or any of the other 20,000-plus cryptocurrencies and 500-plus cryptocurrency exchanges worldwide. Neither does it account for e-waste generated from the use of cooling equipment, cables, lamps, and other peripheral devices.
The global cryptocurrency mining market was worth $1.92 billion in 2022 and is projected to grow to approximately $7 billion by 2032. On a geographic basis, North America is expected to account for the largest share of the market due to the technological advancements, rising demand for cryptocurrency, and presence of major players in the region. Several government initiatives in Canada and the U.S. to legally adopt cryptocurrency systems have further supplemented growth. Although there are ongoing efforts to decarbonize cryptocurrency mining by powering operations with alternative energy sources or flared gas from oil and gas production, the extremely short life cycles of mining hardware and their contribution to the rising amount of e-waste still need to be addressed.
E-waste: A Wasted Opportunity
The global e-waste management market was valued at $49.88 billion in 2020 and is forecast to reach a value of more than $140 billion by 2028, with a compound annual growth rate of 14.3% from 2021 to 2028. This includes recycling and other traditional forms of waste management for metals, plastics, glass, and other materials, with a primary focus on household appliances and consumer and industrial electronics.
The electronic scrap recycling industry in the U.S. provides a boost to the economy of approximately $20.6 billion, including exports of $1.45 billion. In the e-waste recovery market for metals, the key factors driving expansion are growing investments in minerals and precious metals in the emerging countries of the Asia-Pacific, demand from end-use industries, and the necessity of managing e-waste before disposal.
An extensive variety of valuable materials, including plastics and minerals, are contained in electric and electronic devices. Today these are mainly iron, copper, and gold, but other minerals, such as lithium, nickel, cobalt, and rare earth metals, are growing in importance as decarbonization accelerates. The total global value of all raw materials in e-waste discarded in 2019 is estimated at approximately $62.5 billion — more than the GDP of most countries in the world (Figure 2).
In China, the value of metals discarded as e-waste is forecast to total $23.8 billion by 2030, presenting an enormous opportunity to generate value through a circular economy. For the rest of the world, which routinely exported e-waste to China, the country’s recent restrictions on the import of certain plastics, scrap metals, and wastes will further exacerbate the need to globally manage this complex and growing waste stream. China, as well as the countries that export to China, will be forced to establish and improve national e-waste management strategies to adapt to the ban.
Figure 2 — Potential Recoverable Raw Materials from E-waste by Value, 2019 (billions of USD)
Figure 3 — Potential Recoverable Raw Materials from E-waste, Weight in 2019 (million metric tons)
Globally, only $10 billion worth of e-waste is recycled and recovered sustainably. Improper end-of-life management results in a significant loss of scarce and valuable raw materials. For instance, 33 pounds of palladium, 75 pounds of gold, 772 pounds of silver, and 35,274 pounds of copper can be mined into 1 million smartphones. Another example from urban mining (the process of reclaiming raw materials from waste products sent to landfill): 1 metric ton of circuit boards can produce up to 1.5 kilograms of gold and 210 kilograms of copper. Moreover, the concentration of precious metals from urban mining is far greater than that from primary ore mining; for instance, conventional mining of gold from ore contains 0.005 kilograms per metric ton, and copper contains 5.25 kilograms per metric ton. As such, gold and copper concentrations are 300 and 40 times higher, respectively, from urban mining than in ores. Electric and electronic scrap also represent a growing share of plastic waste, which accounts for approximately 20%-30% of the roughly 54 million metric tons of e-waste produced worldwide each year.
If appropriate business models are applied, material recovery can generate significant profits and be used as a source of primary raw materials to manufacture new equipment — thereby reducing upstream social and environmental ramifications, downstream impacts from the extraction and refinement of raw materials, and additional transportation costs. Extending the lives of products and reusing components conveys an even larger economic benefit. Companies can tap this value potential by adopting new circular business models, optimizing the entire product life cycle along the value chain (Figure 4).
Figure 4 — Circular Economy Strategies
It is important to note that e-waste volumes and material composition vary with technological progress and consumer trends, making the intrinsic value of electronic devices a moving target that could decrease rapidly as manufacturers attempt to reduce costs through dematerialization. Declines in intrinsic value and increases in complexity make recycling more difficult, both economically and technically. Dematerialization could cause recycling to become less efficient and more costly per unit mass through loss of scale (all else being equal). To maintain the mechanical properties that ensure durability, the material lost to dematerialization is often the most recyclable, thus rendering the product full of mostly unrecyclable material.
Recycling and End-of-life Management of E-waste
The majority of e-waste is technically recyclable, and recycling rates vary by region of the world. But the current global recycling rate is grim and perhaps greatly overestimated, given that the entirety of an e-waste item (including plastics and lower-quality metals and materials) is rarely recycled or recovered in either formal or informal operations.
Low recycling rates can be attributed in part to the complex multi-material composition and different physicochemical properties of e-waste, which make the standardization of recycling processes complicated. Other important factors include the lack of actual tracking or traceability to verify recycling, the wide spectrum of e-waste categories and inconsistent classification, complex and disparate end-of-life supply chains, and the complicated economics of profitably collecting, dismantling, recovering, and recycling e-waste. The recovery of some materials, such as germanium and indium, is challenging because of their dispersed use in products, and because devices are generally neither designed nor assembled with recycling principles or their end of life in mind. Further, today’s policy focus on recycling “target” materials, like lead and cobalt, does not account for emerging materials of concern, like mercury and indium, and complicates the overall viability of recycling the entire electrical or electronic device.
Despite the promise of a profitable e-waste management economy, there are ongoing challenges to improve recycling, as the current cost of recycling can be much higher than the revenues generated from the recovered materials. Per 2015 data, recycling e-waste costs anywhere between $450 and $1,000 per metric ton, whereas landfilling costs approximately $150 to $250 per metric ton. Although there is value in transitioning to a circular electronics economy, much improvement is needed to create efficiencies and improve the economics across the entire value chain.
Additionally, the environmental and social externalities from large mines or downstream waste streams are not included in the price of minerals or e-products, giving mining and e-waste landfilling an artificial advantage over recycling or reuse. Recycling and other life-extension options (e.g., reuse and repurposing) are not generally profitable today because they compete against new mines and new products that do not fully capture their environmental and social impacts.
Regulations vary across countries, and the consistency, availability, transparency, and reliability of data in end-of-life management make tracking and verification problematic overall. However, the collection or recycling of just 17.4% of the approximately 54 million metric tons of e-waste generated worldwide every year was documented in 2019. This means almost 83% of global e-waste flows fall outside formal tracking systems (Figure 5), destined instead for unregulated dumping and burning, trading, or illicit, unsustainable recycling. In North America, Central America, South America, and the Caribbean, that figure drops to 9.4%.
While statistics differ substantially across and even within geographies due to different tracking, classification, and reporting structures, according to data from the U.S. Environmental Protection Agency (EPA), the recycling rate for selected consumer electronics in the U.S. was 38.5% in 2018, with the remainder disposed of in landfills and incinerators. However, this figure only accounts for a subset of consumer electronics, and thus the actual recycling rate for all varieties of e-waste is unknown. Further, when e-waste in the U.S. reaches a state-approved collection agency, its fate is not easily traced and actual statistics are difficult to ascertain. In addition, a significant but unquantified portion of the e-waste collected for recycling is actually exported to places where it is often informally recycled, with negative impacts on workers, local communities, and the environment. Consequently, current e-waste management practices in the U.S. result in the loss of recoverable resources as well as significant social and environmental degradation abroad.
Figure 5 — Fate of Electronic Waste Worldwide, 2019 (million metric tons)
Past data has illustrated that developed countries export e-waste to developing economies, such as countries in Asia and Africa, where the recycling rate of e-waste is 11.7% and 0.9%, respectively. This shifts the waste management burden to developing economies — a direct contravention of the Basel Convention, an international treaty on the transboundary movement of wastes. However, the revenue from the trade in e-waste and its potential value acts as an economic incentive for underdeveloped countries to import and process it, despite a lack of health, safety, and environmental regulations or permitted infrastructure. Consequently, despite the known health effects and ecosystem disturbances, informal and uncertified e-waste dumping with some recycling is highly profitable and a sole source of income in many low- to middle-income countries. 
While recycling remains an important mechanism for placing materials back into the supply chain and recovering lost value, recycling alone will not solve the world’s e-waste problem. A singular focus on recycling and landfill diversion turns attention away from source reduction, reuse, reengineering, designing out waste, and other circular pathways. From a material design perspective, electronics and electrical equipment are very complex; they contain up to 69 elements from the periodic table, including precious metals, critical raw materials, and noncritical metals. However, within the paradigm of a circular economy, the mining of e-waste could be considered an important source of secondary raw materials. The challenges associated with primary mining, market price fluctuations, material scarcity, availability, and access to resources make it necessary to improve the mining of secondary resources and reduce the pressure on virgin materials, thereby mitigating their material demand in a secure and sustainable way. It should also not be assumed that recycling is profitable on its own merits without interventions (e.g., recycled content mandates, extended producer responsibility, advanced recycling fees, and landfill bans). Policy interventions play an important role in helping level the end-of-use playing field.
The Illegal Shipment of Waste Is a Serious and Growing Crime Globally
E-waste was one of the top three waste categories illicitly traded during 2018-2020. The illicit waste trade embodies many forms and includes waste that is undocumented and uncontrolled; a mixture or combination of different types of waste or materials; transported on the black market; hazardous waste that is undeclared or falsely declared as nonhazardous; or incorrectly classified as secondhand goods, new electronics, household goods, personal belongings, or another type of waste. It can also involve the falsification of functionality tests.
E-waste is often falsely declared as secondhand goods. It is common for CRTs and computer monitors to be misleadingly declared as metal scrap, old batteries to be incorrectly described as plastic or mixed metal scrap, and used appliances and household goods to be loaded in used vehicles for export. Misclassification is a frequent occurrence. In the past year, there have been multiple fires at ports and on trains due to lithium batteries being embedded in equipment and incorrectly classified as a range of materials, from scrap metals to resin, instead of being declared as batteries.
Due to illicit trade, the role of the informal sector, and the export of waste to countries that lack formal systems to accurately verify receipt or classification or ensure final treatment and disposal, the available statistics fail to capture the extent of the e-waste issue. In most countries, the organizational, regulatory, financial, and technical capacities needed for e-waste management and infrastructure are not yet fully established or, in some instances, are entirely absent. In high-income countries, meanwhile, e-waste may not undergo the specific treatment phases required, or it may be exported to low- and middle-income countries through illegal trade routes. Both instances result in lower resource and environmental efficiencies and social inequities.
Some research suggests that the export of e-waste from developed to developing economies is not the dominant pattern of trade. Indeed, waste data illustrates that between 2010-2021, the 146.6 million metric tons pf waste exported from the U.S. to China, an upper-middle-income country, represented the largest global trade flow (Figure 6). In 2021, the largest flow — 5.5 million metric tons — ran from the U.S. to Mexico, another upper-middle-income country. However, a lack of data transparency and efficient tracking mechanisms obscures a more complex picture; the available waste data fails to account for the multiple times waste may be transferred and exchange hands after arriving at its initial country of receipt — called “port-hopping” — or the number of instances that waste shipments may be separated, reconsolidated, reclassified, or reexported.
Figure 6 — Global Waste Trade Flows, 2010-2021
Although accurate data on the volume of the illegal waste trade is not available — especially for e-waste, given discrepancies in its classification and definition, and thus tracking — a 2021 Financial Action Task Force report found that environmental crime is estimated to be among the most profitable crimes in the world, generating around $110 billion to $281 billion in criminal gains each year.
A 2022 INTERPOL report documented 27 pollution crime case studies, including one involving the import of 18 cargo containers containing end-of-life electronic equipment from developed countries into Zambia — a country that lacks infrastructure for the recycling or disposal of e-scrap. The equipment had been classified and declared as “transit goods,” destined to be sold as secondhand electronic goods in the Democratic Republic of Congo. But the nonworking electronics were illegally dumped shortly after import.
Precise data on the amount of e-waste exported from the U.S. to developing countries being unavailable, estimates range extensively, from 8.5% to 10%-40% to 20%-80%. The latter estimate states that 80% of e-waste exported from the U.S. is received by Asian countries, with 90% of that amount directed to China. A United Nations (UN) Environment Programme study found that the vast majority of e-waste generated in developed countries is traded to developing countries through illegal trade routes, and a separate UN report determined that the majority of illegally traded e-waste ends up in landfills, incinerators, and ill-equipped recycling facilities. Since China’s National Sword Policy went into effect in 2018, waste exports have been rerouted to Africa and other developing economies, increasing their overall waste burden. Broadly, there is a lack of awareness and understanding of the seriousness of environmental crime, as it takes place in the context of a much broader chain of legal operations and through a complex web of trans-shipment ports.
Trade and the Inequitable Distribution of Value Recovery
The legal, responsible, and sustainable transboundary trade of e-waste is an integral component of the globalized processes through which metal commodities and other materials are produced and reproduced for global consumption. Indeed, the distribution of the value recovery across geographies depends on whether recycling is managed via local or global value chains.
The geographical inequity of circular trade flows is distributed highly unevenly across the world. In 2020, approximately 99% ($287 billion) of the total value of trade in materials, waste, scrap and residues, and secondary goods (e.g., secondhand goods such as postconsumer textiles intended for reuse or electronics intended for refurbishment) was traded between and within high- and middle-income countries (China, Europe, and the U.S. being the most prominent locations). Moreover, approximately 45% ($131 billion) of the total value of trade was exchanged solely between high-income countries. Conversely, trade to and from low-income countries only comprised approximately 1% ($4 billion) of the total value.
It should be noted that the lack of transparency and clarity on the extent of informal and illegal trade is not formally captured in trade databases and is thus a caveat to current trade statistics. Neither reflected in the findings are the shipments between high- to middle-income countries that are then reexported to low-income countries, through both legal and illegal channels. In the case of illegal trade, low-value waste tends to flow from high- and middle-income countries to low-income countries and can exacerbate environmental and social costs in the developing economies where waste burdens are transferred.
Striking a balance in an equitable transition to a circular economy comes with challenges. For instance, secondhand trade in the reuse and recycling markets, where high-income countries can undermine the quality of jobs of lower-income countries, is an illustrative example of how the circular economy transition can shift impacts across geographies. Current resource-trading practices are characterized by imbalances in power dynamics, through which global value chains source raw materials from lower-income countries for the manufacturing of higher-value products for wealthier consumers, only to export low-value waste and secondhand products back to lower-income countries. This practice is often promoted under the guise of charitable and circular reuse or recycling schemes, irrespective of the actual and final fate of the materials. In many cases, such as for solar panels and e-waste, the materials are either unsuitable for reuse and are abandoned, incinerated, or landfilled, or valuable components are retained for reprocessing in high-income countries. Parallels can therefore be drawn between the accrual of value creation from resource use in the Global North and the accumulation of environmental and social impacts from mining and e-waste importation in the Global South. This relationship creates a circular trade divide and exacerbates trade colonialism.
Several initiatives have emerged to help address the burden placed on governments in low-income countries to safely manage e-waste at the end of life. In one approach, developing countries conduct the initial collection, preprocessing, presorting, and less complex recycling while shipping difficult-to-recycle or hazardous items and components to advanced facilities in OECD countries. Meanwhile, developing countries improve their e-waste management systems. Despite the benefits of catalyzing circular e-waste flow, such models in developing economies could result in the loss of resources twice — first through mining and again through recycling abroad. Another limitation of the approach is that it requires increased international transportation of goods, which may offset efficiencies and environmental gains compared with maintaining activities at the local and regional levels. A better alternative would be to impose a fee on e-technology in the developed world to help fund collection and proper reuse and recycling in those countries, thereby reducing the transboundary shipping of e-waste to developing countries.
E-waste Management in the Informal Sector
Two billion people — more than 60% of the world’s employed population — earn their livelihoods in the informal sector, some of it involving waste collection and recycling. In low- and middle-income countries and regions with no developed waste management infrastructure and low recycling rates, including in Africa, Southeast Asia, and Central and South America, the large informal sector plays a key role in the recycling sector, including collection, recovery, sorting, grading, cleaning, bailing, and waste-compacting. In Latin America, up to 50% of all recycling is performed by the informal sector on average; in Brazil, the informal sector was responsible for 90% of the waste recovered for recycling from 2016-2017.
Some reports estimate that over 90% of the e-waste in these regions is handled by the informal sector. The work is labor-intensive and often handled under substandard conditions without personal safety protections, advanced processes, or regulatory oversight. Most of the workers involved in the informal sector are poor, unskilled, reside in slum areas, and have scarce employment opportunities, and a significant proportion tend to be rural migrants, disabled, elderly, or otherwise marginalized.
Notably, Sub-Saharan Africa is becoming a favored destination for e-waste. Not including illegal trade, e-waste imports to the region increased by 280% in value and 290% in weight between 2010 and 2020 (compared to the global average of 183% and 165% in value and weight, respectively). This raises concerns regarding the environmental and social risks associated with the lack of e-waste management in such parts of the world.
In general, there is a lack of awareness about the entire life cycle of the electronics value chain, particularly in mining and end-of-life operations but especially in the informal sector. To facilitate the recovery of valuable e-waste parts, consideration must be given to resolving the existing competition between the formal and informal sectors and foster their cooperation. Solutions should be compatible with environmental priorities, retain value, protect worker rights, and generate social and economic benefits for this informal, unrepresented economy.
E-waste Policies, Classification, Tracking, and Reporting: It’s Complicated ...
In the U.S., the classification of e-waste is ambiguous, since there is no federal law or overarching regulation that specifically defines e-waste or controls its collection, disposal, or export (except in the case of CRTs). The only federal legislation to date that explicitly regulates e-waste is the Resource Conservation and Recovery Act, which covers a very narrow subset of e-waste — namely the disposal of equipment containing CRTs. The broader categorization and management of e-waste hinges on the federal baseline definition of “waste.” There are, however, provisions under Subtitle C of RCRA, which regulates hazardous solid waste, regarding various types of e-waste — e.g., whole and shredded circuit boards and batteries. Plastics, if nonhazardous, are regulated under Subtitle D of RCRA, which regulates nonhazardous solid waste, but they are largely managed by state and local jurisdictions.
As a category, electronics are notorious for their rapid technological development and deployment, for their high consumption rate, and for being sold with artificially abbreviated lifespans, or intentional obsolescence. They are also known for their multiplex chemistries and composite materials and their intricate global transportation networks and logistics. These factors, among others, contribute to underdeveloped or inconsistent regulations, varied reporting practices, wide-ranging classifications, deficient or untraceable full-product recycling, and treatment markets that cannot keep pace with an ever-expanding market of technologies. (See Table 1, available for download in the sidebar.)
In order to establish baselines, enable benchmarking, evaluate progress and developments over time, and set and assess targets monitored by clear key performance indicators that can provide valuable lessons for the future, harmonized language and definitions across geographies and the ability to track quantities and flows are essential. Insights into e-waste types and quantities, how and where they are generated, and their intricate end-of-life journeys will provide a foundation for monitoring and controlling e-waste, and, ultimately, for preventing its illegal transportation and transboundary movement, disposal, and improper treatment.
The end-of-life supply chain for e-waste in the U.S. is complex. Used electronics are collected from consumers and businesses, evaluated for their value as working goods or materials, repaired and cleaned or recycled, managed as waste, and then resold in the U.S. or exported. These functions are performed by a diverse group of organizations, including waste generators, collectors, recyclers, original equipment manufacturers, retailers, brokers, traders, and professional service firms such as equipment leasing companies and information technology asset management firms. These products and actors form a complicated network likely to generate domestic sales, wastes, and exports at each step in the used electronics supply chain.
Classification and Management Policies and Systems
Defining Waste Under the U.S. Resource Conservation and Recovery Act
Together with its 1984 Hazardous and Solid Waste Amendment (HSWA), RCRA is the federal statute governing the “cradle-to-grave” management of solid and hazardous waste, from generation to transportation, treatment, storage, and disposal. The primary objective of RCRA is to protect human health and the environment while encouraging the conservation and recovery of valuable materials and energy resources. Generally, the statute applies to hazardous waste or solid waste that, among other things, is “abandoned,” “recycled,” or “disposed of.” According to RCRA’s statutory definition, “solid waste” is very broadly defined and is not contingent on the physical form of the material (i.e., whether a material is solid as opposed to a semisolid, liquid, or gas). Instead, it hinges on whether the material is discarded and designated as “waste.” Thus, solid waste by definition can include solids, sludges, liquids, semisolids, or contained gaseous materials.
The bedrock of the EPA’s regulatory program for solid waste, authorized under RCRA, is the agency’s foundational definition of “hazardous waste.” This definition is itself underpinned by RCRA’s statutory definition of “solid waste” — meaning any discarded material that is abandoned, inherently waste-like (e.g., dioxin-containing listed wastes), recycled (i.e., used, reused, or reclaimed), or meets the definition of waste military munition. RCRA’s statutory definition of “solid waste” and the EPA’s regulatory definition of “hazardous waste” do not always include materials intended for recycling, reclamation, or recovery. The EPA’s framework for determining whether a material is a solid waste depends not only on the characteristics (e.g., toxicity, corrosivity, or reactivity) of the material, but also on the manner and methodology by which the material is managed. For recycled materials, the RCRA jurisdiction is complex, and the history of legal decisions related to these definitions is extensive.
In order to be classified as a hazardous waste under RCRA, a material must first meet the EPA’s definition of a solid waste. If a waste is considered solid waste, the waste producer, i.e., the generator, is responsible for determining if it is hazardous waste (Figure 7). E-waste generators (e.g., handlers, installers, shippers, storage facilities, and manufacturers) are required to conduct a “hazardous waste determination” that establishes if the material exhibits the characteristic of toxicity under RCRA and, if so, determine its leachability through the EPA’s toxicity characteristic leaching procedure (TCLP). This step is important because although some used electronics may contain an “RCRA metal” (e.g., lead), they may be classified as solid waste instead of hazardous waste and sent to a municipal landfill for disposal (when allowed), since their toxicity is below the regulatory threshold of a hazardous waste classification.
Testing to determine if a material is deemed hazardous under federal law can cost anywhere from $700 to $1,500. A representative sample of each waste stream (e.g., a representative sample of a solar panel, unless a generator has the same model and it can apply for all units) must be tested. Because certified laboratory analytical testing is costly, many generators opt to accept a default hazardous waste classification using “generator or process knowledge” to avoid testing or the risk of fines.
A hazardous waste designation under RCRA subjects anyone who generates, stores, transports, or otherwise manages discarded e-waste, including companies that dispose of or recycle e-waste items, to the complex array of RCRA’s waste management framework, which is generally implemented by the EPA. It may also be implemented by states authorized by the EPA to operate hazardous waste programs, or, to varying degrees, by the Pipeline and Hazardous Materials Safety Administration (a Department of Transportation agency) or the Occupational Safety and Health Administration (a Department of Labor agency). All generators, transporters, owners, and operators of e-waste storage, treatment, and disposal facilities would be required to comply with permitting obligations; implement manifest systems to track cradle-to-grave activities; follow recordkeeping and reporting protocols; conduct training; comply with storage, accumulation, and transport requirements; and observe land disposal restrictions, among other responsibilities.
Figure 7 — The Environmental Protection Agency’s Hazardous Waste Identification Process
Even if a material meets the definition of solid waste, RCRA may still exclude it from regulation due to potential economic impacts, regulation through other laws, a lack of data, or the impracticability of regulating the waste. The EPA’s hierarchy of waste management (reuse, recycle, and disposal) aims to divert waste from landfills and incinerators, maximize recycling, and minimize waste via source reduction and reuse. The agency’s sustainable materials management strategy is intended to ensure that products are designed to be reused, repaired, or recycled back into the ecosystem or the marketplace.
Congruous with this preferential order of treatment, the EPA classifies used electronics determined to have reusable or recyclable components and intended to be “handled protectively” as “valuable commodities with significant economic value,” rather than waste — even though many electronics and electronic components that otherwise require classification as hazardous waste are either exempt or excluded from RCRA responsibility if destined for reuse or recycling. RCRA obligations can technically be triggered by electronics handlers or recyclers if, during the recycling or disassembly process, the recycler generates treatment residuals or separate wastes classifiable as hazardous. Although the recycling process itself is exempt from regulation, obligations under the RCRA can be activated if it produces a by-product that is a hazardous waste, since that by-product is considered to have been generated by the recycler. Liability under RCRA can be triggered, and the entire recycling operation placed in jeopardy, if a recycler relies on a conditional exclusion from solid waste to receive and process secondary material but fails to meet the conditions of the exclusion. The recycler then becomes liable for receiving hazardous waste and not obtaining a hazardous waste permit.
In the case of waste exports, RCRA does not have jurisdiction over U.S. recyclers or electronics brokers or make them liable if a used electronic device is exported as a “marketable commodity” as opposed to a “regulated waste.” As such, recyclers and brokers are not required to provide prior notification of shipment to the EPA or obtain consent from the receiving nation when the waste is classified as “marketable,” as would otherwise be required by RCRA’s import and export regulations. The lack of an official regulatory mechanism to track the export of e-waste (except in the case of CRTs and other RCRA-classified waste) inhibits the EPA from determining the actual quantity of e-waste exports or verifying whether or not electronics are being recycled.
The steps taken prior to disposal are crucial for determining how used electronics are classified, the mechanism used to track them, and where and how they are ultimately treated and disposed of. Subsequently, they determine the requirements under RCRA for proper handling and final disposal. Promoting reuse and recovery is certainly one of the goals of the RCRA; however, this goal should not take precedence over ensuring the proper management of hazardous waste resulting from reuse or recovery.
RCRA also generally exempts ”very small quantity generators,” which produce less than 220 pounds of hazardous waste per month, from its disposal requirements. This allows small businesses to dispose of used electronics in landfills, unless the waste is generated in one of the 19 states that have explicit landfill bans for certain products. In addition, wastes generated by individual consumers, households, and other residential facilities (such as bunkhouses, ranger stations, crew quarters, and campgrounds) are typically referred to as “household hazardous waste” and are excluded from the EPA’s definition of hazardous waste. The exclusion applies to the material no matter who handles it.
A single household that generates used electronics is not subject to the generator requirements; instead, the used electronics are regulated as solid waste at the state and local levels. Depending on the state’s regulations, this may permit disposal in municipal trash. However, the “household” exclusion becomes complicated for an electronics recycler that accepts used electronics from both households and businesses. Although households are excluded from hazardous waste regulations, businesses generally are not, even though their waste materials are identical. If the recycler cannot track which materials are generated from which entity, then they cannot easily claim the exemption.
State E-waste Laws in the U.S.
Today, there are e-waste laws in 25 U.S. states as well as Washington, D.C. The management of e-waste varies extensively within each of these jurisdictions. With the exception of California (which utilizes an advanced recovery fee) and Utah (which manages an e-waste recycling education program), their respective laws are based on the principles of extended producer responsibility (EPR), a market-based approach that mandates manufacturers to take primary financial and managerial responsibility of their products following consumer use. Generally, EPR policies require manufacturers of certain electronic devices to register with the state, pay an annual registration fee, and establish an e-waste recycling program in the state.
The divergence in provisions across jurisdictions related to scope, classification, labeling, registration, reporting requirements, recycling standards, collection targets, and landfill bans has led to a patchwork of varying e-waste laws. This results in a fragmented approach, rendering compliance burdensome and confusing for companies that operate in multiple or all states and making it challenging for recyclers to effectively design and operate recycling programs. With regard to e-waste classification, most state laws cover a relatively small product range that is limited to televisions, computers, and peripherals. This is in part to capture the highest-volume product categories, with several states having expanded their scope over time.
In California, the first state in the U.S. to pass electronics legislation, the Electronic Waste Recycling Act defines e-waste as any battery-embedded product, unwanted electronic device, or unwanted CRT, such as computer and television equipment, cell phones, and radios. E-waste is classified as universal waste, a category of hazardous waste with less stringent and streamlined handling and transportation regulations intended to reduce management burdens and facilitate collection and recycling. The law assesses a covered electronic waste recycling fee on retail sales of covered electronic devices; tasks the state with administering a payment system for collectors and recyclers to cover the average net costs of recovery and recycling; requires regulations for the proper management of discarded electronic devices; and establishes certain manufacturer responsibilities. (These include making consumer information accessible, brand labeling, annual reporting, adapting product design for recycling, and reducing the use of hazardous materials.) Manufacturers incur no financial responsibility, as the consumers fund the recycling program through retail fees. All entities are covered under the law, including businesses (large and small), governments, households and consumers, non-profits and charities, and schools.
Unlike California’s expansive range of covered electronics, the devices covered in Texas are limited to televisions and computer equipment (i.e, monitors, laptops, keyboards and mouses). Texas has two separate pieces of legislation that regulate e-waste: One requires computer equipment manufacturers to implement a take-back program for consumers (i.e., households), and the other mandates television equipment manufacturers to implement a recovery plan to collect, reuse, and recycle the equipment. There are no regulatory obligations for the computer equipment manufacturer to recycle, but television manufacturers are required to recycle their market share allocation based on sales within Texas. The legislation covers households and computers used for home-business use, which means that industry, local governments, businesses, schools, medical institutions, and other entities fall outside of the e-waste regulations.
While 25 states have fully adopted e-waste regulations, the remaining states still allow households and businesses to discard e-waste into regular trash. For those e-wastes exhibiting the characteristics of hazardous waste (e.g., that contain lead, mercury, cadmium, or chromium), management falls within the scope of RCRA, unless the e-wastes are exempt.
Global E-waste Policies
As of 2019, 29% of the global population did not live in a country with a national e-waste policy; fewer than half of all countries in the world — 78 of the 193 UN member states — currently have such a policy, law, or regulation in place. The existing legislation is inconsistent and covers only certain types of e-waste. Oftentimes, it lacks sufficient enforcement mechanisms to ensure e-waste is appropriately managed.
In contrast with the European Union (EU) and other countries, the U.S. currently has no federal law or strategy for e-waste management that requires collection, disposal, recycling, or reporting or that prohibits the export of e-waste to developing countries. The EU is at the forefront of e-waste management, with the highest documented formal e-waste collection and recycling rate (42.5%) in the world. This is largely due to its Waste Electrical and Electronic Equipment (WEEE) Directive, a legislative instrument originally issued in 2003 and updated in 2012 to reduce e-waste and encourage the recovery, reuse, and recycling of e-waste products. It regulates how products are managed at the end of their life cycle, utilizes a harmonized registration form and system, sets progressively increasing recovery and recycling targets for all categories of electronic equipment, and places the obligation of product collection and recovery on manufacturers. In addition, the government support for upstream collection of e-waste in Europe has led to the creation of a downstream private sector for electronics recycling.
The 2012 revision to the WEEE expanded its scope to include all products that are by definition electrical or electronic devices, including all components, subassemblies, and consumables that are part of the products at the time of disposal. Additionally, a new law requires that by the end of 2024, all mobile phones, tablets, and cameras sold in the EU, regardless of manufacturer, be equipped with a universal USB-C charging port. Starting in 2026, the obligation will extend to laptops. Regardless of manufacturer, all new electronics operating with a power delivery of up to 100 watts will have to meet this requirement.
Similarly, India has mandated that a USB-C charging port be included in all smartphones sold in the country starting in 2025. Some manufacturers, such as Apple, have expressed concern that a universal charger will stifle innovation. However, this could also allow new technologies — such as wireless charging — to emerge and mature.
Developing countries, such as in Southeast Asia and northern Africa, have very limited or no e-waste legislation. As such, country-specific standards and legislation, public awareness campaigns, effective implementation, and government incentives for developing cost-effective technologies to manage e-waste can play an important role in the circular economy. Other countries and regions around the world (e.g., Japan, South Korea, Switzerland, and Taiwan) have legislated and implemented electronic recycling systems. Meanwhile, e-waste legislation coverage has continued to increase, most notably in India, Latin America, and China.
China, once the largest recipient of e-waste imports from developed countries, was commonly regarded as a dumping site for e-waste. Since 2012, comprehensive rectification has been carried out in Guiyu, a town in the Guangdong province of China and a well-known hub for illegal e-waste recycling activities. In 2015, the Guiyu National Circular Economy Industrial Park was completed and all e-waste-disassembling activities outside the parks within the province were prohibited.
Additionally, imports of foreign solid wastes were banned in 2018 through the National Sword Policy, greatly disrupting the import of e-waste to China. The dominant source of e-waste recycled in China has gradually shifted from importation to domestic generation. In 2016, China overtook the U.S. to become the world’s largest e-waste producer. Thanks to the burgeoning amount of domestically generated e-waste, over 100 licensed and certified enterprises currently receive subsidies from the Chinese government to employ the best available recycling technologies, including formal dismantling processes and mechanical treatment methods with safety precautions.
Predominant Trade Policies Pertaining to E-waste
Globally, the definition and classification of hazardous waste and e-waste differ widely due to the existence of various national and international systems, standards, and directives. This causes gaps, overlaps, and disparities, resulting in inconsistencies, uncertainties regarding compliance, and misinterpretation by hazardous waste exporters and importers. Further, each exporter and importer is liable to understand, apply, and interpret the policies differently, resulting in irregularities that impede the aggregation and analysis of data.
The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal (the prevailing international treaty regulating the global trade in hazardous waste), the OECD, the EU, and the U.S. all have slight variations in their classification, definition, and scope of hazardous waste, waste, and e-waste. Due to the variance in legal definitions across countries, the same material may be classified as hazardous waste in one country but as a commodity, raw material, or nonhazardous waste in another. Consequently, the same substance or material will not be subject to systematic waste controls in all of the countries involved in its transboundary movement.
Most of the international community has managed the import and export of wastes through the Basel Convention. The convention was designed to regulate the transboundary movements of waste and to ensure environmentally sound management through notice and consent from receiving countries prior to export. Even with the convention in place, however, large amounts of e-waste continue to be shipped illegally.
Although the U.S. is the largest exporter of hazardous waste, it is the only developed country in the world that is not party to the Basel Convention. All of its major trading partners are signatories, however; therefore it is partially bound to the provisions of the convention by extension and limited to trade with countries with which it has a bilateral or multilateral agreement. Since the U.S. is not technically or directly legally obligated by the convention’s requirements, it can export hazardous waste indirectly without violating it, even in parts of the world that ban imports from nonmember states. This can be accomplished by engaging in trade using existing bilateral or multilateral trade agreements (e.g., the OECD Council Decision on the Control of Transboundary Movements of Wastes Destined for Recovery Operations, known as the OECD Council Decision) with countries that are party to the convention, who can then reexport directly or indirectly to other destinations that are restricted from direct trade with countries who are not parties to the convention, such as the United States.
The Basel Convention began addressing electronic waste in 2002, focusing on safe management and the prevention of illegal exportation to developing countries. In 2022, the Conference of the Parties to the Basel Convention, the treaty’s governing body, held its 15th meeting and adopted amendments to establish new definitions of hazardous and nonhazardous e-waste and ensure that the two categories will either be banned from trade or, at a minimum, require notification by the exporting country and consent by the importing country prior to export. Objections to these amendments prompted a process to work toward an alternative proposal on the control of transboundary e-waste movements under the OECD Council Decision prior to January 2025, when the amendments become effective.
The U.S. participates in a legally binding agreement with OECD member countries that governs the transboundary movements of waste for recovery purposes. The OECD Council Decision is a multilateral agreement that establishes procedural and substantive controls for the import and export of hazardous waste for recovery between the U.S. and other OECD member nations; it applies only to the transboundary movements of wastes destined for recovery operations within the OECD area. Wastes intended for disposal are subject to different legal controls, in particular those established by the Basel Convention and any applicable national laws. The OECD definition of “waste” is based on the “destination” of the material — i.e., whether or not the material is destined for disposal or recovery. The terms “disposal” and “recovery” are distinct and distinguished in the OECD Council Decision, whereas in the Basel Convention, the term “disposal” encompasses both disposal and recovery operations. Although intended to align the term’s practical applicability, this disparity further convolutes its working definition and complicates the understanding of final treatment and disposal.
Global Classification System for Trade
The lack of interoperability between definitions is exacerbated by the incomplete incorporation of different waste categories in the World Customs Organization’s Harmonized Commodity Description and Coding System, known as the Harmonized System (HS). This classification scheme assigns product codes used by customs authorities around the world to identify products when assessing duties and taxes. As an example, the six-digit HS codes used for international trade can inhibit border officials from differentiating between waste and used goods for reuse or secondary raw material recovery, since the codes do not completely align with the definitions of hazardous, nonhazardous, and other kinds of waste as outlined in the Basel Convention. In some cases, the same code could concurrently be applied to waste, scrap materials, and even primary resources.
This method of classification also prevents the assessment of imported goods based on their level of circularity — i.e., if they were produced via sustainable methods or if they are repairable or recyclable. A recent revision introduced a new grouping, “Electrical and electronic waste and scrap,” which will allow declared trade in different e-waste categories to be recorded and analyzed for the first time. Nonetheless, a globally interoperable system must be developed to better capture and communicate relevant information at national borders and facilitate circular trade flows.
The U.S. Harmonized Tariff Schedule (HTS) uses 10-digit codes based on the HS to classify and describe products for export, while the EU has created eight-digit codes. Yet, as these codes are applied unilaterally, their use risks further creating discrepancies in classifications around the world. Beginning in 2022, a series of updates went into effect for the HTS that provides more detailed categories for e-scrap shipments moving over international borders. Prior to the change, shredded printed circuit boards exported to overseas smelters were classified under a code which covers jewelry, valuable stones, and precious metals. The changes could eventually lead to a level of specificity for U.S. exports of key e-wastes and commodities that has been lacking in prior iterations.
With most global e-waste flows not formally documented, adequately monitored, measured, traced, or even collected at all, the fate of the large majority of e-waste is simply unknown. This can be explained, at least in part, by the fact that only 41 countries have official e-waste statistics. But even these are questionable due to the existence of various state, national, and international e-waste definitions, classifications, and categories; voluntary, unenforceable, and unharmonized reporting requirements; uncoordinated or nonexistent tracking documents and repositories; disparate regulations and laws; the absence of international trade data that distinguishes between new and used electronic commodities; and the role of illicit trade.
From an outside, non-practitioner’s perspective, the “cradle-to-grave” concept may seem simple and straightforward enough. But it quickly becomes evident just how obscure and complicated the tracking and end-of-life network is in practice, especially when global trade is factored in. In reality, the seemingly simple initial waste classification is not necessarily a determinant of, or consistent with, the actual and eventual destiny of e-waste as it traverses through global end-of-life supply chains. However, initial classification does determine, to some extent, how and if e-waste is tracked and reported and, to a lesser extent, the fate and treatment of e-waste (Figure 8).
Figure 8 — E-waste Classification and Various End-of-life Reporting Obligations
For instance, the federal universal waste regulations in the U.S. are intended to streamline hazardous waste management standards, minimize regulatory burdens, and facilitate recycling. But even if a material or product is classified as universal waste, recycling is not guaranteed. In fact, universal waste handlers are not required to recycle wastes and can instead opt for management in landfills or incinerators due to costs, logistics, and other factors. Moreover, the EPA has found that the regulated community is more willing to participate in collection programs if they are not required to determine, prior to initiating collection, whether the wastes can be recycled.
This initial universal waste classification also means that entities are not obligated to report to the EPA on what ultimately happens to the waste, unless it is exported by a large quantity generator (LQG). Likewise, e-waste classified as hazardous waste (e.g., CRTs) is oftentimes routed for recycling and, assuming it is generated from a LQG, will be reported in a required biennial report to the EPA and reflected in the agency’s Resource Conservation and Recovery Act Information System (RCRAInfo) database for cradle-to-grave tracking. Under RCRA, CRTs exported for recycling are exempt from solid or hazardous waste management and do not need to be included in the report for entry in RCRAInfo. Exported CRTs must be reported through the U.S. Customs and Border Protection (CBP)’s Automated Export System, but designation for recycling is not a guarantee that they will actually be recycled as intended, as many e-wastes intended for reuse or recycling are rerouted or mismanaged.
For nonhazardous waste tracking, there is some traceability for the interstate movement of municipal solid waste, although with far less detail and specificity than is required for hazardous waste tracking and reporting. In addition, states and territories with an EPA-authorized state-led RCRA program may have more stringent requirements than the federal baseline program, which means a waste may be classified as nonhazardous in one state and hazardous in another, thus activating different reporting structures and becoming captured in separate systems.
At the national level, the EPA uses a materials flow methodology, which relies on a mass balance approach. Using data from industrial associations, key businesses, and industry sources, as well as government sources such as the Department of Commerce and Census Bureau, the EPA estimates the tons of materials generated, recycled, composted, or sent to combustion facilities and landfills. The agency supplements this data with other sources, such as waste characterizations, state-level data, and export and import data extracted from the U.S. International Trade Commission online database.
Further, the repackaging, consolidation, and comingling of waste at transfer facilities or treatment, storage, and disposal facilities (TSDF) can interrupt the cradle-to-grave tracking system for e-wastes classified as nonhazardous or hazardous waste. Depending on the classification, the waste shipment will be accompanied by a unique shipping document called a Uniform Hazardous Waste Manifest. This document is required by the EPA and Department of Transportation for cradle-to-grave tracking of waste considered hazardous under RCRA, while a standard bill of lading is used for universal waste and, in some instances depending on the point of generation, for nonhazardous waste.
In the case of e-waste classified as hazardous, the generator initiates the manifest which, in theory, accompanies the hazardous waste throughout its transportation and disposal journey. When the waste is delivered to the facility designated on the manifest, the original manifest is returned to the generator with signatures of all the entities that have handled the waste (e.g., transporters and alternate TSDFs). The receiving facility signs the document, assigns management method codes, and returns the signed manifest back to the generator for verification of receipt.
Oftentimes, the TSDF listed on the manifest from the original shipper (who is considered the generator) is not the ultimate or final disposal facility, and the TSDF simply stores the waste until it is consolidated with waste from other waste generators, remanifested with a new document and tracking number, and transported to a second TSDF for further processing, treatment, or disposal. In these cases, the TSDF will assign an H141 code to the original manifest, which indicates the management method at the designated facility was storage/bulking or transfer. Without cross-referencing the new manifest with the original manifest tracking number, and without the benefit of receiving copies of all subsequent shipping documents, the original waste generator is deprived of the ability to track the actual fate of their waste from cradle-to-grave — despite having the ultimate legal liability for the hazardous waste from the point of generation to final disposal. With a new outbound manifest and tracking number, the second (or third or fourth) TSDF assumes the role as shipper (i.e, the generator), but the original generator maintains the cradle-to-grave liability under RCRA until the waste is processed at its final facility or facilities.
Exports of Hazardous Wastes
The EPA’s regulatory management of the export and import of hazardous waste, directed by the provisions of RCRA, has evolved into an elaborate and multifaceted suite of federal requirements. Exports of hazardous waste are handled or managed by several different parties, each having distinct requirements, and involve an electronic export notice, international movement document, and Uniform Hazardous Waste Manifest, unless the waste is exempted from manifesting (i.e., nonhazardous waste, waste intended for recycling, commodities, or universal waste).
If an export shipment from the U.S. is accepted by the importing country, the foreign receiving facility sends a copy of the signed international movement document to the U.S. exporter. U.S. exporters of manifested hazardous waste and universal waste, as well as all exporters of CRTs for recycling, are also required to file EPA-related information through the CBP’s Automated Export System. No later than one calendar year following the receipt of the waste, the foreign receiving facilities send a copy of the signed confirmation of recovery or disposal to the exporter and to the competent authority of the country of import after completing waste recovery or disposal. The exporter is required to file an annual report with the EPA summarizing the types, quantities, frequency, and ultimate destination of all such hazardous waste exported during the previous calendar year. Ports across the U.S. and around the world also collect information and report on the volumes and classification of materials that pass through. It is not clear what system each port uses, if and how each system is integrated, or if and how the data collected is used.
It is important to note that the receipt of waste by the initial importer does not constitute final disposal or recovery. In reality, the vast majority of used electronics exchange hands multiple times and are sold to a variety of brokers, traders, recyclers, handlers, and foreign processors both within and outside the U.S. This complicates the tracking and verification of actual end-of-life management for each of the components in a single e-waste product (which can include plastics, metals, glass, ceramics, etc.). Even whole e-wastes destined for direct disposal without dismantling or processing (e.g., incineration) may exchange hands multiple times and take a circuitous journey until their final disposal. When e-waste is dismantled and separated into various components, some parts may be classified as hazardous waste, some as commodities, and others as nonhazardous. Depending on the waste classification, each stream necessitates different tracking documents (or none at all) and is captured in different systems (or none at all). The streams are sold to different buyers, which means it is very difficult to cobble together and account for the entirety of an e-waste disposed of or recycled, since some components may actually be recycled and others landfilled (in both hazardous and nonhazardous landfills), incinerated, or exported.
Many e-waste generators use waste brokers — one-stop shops that provide full service for the end-of-life management of used electronics (including packaging, labeling, manifesting, collection, transportation, etc.). The broker collects and aggregates a variety of e-waste from multiple generators and transports them to a central location for sorting, storage, consolidation, macro disassembly, dismantling, and reshipment. Recoverable or usable parts and components are separated and segregated for reuse and resale to multiple vendors, both domestic and international. Materials requiring further dismantling, separation, shredding, crushing/baling, or processing are sent to recyclers, handlers, and other entities for additional “demanufacturing,” disassembly, and/or recycling. Throughout this highly multifaceted process, used electronics that were not initially classified as hazardous waste can technically become waste when the recycler or handler determines that the material cannot be used or reused for its intended purpose or demanufactured or recycled any further. At this point, assuming the waste is still within the U.S., certain obligations under RCRA are triggered (e.g., manifesting and reporting).
Since most types of e-waste are managed as nonhazardous waste (some e-wastes are considered universal waste in California), the vast majority falls outside the scope of RCRA obligations. As a result, e-waste is tracked with bills of lading that provide minimal information (an inventory of e-waste types and quantities and the shipment’s overall weight) and is subject to lax requirements for end-of-life tracking and disposal verification. Many brokers offer clients cradle-to-grave tracking documents and certificates of recycling or destruction that are “EPA-compliant” or “certified” by the International Organization for Standardization (ISO), but in the immense global recycling and waste network, actual end-of-life management with verification of qualified treatment does not exist in practical reality. It is currently not possible to determine what e-waste was actually recycled and how it was actually managed throughout the various stages of its journey — e.g., exactly what materials were recovered and where, their composition, what portions were landfilled or incinerated and where, what was exported, and the materials’ actual fate in the importing county.
With multiple reporting mechanisms at the state, national, and international levels — some obligatory and others voluntary — reporting is complicated and decentralized. As such, it represents an incomplete and fragmented picture of the e-waste flows within the U.S. and particularly around the world. This holds true even when attempting to collate all the pieces of the murky and mysterious end-of-life puzzle. A complicating factor is that reporting requirements are diametrically dissimilar for scrapyards, recyclers, TSDFs, and other parties involved in the end-of-life management of e-waste. Not only is each entity regulated differently, but the wastes and materials from electronics (plastics, glass, metals, etc.) are captured in standalone systems for tracking, trade, and reporting. In addition, inconsistencies in reporting invariably affect data quality and encumber effective, evidence-based policymaking, as well as the efficient management of ultimate e-waste disposition by generators.
Understanding the types and quantities of e-waste generated (especially considering urbanization and rapid population growth), how and where they are generated, and the types of entities that generate them can allow society and local, regional, and national governments to tailor management methods and plan for the future. This valuable knowledge would allow us to design effective systems and technologies, create a baseline measurement scheme, streamline transportation and logistics, set targets for waste minimization and circularity, track progress, and adapt to patterns of societal change. With accurate data, governments can realistically allocate land and budget for infrastructure, asses relevant technologies, and consider strategic partners, such as the private sector or nongovernmental organizations.
In 2021, only 45% of the 190 countries party to the Basel Convention — which do not include the U.S., meaning the country is not directly subject to the convention’s reporting obligations — submitted the national reports required by the treaty. In 2020, 61% of the parties provided national reports. The national reporting data from the signatories provides information to analyze flows and amounts of e-waste moving across borders. But it is insufficient for a comprehensive analysis because of consistently incomplete reporting by the parties and ambiguous definitions, incorrect categorization, discrepancies, and inaccuracies in their data. For example, the amounts of transboundary hazardous wastes included in the national reports may be imprecise, since notification documents describe the maximum expected amounts of hazardous wastes, not the actual weights shipped.
The United Nations Commodity Trade Statistics (UN Comtrade) database is considered the most comprehensive bank of trade data, capturing annual and monthly import and export statistics by product and trading partner from 1962 to present from close to 200 countries. However, it is known to have inaccuracies, since it relies on reports submitted by countries and they do not always report their trade statistics annually. The UN Comtrade database does not contain estimates of missing data; thus, a country’s trade could be understated due to the lack of available of data or incomplete reporting. In addition to missing data, imports reported by one country do not necessarily match exports reported by their trading partners due to differences in valuation and changing foreign exchange rates, varying policies on the inclusion and exclusion of particular commodities, timing, and other factors. Illegal trade is also, by definition, not captured in official government statistics, but it could be a significant contributor to trade flows. Various kinds of human error, such as using the wrong codes or incorrectly transposing them, also contribute to many of the inaccuracies.
The EPA collects information biennially regarding the generation, management, and final disposal of hazardous wastes regulated under RCRA. The biennial reports provide detailed data on the generation of hazardous waste from LQGs and on waste management practices from TSDFs. This data is reflected in the RCRAInfo database, the national program management and inventory system created by the EPA to enable cradle-to-grave waste tracking by handlers of wastes deemed hazardous under RCRA.
There are exceptions to what is actually reported in the system, however, which limits the full scope of the cradle-to-grave picture. Wastes that are not transported on a Uniform Hazardous Waste Manifest (i.e., e-waste classified as nonhazardous, universal wastes, commodities, and recyclable materials that are reclaimed to recover economically significant amounts of gold, silver, platinum, palladium, iridium, osmium, rhodium, and ruthenium) are not formally tracked and entered into RCRAInfo. Further, biennial reporting is only required for LQGs, meaning that all e-wastes from households, businesses, and other entities not deemed LQGs are omitted from the reporting database. Although record retention requirements may exist regarding off-site shipments for some of these generators, the data is not captured in a publicly accessible system.
Facilities that export hazardous waste must file a separate annual report with the EPA in the RCRAInfo Waste Import Export Tracking System (WIETS) that summarizes the type, quantity, frequency, and ultimate destination of all hazardous waste exported during the previous calendar year. However, the accuracy of the system is dependent on the ability of users to correctly classify their materials. U.S. exporters of manifested hazardous waste, universal waste, and CRTs for recycling are required to file in the CBP’s Automated Export System for each export shipment.
The effective management of e-waste will contribute critically to the goal of realizing sustainability, circularity, and resource efficiency. Ultimately, the aim is to continue advancing toward a circular economy and to close the loop so that products placed on the market are designed to 1) retain value and 2) return to the market as a new material or product through recovery, remanufacturing, refurbishing, and recycling processes.
However, successfully managing e-waste and the system in which it circulates will not only rely on the development and manufacture of products based on circular principles, but the robustness of coordination across value chains and the development of strong secondary markets for valuable recycled, recovered, remanufactured, or refurbished goods and materials. The circular economy cannot simply push recycled, refurbished, or remanufactured materials to end markets; end markets have to be able to pull materials through.
The recommendations presented herein are not inclusive or perfect solutions, rather options that can be considered as a means to begin transitioning to a circular electronics future. But they are presented in a priority ranking:
1. Strengthen the role of the U.S. government in managing the full life cycles of e-waste.
The EPA should establish national leadership in e-waste management across the life cycle by setting federal baseline standards from cradle to grave or cradle to cradle in a circular future. This would create consistency, harmonization, and a base level of regulation for all states.
In turn, this would encourage investment in the necessary infrastructure; enable enforcement and tracking mechanisms for life cycle management; allow for collection, recycling, recovery, and other kinds of post-use targets; and pave the way for the scale-up of circular economy business models, e.g., redesigning electronics with their end of life in mind. One of the key issues will be determining which supply chain entities (likely to be a combination of industry and government agencies) are responsible for ensuring the collection and delivery of e-waste to those facilities that can reuse, recycle, repurpose, etc. — or if those options are not available, determine how to divert e-waste to the appropriate permitted landfill.
With dedicated e-waste laws in 25 states, each differing in its definition, classification, and management of e-waste, the passage of perhaps weaker federal legislation could undermine the ability of states to enforce their programs. But it would also provide a consistent set of standards for businesses to follow in all 50 states. As such, it is important that future policies be flexible so as to address possible setbacks, share lessons learned, and promote an effective and practical path forward.
In the absence of national e-waste policies in the U.S., third party organizations such as Responsible Recycling (known as R2) and e-Stewards have helped bridge the gap between state and federal action by developing certification standards. However, since their standards are voluntary, they lack the capacity or jurisdiction to serve as a substitute for national legislation. Only a subset of entities across the e-waste value chain participate, leaving many businesses without clear guidelines. Although voluntary standards can be incorporated into national e-waste policy, they alone are not sufficient to transform the e-waste landscape in the United States.
It is critical that corporations and organizations across e-material supply chains be included in the discussions of new regulations. It will be crucial to understand the potential costs of e-waste collection, tracking, recycling, landfilling, and reuse when designing regulations.
2. Increase data transparency and standardize data collection, reporting, and tracking across life cycles.
The dearth of data and transparency on the types, generation rates, interstate movements, cross-border trade, and actual destinations and final fates of e-waste make it impossible to capture the full extent of the evolving e-waste crisis. It also detracts from our vision of sustainability and leaves societies unprepared for the demands of an equitable and just circular economy. Leveraging data allows for analysis and insights that can help us overcome systemic biases, identify gaps or inefficiencies in standards, and achieve better policy outcomes.
At the national and global levels, data on projected e-waste streams is necessary to make informed decisions and support the establishment of suitable regulatory conditions. Indeed, global action is always a challenge. But legislative and regulatory steps by the U.S. and EU and/or the OECD — preferably coordinated across these regions — can help build the basis for global negotiations. This can strengthen domestic upstream and downstream capabilities, stimulate investment and innovative financing schemes, and catalyze the development of local and regional end-of-use infrastructure that can help maximize the value creation of e-waste.
Considering the wide range of electronics both entering the market and nearing the end of life, there is an urgent need for the EPA to:
- Obtain clearer estimates on all types of electronics that will be migrating to the waste and second-life sectors over the coming decades.
- Understand how materials are classified and how classification affects fate and disposal.
- Demystify tracking and reporting across relevant agencies, geographies, and systems.
- Identify risks and vulnerabilities across life cycles to help minimize impacts and maximize value.
Standardized data collection, systematic reporting, and tracking mechanisms coordinated across governments and geographies can create transparency and accountability along the global value chain while also helping to verify final treatment methodologies and validate circularity claims. They can also ensure circular economy-relevant information is captured in cross-border trade in a way that is globally interoperable.
3. Develop a shared set of definitions and standards for post-use circular activities.
The recovery of resources from e-waste will require setting well-defined post-use definitions and standards for the reintroduction of products into the circular economy — i.e., through recovery, recycling, remanufacturing, repurposing, and refurbishing. Translating clear and consistent definitions in materials management into practical policies has been a major barrier to developing a shared understanding of, and subsequently a business case for, these second-life functions. Disparate and outdated definitions of recycling and other post-first-life processes result in imbalanced or ineffectively implemented policies. This makes it difficult to determine how to verify legitimate recycling, for instance, which has been a major hindrance to the circular agenda.
A unified understanding of terminologies and the standardization of data are key for ensuring improved e-waste management in the future. These can be achieved by adopting a harmonized set of definitions and standards for post-use materials.
The OECD is at the heart of international cooperation. By working with governments, organizations, policymakers, and stakeholders worldwide, the OECD helps establish evidence-based international guidelines and standards to find solutions to a range of social, economic, and environmental challenges. Through multi-stakeholder engagement, the organization could help shepherd the development and harmonization of key circular economy definitions, which could then be incorporated into country-specific policies. Mutually recognized definitions for post-use activities in the end-of-use value chain are essential for enabling efficient electronics management and will incentivize circular practices. Quality and safety standards for materials that are recycled, remanufactured, or refurbished, for example, are also needed to ensure they meet the necessary specifications for the markets they are entering.
4. Think in “systems” and design for life cycles.
To identify, quantify, and assess the social, environmental, and economic implications of electronics across their complex life cycles, it is important to integrate life cycle dimensions and a systems perspective into future policies. A systems-level mindset promotes ongoing innovation that encourages designing out waste, using waste as a resource, and coordination between the research and development (R&D) sector, manufacturers, and downstream materials management sectors to ensure products and materials placed on the market are capable of retaining value through circularity. Transforming how e-materials are managed across life cycles and evolving into a circular economy will only be sustainable if systems-level impacts along the entire value chain are appropriately considered. The expansion and standardization of science-based methodologies and tools, such as life cycle assessments, will allow for comparison across and within disciplines in a more systematic and consistent manner, thereby encouraging life cycle thinking.
5. Promote circularity through extended producer responsibility.
As a policy principle that builds on lessons learned, extended producer responsibility (EPR), when thoughtfully designed, promotes improved circularity by extending the responsibility of manufacturers to various post-consumer stages in the product life cycle, thereby unburdening municipalities. EPR can be applied in particular to the take-back, recycling, and final treatment or disposal of products, and can be exercised fully or partially and physically and/or economically.
An EPR policy is also characterized by the provision of incentives for producers to consider, ideally, environmental, social, and economic implications when designing their products. Thus, EPR seeks to integrate aspects of sustainability throughout the product chain, in addition to seeking life cycle extension as a pathway. “Right to repair” laws — which require original equipment manufacturers to make diagnostic and repair information for digital electronic parts and equipment available to independent repair providers and consumers — are a means to extend the useful life and value of a product. Similarly, EPR levers that require manufacturers to provide product information to consumers, such as products’ composition, hazards, practices of refurbishment, and life span, can shift consumer behaviors to assume circular responsibilities.
6. Pilot traceability for circular e-waste flows using blockchain or distributed ledger technologies.
Increased transparency and traceability must be supported by transformative digital and physical tracking technologies that provide energy-efficient, vigorous verification and certification records and real-time identification and tracking of products and components across their complete life cycles. Blockchain technology offers particular value in terms of enabling transparency and traceability in circular trade; it could ostensibly capture multi-material transactions and hazardous and nonhazardous classifications, which are typically managed in multiple systems across numerous jurisdictions. To improve tracking deficiencies, blockchain and distributed ledger technologies can necessitate and provide great impetus for a transparent, accountable, and more circular and sustainable management system for e-waste. A blockchain pilot working at the subnational or regional level would allow partners to aggregate sufficient materials and data across a controlled population and leverage existing infrastructure for collecting, sorting, dismantling, and recycling. In turn, this would help keep economic constraints, such as transportation and logistics costs, under control.
7. Transform the informal sector.
Despite various e-waste policies and measures in force around the world, numerous practices by both the formal and informal sectors are impacting the environment, the availability of natural resources, and the economy, with additional consequences for the safety of unorganized and unskilled labor. Policymakers should identify, assess, and implement best practices carried out globally, especially in developing nations, where a large percentage of e-waste is shipped for reuse, recycling, or disposal. In a global economy that relies on trade and the transboundary movement of wastes and commodities, the reality is that many materials invariably circulate through informal circuits. The top priority should be to facilitate the transition of workers and economic units from the informal economy to the formal economy, while respecting workers’ fundamental rights and ensuring opportunities for income security, livelihoods, and entrepreneurship in the process. The informal economy can be formalized in a variety of ways, including registration, taxation, organization and representation, legal frameworks, social protection, and business incentives and support. Interventions like these should be tailored to meet local circumstances.
There is not one overarching approach that will cut across the entire global e-waste value chain. Given the integrated nature of the existing e-waste system, singular solutions invested in without consideration of systems-level implications face a higher risk of failure. Policies and other actions will have to be tailored to regions of the world and take into account a range of socioeconomic and other factors. They will need to be coordinated throughout industries and sectors and across geographies. Proper solutions will likely combine fiscal instruments, government standards, voluntary measures, and regulation. Regardless of the configuration, it will require the underpinning of informed and balanced policies that keep pace with technologies across the entire product life cycle and account for impacts along the global value chain.
Even incremental actions that help lead toward a more transparent, integrated, and adaptable system will improve the overall effectiveness of used electronics management.
The author thanks Mathilde Saada, former research associate at the Baker Institute Center for Energy Studies, for her research support in the development of this report and the many external reviewers representing recyclers, academia, government, trade associations, and industry practitioners.
 PACE and the E-waste Coalition, A New Circular Vision for Electronics: Time for a Global Reboot (World Economic Forum, 2019); O.S. Shittu, I.D. Williams, and P.J. Shaw, “Global e-waste management: Can WEEE make a difference? A review of e-waste trends, legislation, contemporary issues and future challenges,” Waste Management 120 (2019), 549–563.
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 PACE, A New Circular Vision for Electronics.
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 Shittu, Williams, and Shaw, “Global e-waste Management.”
 This amount includes various end-of-life pathways of electronics generated in China and refurbished, reused, recycled, etc. In total, more than 70 million units of e-waste are dismantled annually (China Ministry of Ecology and Environment 2019).
 Forti et al., The Global E-waste Monitor 2020.
 S.A. Khan, “E‐products, E‐waste and the Basel Convention: Regulatory challenges and impossibilities of international environmental law,” Review of European, Comparative & International Environmental Law 25, no. 2 (2016), 248–260.
 Although batteries alone do not require electric currents or fields (they produce them), lithium ion batteries and batteries contained in equipment are covered under some e-waste policies, including the European Union Waste Electrical and Electronic Equipment (WEEE) Directive. Due to the integration of lithium ion batteries in a multitude of electronics, it is important to address battery management in conjunction with broader e-waste policies and practices.
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 The Democratic Republic of the Congo (DRC) and China were responsible for approximately 70% and 60% of global production of cobalt and rare earth elements, respectively, in 2019. For processing operations, the level of concentration is even higher, with a strong presence from China across the board. According to the International Energy Agency, China’s share of refining is around 35% for nickel, 50%-70% for lithium and cobalt, and nearly 90% for rare earth elements. Chinese companies have also made substantial investments in overseas assets in Australia, Chile, the DRC, and Indonesia.
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 Zetta translates to 10^21 (1E+21).
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 This applies in particular to hospitals (under the Health Insurance Portability and Accountability Act of 1996), businesses, universities, and government.
 Shittu, Williams, and Shaw, “Global e-waste management: Can WEEE make a difference?”
 X. Yuan, C.W. Su, and A.D. Peculea, “Dynamic linkage of the bitcoin market and energy consumption: An analysis across time,” Energy Strategy Reviews 44, 100976 (2022); “Fact Sheet: Climate and Energy Implications of Crypto-Assets in the United States,” White House, https://bit.ly/3BHtP0C.
 Yuan, Su, and Peculea, “Dynamic linkage of the bitcoin market and energy consumption.”
 OSTP, Climate and Energy Implications of Crypto-Assets in the United States (Washington D.C.: White House Office of Science and Technology Policy, 2022).
 OSTP, Climate and Energy Implications of Crypto-Assets in the United States.
 A. De Vries and C. Stoll, “Bitcoin's growing e-waste problem,” Resources, Conservation and Recycling 175 (2021), 105901. This assumes mining devices will become e-waste when they can no longer operate profitably.
 De Vries and Stoll, “Bitcoin's growing e-waste problem.”
 Precedence Research, Cryptocurrency Mining Market (Precedence Research), https://www.precedenceresearch.com/cryptocurrency-mining-market.
 Brand Essence, Cryptocurrency Mining Market (Brand Essence), https://brandessenceresearch.com/cryptocurrency/cryptocurrency-mining-market.
 N. Abhijith, E-waste Management Market (Allied Market Research, June 2021), https://www.alliedmarketresearch.com/e-waste-management-market.
 “Electronics,” Institute of Scrap Recycling Industries, Inc, https://www.isri.org/recycled-commodities/electronics.
 “UN report: Time to seize opportunity, tackle challenge of e-waste,” UN Environment Programme (press release), https://www.unep.org/news-and-stories/press-release/un-report-time-seize-opportunity-tackle-challenge-e-waste.
 For over two decades, China imported the vast majority of recyclables and waste from North America, Europe, and other developed nations. Due to concerns of environmental degradation, the Chinese Ministry of Ecology and Environment enacted the “National Sword” policy, which went into force in January 2018. The policy placed restrictions on the import of most plastics, wastes, and other materials. A total ban on imported waste went into effect on January 1, 2021.
 M. Shahabuddin et al., “A review of the recent development, challenges, and opportunities of electronic waste (e-waste), International Journal of Environmental Science and Technology (2022): 1–8, https://doi.org/10.1007/s13762-022-04274-w.
 A. Bazargan, K.F. Lam, and G. McKay, “Challenges and opportunities in e-waste management,” in E-Waste: Management, Types and Challenges, eds. Yuan Chun Li and Banci Lian Wang (Nova Science Publishers, 2012): 39–66.
 Shahabuddin et al., “A review of the recent development, challenges, and opportunities of electronic waste (e-waste).”
 E. Sahle-Demessie, J. Glaser, and T. Richardson, “Electronics waste management challenges and opportunities,” American Chemical Society, National Meeting 2018, Boston, MA.
 Bazargan, Lam, and McKay, “Challenges and opportunities in e-waste management.”
 Shahabuddin et al., “A review of the recent development, challenges, and opportunities of electronic waste.”
 V. Sahajwalla and V. Gaikwad, “The present and future of e-waste plastics recycling,” Current Opinion in Green and Sustainable Chemistry 13 (2018): 102–107; Shahabuddin et al., “A review of the recent development, challenges, and opportunities of electronic waste.”
 Z.H. Sun et al., “Toward sustainability for recovery of critical metals from electronic waste: The hydrochemistry processes,” ACS Sustainable Chemistry & Engineering 5, no. 1 (2017): 21–40.
 V. Forti, et al., The Global E-Waste Monitor 2020.
 L. Andeobu, S. Wibowo, and S. Grandhi, “An assessment of e-waste generation and environmental management of selected countries in Africa, Europe and North America: A systematic review,” Science of The Total Environment 792 (2021) 148078; V. Forti, et al., The Global E-Waste Monitor 2020.
 Baldé et al., Global Transboundary E-waste Flows Monitor – 2022.
 EPA, Electronic Products Generation and Recycling in the United States, 2013, 2014, Studies, Summary Tables, and Data Related to the Advancing Sustainable Materials Management Report (Washington, D.C.: EPA, December 2016), https://bit.ly/3BI9wjO.
 P. Thakur and S. Kumar, “Evaluation of e-waste status, management strategies, and legislations,” International Journal of Environmental Science and Technology 19, no. 7 (2022): 6957–6966; L. Andeobu, S. Wibowo, and S. Grandhi, “An assessment of e-waste generation and environmental management of selected countries in Africa, Europe and North America: A systematic review,” Science of The Total Environment 792 (2021), 148078.
 K.A. Schumacher, L. Agbemabiese, “E-waste legislation in the US: An analysis of the disparate design and resulting influence on collection rates across States,” Journal of Environmental Planning and Management 64, no. 6 (2021): 1067–1088.
 Ian Tiseo, “E-waste Collection and recycling rates worldwide by region,” Statista, February 6, 2023, https://bit.ly/41RcgWG; V. Forti, et al., The Global E-Waste Monitor 2020; UN Environment, Global Environment Outlook 6 (United Nations Environment Programme, 2019), https://www.unenvironment.org/resources/global-environment-outlook-6; A.K.H. Priyashantha, N. Pratheesh, and P. Pretheeba, “E-waste scenario in South-Asia: an emerging risk to environment and public health,” Environmental Analysis Health and Toxicology 37, no. 3 (Sept 2022), https://doi.org/10.5620/eaht.2022022.
 The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal is an international treaty designed to reduce the movements of hazardous waste between nations, and specifically to prevent the transfer of hazardous waste from developed to less developed countries.
 Felix Preston, Johanna Lehne, and Laura Wellesley, An inclusive circular economy: priorities for developing countries (London: Energy, Environment and Resources Department, Chatham House, 2019); Michelle Heacock et al., “E-waste and harm to vulnerable populations: A growing global problem,” Environmental Health Perspectives 124, no. 5 (2016): 550–555; Venkatesha Murthy and Seeram Ramakrishna, “A Review on Global E-Waste Management: Urban Mining towards a Sustainable Future and Circular Economy,” Sustainability 14, no. 2 (2022): 647; Preston, Lehne, and Wellesley, An inclusive circular economy: priorities for developing countries.
 S. Van Den Brink et al., Strategic Risk Analysis, Project STRIKE Stronger Training and Increased Knowledge for Better Enforcement Against Waste and Mercury (2020).
 K. Omi, Current situation, analysis and observations on waste control at borders by Customs, World Customs Organization Research Paper No. 50 (2020), https://bit.ly/3BJ8aFs; Basel Action Network, The ‘Scam Recycling’ Continues: E-waste Exportation from the U.S. to Developing Countries, Update #2 (Seattle: Basel Action Network, 2018), https://bit.ly/3WiWaUi; Baldé et al., Global Transboundary E-waste Flows Monitor – 2022.
 Olusegun Odeyingbo, Innocent Nnorom, and Otmar Deubzer, Person in the Port Project: Assessing Import of Used Electrical and Electronic Equipment into Nigeria (Bonn: UNU-ViE SCYCLE and BCCC Africa, 2017).
 S. Abalansa et al., “Electronic waste, an environmental problem exported to developing countries: The GOOD, the BAD and the UGLY,” Sustainability 13, no. 9 (2021) 5302; United Nation Environment Programme (UNEP) (2019). UN Environment, Global Environment Outlook 6.
 For example, see J. Lepawsky, “The changing geography of global trade in electronic discards: time to rethink the e‐waste problem,” Geographical Journal 181, no. 2 (2015): 147–159.
 This amount represents 62 World Customs Organization Harmonized System codes for waste.
 Financial Action Task Force, Money Laundering from Environmental Crimes (Paris: Financial Action Task Force, 2021), https://www.fatf-gafi.org/media/fatf/documents/reports/Money-Laundering-from-Environmental-Crime.pdf.
 The U.S. used a mass balance method and price analysis of trade statistics. Baldé et al., Global Transboundary E-waste Flows Monitor – 2022.
 Marisa D. Pescatore, “The Environmental Impact of Technological Innovation: How U.S. Legislation Fails to Handle Electronic Waste's Rapid Growth,” Villanova Environmental Law Journal 32, no. 115 (2021).
 L. Andeobu, S. Wibowo, and S. Grandhi, “An assessment of e-waste generation and environmental management of selected countries in Africa, Europe and North America: A systematic review,” Science of the Total Environment 792 (2021) 148078; I.M.S.K. Ilankoon et al., “E-waste in the international context–A review of trade flows, regulations, hazards, waste management strategies and technologies for value recovery,” Waste Manage 82 (2018): 258–275.
 P. Thakur and S. Kumar, ”Evaluation of e-waste status, management strategies, and legislations,” International Journal of Environmental Science and Technology 19, no. 7 (2022): 6957–6966.
 UN Environment, Global Environment Outlook 6.
 I. Rucevska et al., Waste Crime - Waste Risks: Gaps in Meeting the Global Waste Challenge - A Rapid Response Assessment (Nairobi and Arendal: United Nations Environment Programme and GRID-Arendal, 2015), https://wedocs.unep.org/20.500.11822/9648.
 For over two decades, China imported the vast majority of recyclables and waste from North America, Europe and other developed nations. Due to concerns of environmental degradation, the Chinese Ministry of Ecology and Environment enacted the “National Sword” policy, which went into force on January 2018. The policy placed restrictions on the import of most plastics, wastes, and other materials. A total ban on imported waste went into effect on January 1, 2021.
 Odeyingbo, Nnorom, and Deubzer, Person in the Port Project.
 Portions of this section are extracted from MSCI, Transitioning to a Circular Economy: Opportunities for Growth and Societal Transformation, Thematic Insight (MSCI, 2023). The report was written by the author for MSCI using ongoing research conducted at Rice University’s Baker Institute for Public Policy.
 Khan, “E‐products, E‐waste and the Basel Convention.”
 China is the predominant middle-income country, with imports of secondary goods, materials and waste, scrap, and residues valued at $38 billion and exports valued at $12.7 billion in 2020.
 “Trade Flows,” Circulareconomy.earth, Chatham House, 2022.
 United Nations Environment Programme and International Resource Panel IRP, Sustainable Trade in Resources: Trade, Global Material Flows, Circularity, and Trade (Nairobi, United Nations Environment Programme, 2020), https://www.resourcepanel.org/reports/sustainable-trade-resources.
 GRID-Arendal, Circular economy on the African continent: Perspectives and potential (GRID-Arendal, 2021): 1–48.
 Meidl, Rachel A. 2022. Solar’s Bright Future Faces a Cloudy Reality: What About All the Waste? End-of-Life Solar Panels: Federally Classified Hazardous Waste. Baker Institute Report no. 01.12.22. Rice University’s Baker Institute for Public Policy, Houston, Texas.
 Chatham House. The Circular Economy in Latin America and the Caribbean: Opportunities for Building Resilience (London: Chatham House, 2019): 1-65.
 Barrie et al., The role of international trade.
 Referred to by a representative of Luxembourg at the February 13, 1989, meeting on the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal.
 Barrie et al., The role of international trade.
 Barrie et al., The role of international trade.
 International Labour Organization, Women and men in the informal economy: A statistical picture, 3rd edition (Geneva: Internationnal Labour Organization, 2018).
 Flávio de Miranda Ribeiro, From Informal to Providers: A São Paulo State perspective for waste pickers at Brazilian Solid Waste Policy (Sao Paulo State Environmental Agency, 2016): https://bit.ly/3MnoQHc.
 Baldé et al., Global Transboundary E-waste Flows Monitor – 2022.
 International Labour Organization, The informal economy of e-waste: The potential of cooperative enterprises in the management of e-waste, Sectoral Activities Department (SECTOR), Cooperatives Unit (COOP) (Geneva: International Labour Organization, 2014).
 Barrie et al., The role of international trade.
 Title 40, CFR, 261.4(a)(13) and (14). Processed scrap metal and shredded circuit boards that are recycled are specifically excluded from solid waste regulations and therefore are not subject to hazardous waste regulations.
 Meidl, Rachel A., Michelle Michot Foss, and Ju Li. 2022. A Call to Action for Recycling and Waste Management Across the Alternative Energy Supply Chains. Baker Institute Report no. 03.02.22. Rice University’s Baker Institute for Public Policy, Houston, Texas.
 42 U.S.C. § 6902(b); § 6902(a)(l), (a)(3)-(5).
 40 C.F.R. §§ 260.10, 261.2.
 42 U.S.C. § 6903(27).
 40 C.F.R. part 261.2.
 40 C.F.R. part 261.2.
 40 C.F.R. part 261.3.
 40 C.F.R. part 262.11.
 “SW-846 Test Method 1311: Toxicity Characteristic Leaching Procedure,” U.S. Environmental Protection Agency, last updated September 1, 2022, https://www.epa.gov/hw-sw846/sw-846-test-method-1311-toxicity-characteristic-leaching-procedure.
 40 C.F.R. § part 268.
 “Hazardous Waste Generator Regulatory Summary,” U.S. Environmental Protection Agency, last updated July 8, 2022, https://www.epa.gov/hwgenerators/hazardous-waste-generator-regulatory-summary#table/.
 Pescatore, “The Environmental Impact of Technological Innovation.”
 EPA, “Sustainable Materials Management: Non-Hazardous Materials and Waste Management Hierarchy,” https://www.epa.gov/smm/sustainable-materials-management-non-hazardous-materials-and-waste-management-hierarchy.
 EPA, “How Communities Have Defined Zero Waste,” October 26, 2022, https://www.epa.gov/transforming-waste-tool/how-communities-have-defined-zero-waste.
 “Regulatory Exclusions and Alternative Standards for the Recycling of Materials, Solid Wastes and Hazardous Wastes,” U.S. Environmental Protection Agency, https://www.epa.gov/hw/regulatory-exclusions-and-alternative-standards-recycling-materials-solid-wastes-and-hazardous.
 42 U.S.C. § 6938 (RCRA § 3017) and 40 C.F.R. part 262, subpart E, F, and H.
 40 C.F.R. § 261.5(f)(3). For hazardous waste (i.e., waste with the characteristics of reactivity, corrosivity, ignitability, or toxicity), RCRA regulations require that all storage, treatment, or disposal of at least 220 pounds (100 kilograms) per month be performed under permit from the EPA.
 40 C.F.R. § 261.4(b)(1)
 “Regulations, Resources, and Guidance on Recycling Equipment,” Texas Commission on Environmental Quality, https://www.tceq.texas.gov/assistance/industry/e-recycling/e-recycling-regs.html.
 “Map of States with Legislation,” Electronics Recycling Coordination Clearinghouse, https://www.ecycleclearinghouse.org/contentpage.aspx?pageid=10.
 Schumacher and Agbemabiese, “E-waste legislation in the US.”
 Majeti Narasimha Vara Prasad, Meththika Vithanage, and Anwesha Borthakur, eds., Handbook of Electronic Waste management: International Best Practices and Case Studies (Butterworth-Heinemann, 2019).
 Schumacher and Agbemabiese, “E-waste legislation in the US.”
 In 2022, A.B. 2440 and S.B. 1215 set up an extended producer responsibility program for loose batteries and added all battery-embedded products to the Electronic Waste Recycling Act of 2003.
 Although e-waste can be managed under more relaxed standards, it still contains hazardous materials and must therefore be shipped to a designated handler or recycler without being comingled and disposed of with other solid wastes.
 Electronic Waste Recycling Act of 2003 (S.B. 20, Sher, Chapter 526, Statutes of 2003); “Forms and Information Supporting Participation in the Covered Electronic Waste Recycling Program,” CalRecycle, https://calrecycle.ca.gov/electronics/formsandinfo/.
 Texas Administrative Code, Title 30 § 328.149.
 Texas Administrative Code, Title 30 § 328.149.
 Andeobu, Wibowo, and Grandhi, “An assessment of e-waste generation.”
 Baldé et al., Global Transboundary E-waste Flows Monitor – 2022.
 Baldé et al., Global Transboundary E-waste Flows Monitor – 2022.
 European Union, “Directive 2012/19/EU of the European Parliament and of the Council of 4 July 2012 on waste electrical and electronic equipment (WEEE),” Official Journal of the European Union.
 “Waste from Electrical and Electronic Equipment (WEEE),” Waste and Recycling, European Commission, https://environment.ec.europa.eu/topics/waste-and-recycling/waste-electrical-and-electronic-equipment-weee_en.
 Shahabuddin et al., “A review of the recent development, challenges, and opportunities of electronic waste.”
 Sun, Schnoor, and Zeng, “Decadal Journey of E-Waste Recycling.”
 Sun, Schnoor, and Zeng, “Decadal Journey of E-Waste Recycling.”
 “Parties to Basel Convention on Control of Transboundary Movements of Hazardous Wastes and their Disposal,” UN Environment Programme, accessed February 2023, www.basel.int/Countries/StatusofRatifications/PartiesSignatories/tabid/4499/Default.aspx#enote1.
 See generally Katie Campbell and Ken Christensen, “Where does America’s e-waste end up? GPS tracker tells all,” PBS News Hour, May 10, 2016, https://www.pbs.org/newshour/science/america-e-waste-gps-tracker-tells-all-earthfix. The article describes an electronic waste recycling sting using GPS tracking, which showed U.S. electronic waste ending up in foreign countries. The United Nations estimates that the U.S. exports between 10% and 40% of its electronic waste to other countries for recycling.
 This is based on UNComtrade data on 62 HS-6 categories of waste and scrap material.
 The U.S. participates in a legally binding agreement with OECD members governing transboundary movements of waste for recovery purposes.
 Where the signature is subject to ratification, acceptance, or approval, the signature does not establish consent to be bound. “What is the difference between signing, ratification and accession of UN treaties?,” DAG Hammarskjold Library, April 26, 2018, https://ask.un.org/faq/14594 notes different legal obligations for signatories and parties. See generally Elizabeth S. Pope, “The Shadowy World of Hazardous Waste Disposal: Why the Basel Convention’s Structure Undermines Its Substance,” South Carolina Journal of International Law & Business 13, no. 2 (2017): 305, 324, which notes the U.S. is one of the main exporters of hazardous waste.
 “Basel Convention E-waste Amendments,” Un Enviroment Programme, http://www.basel.int/Implementation/Ewaste/EwasteAmendments/Overview/tabid/9266/Default.aspx.
 OECD Decision C(2001)107/FINAL.
 OECD Decision C(2001)107/FINAL.
 See Section 3.1 of the OECD Decision.
 Barrie, Schröder, and Schneider-Petsinger, The role of international trade.
 Barrie, Schröder, and Schneider-Petsinger, The role of international trade.
 V. Forti, et al., The Global E-Waste Monitor 2020.
 Lepawsky, “The changing geography of global trade.”
 “Cradle-to-grave” refers to a generator of hazardous waste managing waste from the point of generation to transportation, treatment, storage and ultimate disposal, and beyond.
 40 C.F.R. Section 273.
 60 F.R. 25492, 2550, May 11, 1995, https://www.epa.gov/hw/frequent-questions-about-universal-waste#recycle.
 In any single month, a large quantity generator generates 1,000 kilograms (2,200 pounds or 1.1 tons) or more of RCRA hazardous waste. It may accumulate at any time 1 kg (2.2 pounds) of RCRA acute hazardous waste or more than 100 kg (220 pounds) of spill clean-up material contaminated with RCRA acute hazardous waste.
 “Methodology: EPA’s Facts and Figures on Materials, Waste and Recycling,” U.S. Enviromental Protection Agency, https://www.epa.gov/facts-and-figures-about-materials-waste-and-recycling/methodology-epas-facts-and-figures-materials.
 EPA management method codes are assigned by the TSDF to describe the type of hazardous waste management system used to treat, recover, or dispose of a hazardous waste.
 42 U.S.C. § 6938 (RCRA § 3017).
 40 C.F.R. part 262, Subparts E, F, and H. Subpart E establishes export requirements for manifested, Subtitle C “hazardous waste” and is applicable to all exports unless other explicit provisions apply. Subpart H applies to the transboundary movement of recoverable wastes between OECD member countries, colloquially known as the “OECD regulations” in the context of the EPA’s domestic regime.
 Title 40 C.F.R. Part 262, Subpart H.
 V. Forti, et al., The Global E-Waste Monitor 2020.
 RCRA § 3002 and 3004.
 RCRAInfo is the EPA’s comprehensive information system. It provides access to data and supports the Resource Conservation and Recovery Act (RCRA) of 1976 and the Hazardous and Solid Waste Amendments (HSWA) of 1984. RCRAInfo characterizes facility status, regulated activities, and compliance histories in addition to capturing detailed data on the generation of hazardous waste from large quantity generators and on waste management practices from treatment, storage, and disposal facilities.
 40 C.F.R. 262.83(g); 40 C.F.R. 262.87.