Scrap is not synonymous with waste

Columns - Editor’s Letter

The term ‘waste’ sometimes appears in regulations that affect the movement of recyclables around the globe.

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June 28, 2021

It’s a battle the recycling industry has been fighting for generations: recyclables are not waste, and recycling is not disposal.

Despite this, the term “waste” still crops up in regulations that affect the movement of recyclables around the globe.

An example is potential changes to the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal that could affect the movement of end-of-life electronics by expanding the scope of devices that are categorized as “waste” under the convention. The proposals will be considered by the Conference of the Parties, which is scheduled to meet July 19-30.

A proposal from Switzerland and Ghana seeks to control all materials, whether they’re hazardous or not. Speaking at a session during ISRI2021, the Institute of Scrap Recycling Industries (ISRI) annual convention, ISRI Vice President of Advocacy Adina Renee Adler said, if the proposal is accepted, “All of these electronics, no matter what their characteristics, would have to go through the prior informed consent procedure, which is an administrative burden to exporters as well as, frankly, to the governments that have to manage all of those requests.”

Panelists at the Brussels-based Bureau of International Recycling Non-Ferrous Division meeting at the association’s 2021 World Recycling Convention in early June also noted actions and attitudes in Malaysia and India that view increasingly valuable nonferrous scrap as “waste.”

“Recyclers manufacture commodity-grade materials that are used in the production of new products.”

Eric Tan, president of the Malaysia Non-Ferrous Metals Association, said nonferrous metals are essential to a “low- carbon future” involving electric vehicles, solar energy and increased digitalization and Malaysia can benefit by processing and melting scrap to produce those metals.

As ISRI notes, recycling and recyclers are essential to the global manufacturing supply chain. Recyclers manufacture commodity-grade materials that are used in the production of new products. Companies that export tested electronics for reuse and repair help developing countries bridge the digital divide.

Among the association’s 2021 advocacy agenda is promoting language in federal and state law and in international agreements that differentiates recyclables from waste and recycling from disposal. To that end, Adler said ISRI submitted comments to the Basel Convention Secretariat, arguing that if end-of-life electronics are interpreted as a waste and not a product, the achievement of a circular economy would be impaired and the opportunity to extend the life of products would be prevented.

As ISRI notes on its advocacy page, “Recycling is essential to the global circular economy but requires market access and the removal of artificial trade barriers.”

As global economies strive for more circularity in their supply chains, the perfect should not be allowed to become the enemy of the good when it comes to international regulations.