One processor's take on Canada's export rules

[caption id="attachment_23512" align="aligncenter" width="1200"] Under the proposed regulations, Canadian companies seeking to export non-hazardous e-scrap have to obtain approval from the country that will receive the shipment. | Butekov Aleksei/Shutterstock[/caption] One of Canada’s largest electronics recycling companies, eCycle Solutions, says Canadian leaders’ plan to restrict e-scrap exports will complicate - but certainly not debilitate - shipments of circuit boards to smelters. Canada's environmental ministry recently announced it would change e-scrap export regulations to bring Canada's laws in line with changes to the Basel Convention, to which Canada is a party. The draft regulatory changes are now available for public comment.  In general, the updates will require parties to get prior approval from recipient countries before they can ship non-hazardous e-scrap.  Electronics recycling and reuse company eCycle Solutions, which has five facilities in four provinces, has mixed feelings about the changes to the Basel Convention. On the one hand, they'll add complexity to exports of scrap circuit boards to overseas smelters, by requiring that those shipments go through the prior-informed consent (PIC) process before they hit the water. That process, which requires extra paperwork and time, applies to printed circuit boards headed to Japan's JX Nippon Mining and Metals, which acquired e-Cycle Solutions last year.  Both Canada and Japan are members of the Organization for Economic Cooperation and Development (OECD), a grouping of countries with developed economies.  "We do have some concerns over the added cost and increase in resources that will be necessary for Prior Informed Consent (PIC), specifically for items such as circuit boards that will be sent for smelting from one OECD country to another," Lisa Thompson, director of compliance for eCycle Solutions, wrote in an email to E-Scrap News. On the other hand, the company likes changes to the Basel Convention restricting trade in lower-grade e-plastics. In recent years, eCycle Solutions has invested in e-plastics sorting systems.   "We do also recognize the positive impacts that the PIC process could potentially bring to other materials such as plastics (ie. Increased transparency, encouraging reliable domestic solutions and end-markets etc…)," Thompson wrote. 

Canada's proposed changes

Ghana and Switzerland first proposed the changes to the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and their Disposal in 2020. The changes expanded the applicability of the PIC procedure, through which governments of exporting companies must receive prior permission from the governments of importing countries (and all countries through which the shipment will transit).  The Basel Convention already required PIC for the trade of material that met the definition of hazardous waste because it contained toxic materials. It doesn't restrict cross-border shipment of electronics for reuse. Neither does it limit trade in clean scrap metals.  But then there is the category of e-scrap that is exported with the intention of recycling, not reuse, but that isn't necessarily considered "hazardous" based on its metals content. The Ghana/Swiss amendment, which was ultimately approved in June 2022, extended the PIC requirement to that category. The changes go into effect Jan. 1, 2025.  Advocates of the change said that, in practice, extensive testing is required to differentiate between the non-hazardous and hazardous e-scrap anyway, and even non-hazardous material has potential to cause environmental and health harm if mishandled - open burning of circuit boards, for example.  Environment and Climate Change Canada (ECCC) is proposing changes to the country's Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations (or XBR for short) to bring Canada in line with Basel.  "Hazardous waste and hazardous recyclable materials are harmful to the global environment and to human health. Canada is taking action to make sure that these materials, including e‑waste, are not sent to countries that do not want them, or that do not have the necessary infrastructure to deal with them in an environmentally sound manner," Steven Guilbeault, Minister of Environment and Climate Change, stated in a press release.  In 2019, the Basel Convention was amended to place the PIC requirements on the trade of mixed, lower-grade plastics, including e-plastics. Those changes went into effect on Jan. 1, 2021.

Processor impacts

In an interview, Scott Loughran, president and CEO of eCycle Solutions, said he's not sure how much the PIC requirement will affect eCycle Solutions' exports, but he noted that getting PIC responses can be more difficult from emerging market countries than established ones like Japan.  "Canada is quick about approving it, but it's waiting for a response from the receiving country that's just taking forever," Loughran said, noting that eCycle Solutions starts the application process in August for the following year's shipments.  For example, eCycle Solutions applied in August or September 2022 for exports to Malaysia in 2023, and the company didn't receive the permit until February 2023.  Loughran uses float-sink systems to sort and clean up e-plastics streams for export. As long as Canada enforces the rules requiring PIC for e-plastics exports, it should level the playing field by requiring other domestic recycling companies to also perform sorting on their e-plastics exported to countries such as Malaysia, he said.  Overall, Loughran said, the regulations won't force major changes, other than requiring a little more work for some shipments.  "This doesn't really have a huge impact on the way we're doing things already in Canada," he said.  Thompson and Loughran noted that Canadian authorities had previously floated the possibility of adding requirements for shipments of material between provinces. Those requirements aren't included in the latest regulatory draft.  "We are also pleased that electronic waste transported inter-provincially within Canada for the purpose of recycling will be excluded," Thompson wrote. "This ensures we maintain flexibility in leveraging our existing national network to uphold customer service levels and support the various provincial programs."

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