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E-Waste Export Policy

Scott Recycling's policy on exporting electronic waste and processed material outside the United States.

Status: Current as of 2026-04-14. Reviewed annually.

Policy Statement

Scott Recycling does not export e-waste to developing countries or any jurisdiction that lacks the regulatory framework to process it safely and responsibly.

All material collected, processed, or resold by Scott Recycling either:

  1. Is processed domestically at our facility or at a U.S.-based downstream processor, OR
  2. Is shipped to a certified downstream processor (R2, e-Stewards, ISO 14001, or equivalent) whose downstream chain-of-custody is documented and auditable, OR
  3. Is refurbished and resold through domestic marketplaces (eBay, Amazon, Walmart, direct customer sales) with the understanding that legitimate reuse is not "export" even if the end buyer is international

This policy exists because:

  • Irresponsible e-waste export dumps toxic materials on communities that lack protective regulation
  • Federal regulatory trajectory (including BAN Amendment ratification considerations and SERI's Responsible Recycling standard) is moving toward banning undocumented e-waste export
  • Customer expectations — institutional and government customers increasingly require documented domestic processing or certified downstream chains
  • Reputational risk — any single export-to-developing-country incident (even by a contractor downstream) can permanently damage the business's brand and its ability to pursue R2 certification

Scope

This policy covers:

  • Raw e-waste collected via customer pickups or drop-offs
  • Processed material streams (steel, aluminum, copper, circuit boards, plastics)
  • Refurbished electronics (laptops, desktops, phones, tablets, servers — for resale)
  • Harvested components (CPUs, RAM, GPUs, power supplies, hard drives)
  • Hazardous materials (CRTs, batteries, mercury lamps, PCB-containing equipment)
  • Data-bearing devices pre- and post-destruction

Regulatory Framework

Scott Recycling's export policy aligns with or exceeds:

Regulation / Standard What it requires Our compliance approach
US EPA (current) Export of CRTs for recycling requires prior notification; hazardous waste export follows RCRA Subpart H We do not export CRTs or RCRA-hazardous waste. Period.
Basel Convention International treaty restricting hazardous waste export. US is signatory but has not ratified the Ban Amendment. We operate as if the Ban Amendment were in force — no export to non-OECD countries of hazardous material.
BAN Amendment (not yet ratified by US) Would prohibit export of hazardous waste from OECD to non-OECD countries Prospective compliance — aligns with our current practice.
R2v3 Standard (SERI) Requires documented chain of custody through all downstream processors, preference for reuse, restrictions on focus materials export Policy basis for our downstream due diligence. Full R2 certification is pending — see R2 decision memo.
e-Stewards Standard (BAN) Prohibits export of focus materials to non-OECD countries We meet this standard.
State laws (varies) Some states have e-waste disposal bans; a few restrict export We comply with every state in our service area. North Carolina's e-waste disposal ban is the most relevant; we do not export NC material offshore.

Downstream Processor Requirements

Any downstream processor that receives material from Scott Recycling must:

  1. Be located in the United States — exceptions require case-by-case approval from Dan
  2. Provide proof of current certification — R2, e-Stewards, ISO 14001, NAID, or equivalent — renewed annually
  3. Document their own downstream chain — where does the material go after them?
  4. Permit audits — Scott Recycling or our certification body must be able to audit or inspect
  5. Maintain insurance — general liability, environmental, pollution legal liability
  6. Sign a downstream agreement that prohibits their onward export to non-OECD countries without prior written notification

Downstream processors that fail to meet these requirements are removed from our approved list.

Specific Material Stream Rules

CRT glass (lead-containing)

  • Never exported. Period. Shipped only to US-based CRT processors certified for leaded-glass handling.
  • Storage duration tracked via sr_ewaste_compliance module (10-month warning / 11-month critical / 12-month violation).

Batteries (Li-ion, NiMH, NiCd, lead-acid)

  • Shipped only to US-based battery recyclers with appropriate certifications.
  • Export restricted — even to Canada or Mexico.

Mercury-containing lamps

  • Shipped only to US universal waste handlers certified for mercury.

Circuit boards (precious metal recovery)

  • Shipped to US-based refiners only. International refining is common in this space but Scott Recycling does not participate — we use US refiners exclusively even at slightly lower recovery rates because the compliance and reputational risk of international routing is not worth the margin.

Scrap metal (clean — steel, aluminum, copper, brass)

  • Generally sold to commodity buyers who may ship internationally as part of the global commodity market. This is not e-waste export — it's commodity metal trading, and the material has been fully processed and separated before it leaves our facility.
  • We do not track where our clean aluminum ends up after it's sold to a scrap yard, because it's a commodity at that point.

Refurbished electronics (working, resold for reuse)

  • Sold on eBay, Amazon, Walmart, and website store. These marketplaces have international buyers.
  • A working, tested, refurbished laptop sold to a buyer in (say) Germany is legitimate international reuse, not export-as-disposal. R2v3 explicitly permits reuse export to countries that can use the equipment.
  • We do NOT ship non-working or defective devices internationally — defective material gets processed domestically regardless of buyer demand.

Components (CPUs, RAM, drives, etc.)

  • Sold via marketplaces same as refurbished electronics. Working components to international reuse buyers is legitimate.
  • Non-working components are domestically processed.

Hazardous / focus materials

  • Never exported under any circumstances. Always domestic certified processing.

Documentation Requirements

For audit purposes, Scott Recycling maintains:

  • Downstream processor files — certifications, insurance, audit records, contracts — per processor, reviewed annually
  • Material shipment records — what shipped, when, to whom, weight, disposal method — retained per sr_ewaste_compliance chain of custody
  • Customer destruction certificates — issued for data-bearing material with a full chain-of-custody record
  • Annual export activity report — for internal review and for any certification audit

These records are retained per our Record Retention Policy — destruction certificates are permanent, other records are 7 years.

Exceptions

In limited circumstances, material may be shipped internationally:

  • Refurbished electronics sold to OECD-country buyers via legitimate marketplaces — this is reuse, not disposal export. Requires no special approval but is tracked in sales data.
  • Manufacturer take-back programs — if a customer (e.g., Dell, HP, Lenovo) provides a take-back program that includes international processing under their own R2 downstream chain, Scott Recycling may route material through the manufacturer's program. Requires the manufacturer to document their chain of custody.
  • Research samples — very small quantities (single-device, non-commercial) for research or education purposes may be shipped internationally with Dan's express approval and documentation.

Each exception is documented in the shipment record with the justification.

Policy Changes

This policy is reviewed:

  • Annually by Dan
  • Triggered by any regulatory change (federal, state, Basel, BAN Amendment)
  • Triggered by any R2 certification audit (policy must align with R2v3 standard)
  • Triggered by any incident involving a downstream processor

Changes require Dan's approval. Material changes to export practice are documented in the policy history below.

Policy History

Date Change Approved by
2026-04-14 Initial policy documentation (was informal before this). Policy codifies existing practice. Dan

Enforcement

Any Scott Recycling employee who:

  • Arranges or authorizes export of material in violation of this policy
  • Fails to verify downstream processor certifications as required
  • Destroys or alters chain-of-custody records
  • Colludes with a downstream processor to circumvent this policy

...is subject to disciplinary action up to and including termination, per Disciplinary Procedures.

External parties (contractors, customers, downstream processors) who violate this policy are removed from Scott Recycling's approved lists and may be reported to regulators where applicable.