Original Equipment Manufacturer (OEM) Environmental Compliance professionals know all too well that a successful e-waste channel audit six or even three months in the past, doesn’t mean that this channel will remain so. Why is that? Large recycler’s downstream vendors constantly have to make changes to keep their Operational Expenses (OPEX) down. Also, recycling standards in different countries are continually changing. For example in China, (e.g. China Sword), Tier 1 recyclers around the world are having to make hard and fast decisions about where they will send their waste inventory to stay in business. These changes are affecting once ethical and efficient e-waste processors.

To maintain quality in this dynamic environment, OEMs must rethink their audit strategy to mitigate brand exposure and legal liability. Therefore, more advanced OEMs may try implementing a basic tracking pilot. If the test was successful, they may reason that it will ALWAYS be. Is this a wise course? As mentioned above, the landscape is dynamic for recyclers and quality is volatile. With the advent of social media, OEM’s can’t afford to have their brand exposed due to an unscrupulous recycler (e.g. bad actor) shipping it’s e-waste to a developing country or to be exposed for illegally dumping it’s branded e-waste into a landfill. The fines can add up to the millions of dollars.

A viable solution is for environmental compliance professionals to enhance their auditing programs with a real-time tracking service. A tracking service can monitor e-waste flows 24/7 so they can sleep at night. This service can be used to audit the Bill Of Lading (BOL) process in real-time reducing the need for exhaustive paper trails. Solutions like the Green Tracking Service (GTS) will quantify all flows by accurately timestamping e-waste location activity and alerts. In addition GTS can provide detailed reports of flow activity that compliance professionals can present to auditors, officials and partners. This assurance is worth the investment. Think of it as an e-waste flow insurance policy. Although companies trust their downstream, verification can provide compliance professionals solid leverage when negotiating with potential new clients.

Trackers should be incorporated into audit, takeback and/or Extended Producer Responsibility (EPR) processes. But how often should trackers be sent downstream to be effective? This will be discussed in the next article.