BAN’s analysis, based on trade data, shipping manifests, and GPS tracking between early 2023 and February 2025, suggests that these exports could be worth over $1 billion annually. Malaysia has been identified as the largest recipient of these shipments, though other countries like Indonesia, Thailand, and the Philippines are also involved.
The investigation names ten U.S. recycling brokers accused of facilitating these toxic exports. Alarmingly, eight of these companies hold R2V3 certifications—an industry standard for responsible material management. Several of the firms implicated in the trade are based in California, a state with some of the strictest e-waste regulations in the U.S. This raises concerns about the efficacy of certifications and the potential for even certified recyclers to engage in questionable practices.
Despite the presence of certification programs, the investigation reveals a significant gap in enforcement and oversight, enabling brokers to bypass regulations and engage in deceptive practices.
One of the most concerning findings of BAN’s report is the role that weak enforcement mechanisms and international regulatory loopholes have played in sustaining this trade. The Basel Convention, a treaty aimed at preventing the export of hazardous waste to developing countries, bans the import of e-waste into these regions. However, containers of e-waste traced by BAN have been found arriving in countries such as Malaysia, Indonesia, and the Philippines.
Often, these shipments end up in makeshift recycling operations, where workers dismantle electronics in unsafe conditions. In Malaysia, for instance, researchers observed workers burning wires and melting plastics in open-air facilities near palm plantations and waterways. This practice not only creates significant environmental damage but also exposes workers—often low-income and undocumented—to severe health risks.
BAN’s findings underscore the need for businesses, especially large corporations that rely on e-waste brokers, to ensure more rigorous oversight of their recycling partners. One such case involves Best Buy, a major U.S. retailer, whose e-waste was traced to questionable destinations abroad. This highlights the growing importance of transparency and accountability in corporate e-waste management. Businesses are urged to demand clear, verifiable tracking of their e-waste and ensure that their partners adhere to best practices in recycling.
Moreover, the report highlights the issue of government-linked waste streams, citing the example of GEM Iron and Metal Inc., which secured a contract with the U.S. Defense Logistics Agency to manage sensitive electronic waste. This raises concerns about how government-regulated waste may also be contributing to the global e-waste crisis if not properly managed.
With e-waste projections reaching 82 million tons by 2030, the global crisis is only expected to grow. BAN calls for an industry-wide shift towards improved tracking, third-party audits beyond standard certifications, and investment in domestic recycling infrastructure. While the focus is not on vilifying the entire recycling industry, there is a clear need for a more robust framework that restores trust and credibility in the process.
In the absence of federal action, the responsibility lies with businesses to implement ethical and transparent systems to ensure their waste does not contribute to global pollution. For the recycling industry to remain credible, it must move beyond voluntary standards and adopt strict accountability measures.
The troubling findings in BAN’s report serve as a wake-up call for businesses and public agencies that handle e-waste. The time for action is now—not only to prevent hazardous waste from reaching developing nations but to ensure that recycling practices are safe, sustainable, and transparent. As the scale of the e-waste crisis expands, the question facing companies is not whether to act, but how quickly they can establish ethical systems to manage their end-of-life electronics.
