Transboundary shipment of waste electrical and ... - Basel Convention

| TEXTE | 22/2010 

Transboundary shipment of 

waste electrical and electronic 

equipment / electronic scrap – 

Optimization of material flows 

and control

| TEXTE | 22/2010 

ENVIRONMENTAL RESEARCH OF THE 

FEDERAL MINISTRY OF THE ENVIRONMENT, 

NATURE CONSERVATION AND NUCLEAR SAFETY 

Project No. (FKZ) 3708 93 300 

Report No. (UBA-FB) 001331/E 

Transboundary shipment of waste 

electrical and electronic equipment / 

electronic scrap – Optimization of 

material flows and control 

by 

Knut Sander 

Stephanie Schilling 

Ökopol GmbH, Hamburg 

On behalf of the Federal Environment Agency (Germany) 

UMWELTBUNDESAMT

This publication is only available online. It can be downloaded from 

http://www.umweltbundesamt.de/uba-infomedien/mysql_medien.php?anfrage=Kennummer&Suchwort=3933 

along with a English-language and a German-language summary and the 

complete version (in German). 

The contents of this publication do not necessarily 

reflect the official opinions. 

ISSN 1862-4804 

Publisher: Federal Environment Agency (Umweltbundesamt) 

P.O.B. 14 06 

06813 Dessau-Roßlau 

Germany 

Phone: +49-340-2103-0 

Fax: +49-340-2103 2285 

Email: info@umweltbundesamt.de 

Internet: http://www.umweltbundesamt.de 

Edited by: Section III 1.5 Municipal Waste Management, 

Hazardous Wastes, Focal Point to the Basel Convention 

Dr. Ulrich Smeddinck 

Dessau-Roßlau, April 2010

1. Report No. 

Report Cover Sheet 

UBA-FB 001331/E 

2 3 

4. Report Title: Transboundary shipment of waste electrical and electronic equipment/ electronic -scrap 

– Optimization of material flows and control 

5. Author(s), Name(s), First Name(s): 8. Report Date: 17.02.2010 

Sander, Knut; Schilling, Stephanie 9. Publication Date: 04/2010 

6. Performing Organisation (Name, Address) 

ÖKOPOL – Institute for Environmental Strategies GmbH, Nernstweg 32 - 34, 

D – 22765 Hamburg 

10. UFOPLAN-No. 3708 93 300 

11. No. of Pages: 133 (German version) 

7. Sponsoring Agency (Name, Address): 12. No. of References: 63 

Umweltbundesamt [German Federal Environment Agency], 13. No. of Tables, Diagrams: 32 

Wörlitzer Platz 1, 06844 Dessau 14. No. of Figures: 34 

15. Remarks 

16. Abstract: 

The report describes approaches, measures and regulation structures for the export of used electrical/electronic equipment and 

waste electrical/electronic equipment to non-EU countries. It aims at optimising the protection of the environment and resource 

flows. Emphasis is placed on exports via the Port of Hamburg. The export of the equipment types investigated in non-EU countries 

took place exclusively as used equipment. Notified waste exports of such equipment are not known. The German Foreign 

Trade Statistics embrace a part of the actual exports. However, statistics do not differentiate between used and new goods. The 

total quantity of the exports extrapolated within the framework of the investigation in 2008 lay between 93,000 t and 216,000 t. 

The specific value of the exports (€/kg) lies significantly below the value of the exports to EU Member States. The equipment 

originates from a multiplicity of sources (in all >4,000 sources), in part from private end users, in part from commercial sources 

and partially from the waste regime. Private collection and reloading points represent one of the most important pivotal points for 

the export of low-value equipment. In the countries of destination, the equipment encounters recovery and disposal structures, 

which are not suitable to ensure the protection of human health and the environment as well as the extensive recovery of resources. 

Through this, several hundred of kilos of precious metals and rare earths are lost from the economic cycle. The elaborated 

measures for the optimisation of material flows cover short-term measures (amendment of the WEEE Directive, export 

controls, information of the public, obligation of manufacturers and re-marketing firms, return logistics) as well as medium-term 

measures (modification of the foreign trade statistics, improvement of the situation in the countries of destination). 

17. Keywords: Waste shipment, export, e-waste, WEEE, EEE, Electronic scrap, used electrical/electronic equipment, port of 

Hamburg, controls, waste transports, third countries, Non-EU-countries, Basel Convention, external trade, statistics, recycling/recovery 

of raw materials, informal recovery/recycling, collection, customs, police, authorities, developing countries

Berichts-Kennblatt 

1. Berichtsnummer: 

UBA-FB 001331/E 

2. 3. 

4. Titel des Berichts: Optimierung der Steuerung und Kontrolle grenzüberschreitender Stoffströme 

bei Elektroaltgeräten/Elektroschrott 

5. Autor(en), Name(n), Vorname(n): 8. Abschlussdatum: 17.02.2010 

Sander, Knut; Schilling, Stephanie 9. Veröffentlichungsdatum: 04/ 2010 

6. Durchführende Institution (Name, Anschrift): 

ÖKOPOL – Institut für Ökologie und Politik GmbH, Nernstweg 32 - 34, 

22765 Hamburg 

10. UFOPLAN-Nr. 3708 93 300 

11. Seitenzahl: 112 

7. Fördernde Institution (Name, Anschrift): 12. Anz. Literaturangaben: 63 

Umweltbundesamt, Wörlitzer Platz 1, 06844 Dessau 13. Anz. Tabellen: 32 

15. Bemerkungen 

16.Kurzfassung 

14. Anz. Abbildungen: 34 

Der Bericht beschreibt Ansätze, Maßnahmen und Regelungsstrukturen zum Export von gebrauchten Elektro(nik)geräten 

und Elektro(nik)altgeräten in Nicht-EU-Staaten mit dem Ziel, den Schutz der Umwelt und der Ressourcen zu optimieren. 

Der Schwerpunkt wird dabei auf Exporte über den Hamburger Hafen gelegt. Der Export der untersuchten Gerätearten in 

Nicht-EU-Staaten erfolgt ausschließlich als Gebrauchtgeräte. Notifizierte Abfallexporte solcher Geräte sind nicht bekannt. 

Die deutsche Außenhandelsstatistik erfasst einen Teil der tatsächlichen Exporte und differenziert nicht zwischen Gebraucht- 

und Neuwaren. Die im Rahmen der Untersuchung hochgerechnete Gesamtmenge der Exporte lag 2008 zwischen 

93.000 t und 216.000 t. Der spezifische Wert der Exporte (€/kg) liegt signifikant unter dem Wert der Exporte in EU- 

Staaten. Die Geräte stammen aus einer Vielzahl unterschiedlicher Quellen (insgesamt >4.000), teilweise von privaten 

Endnutzern, teilweise aus gewerblichen Quellen und teilweise aus dem Abfallregime. Private Sammel- und Umschlagplätze 

stellen einen der wichtigsten Drehpunkte für den Export von geringwertigen Geräten dar. In den Empfängerstaaten 

treffen die Geräte auf Entsorgungsstrukturen, die nicht geeignet sind, den Schutz der menschlichen Gesundheit und der 

Umwelt sowie die weitgehende Wiedergewinnung von Ressourcen sicherzustellen. Hierdurch gehen mehrere hundert 

Kilo Edelmetalle bzw. Seltene Erden dem Wirtschaftskreislauf verloren. Die erarbeiteten Maßnahmen zur Optimierung 

der Stoffströme decken kurzfristige Bereiche (Novellierung der WEEE-Richtlinie, Exportkontrollen, Information der Öffentlichkeit, 

Verpflichtung von Herstellern und Re-Marketing-Firmen, Rücklogistik) ebenso ab, wie mittelfristige Maßnahmen 

(Änderung der Außenhandelsstatistiken, Verbesserung der Situation in den Empfängerstaaten). 

17. Schlagwörter: Abfallverbringung, Ausfuhr, Export, Elektro(nik)altgeräte, Elektro(nik)geräte, Elektroschrott, gebrauchte 

Elektro(nik)geräte, Hamburger Hafen, Kontrollen, Abfalltransport, Drittländer, Nicht-EU-Länder, Basler Übereinkommen, 

Außenhandel, Statistik, Rohstoffrückgewinnung, Informelle Verwertung, Sammlung, Zoll, Polizei, Behörden, Entwicklungsländer

Transboundary shipment of waste electrical and electronic equipment / electronic scrap 


UBA-FKZ 3708 93 300 1 Ökopol GmbH 

CONTENTS 

LIST OF TABLES ......................................................................................................................................................3 

LIST OF FIGURES.....................................................................................................................................................4 

LIST OF ABBREVIATIONS.......................................................................................................................................5 

1 INTRODUCTION .................................................................................................................................................7 

2 LEGAL FRAMEWORK FOR THE TRANSBOUNDARY SHIPMENT OF WASTE ............................................8 

2.1 BASEL CONVENTION AND OECD DECISION...........................................................................................10 

2.2 EC REGULATION ON SHIPMENTS OF WASTE........................................................................................11 

2.3 GERMAN WASTE SHIPMENT LAW............................................................................................................14 

2.4 WEEE DIRECTIVE AND GERMAN ELECTRICAL AND ELECTRONIC EQUIPMENT LAW......................16 

2.5 REVISED CORRESPONDENTS’ GUIDELINES NO 1 FOR SHIPMENTS OF WASTE ELECTRICAL AND 

ELECTRONIC EQUIPMENT....................................................................................................................18 

3 QUANTITATIVE ASPECTS OF EXPORT ..........................................................................................................19 

3.1 STATISTICAL SYSTEMS.............................................................................................................................19 

3.2 DATA FROM THE FEDERAL STATISTICAL OFFICE (DESTATIS) ...........................................................22 

3.2.1 Declared Quantities ...............................................................................................................................22 

3.2.2 Specific Prices .......................................................................................................................................22 

3.3 EXPORT DATA FROM HAMBURG PORT ..................................................................................................27 

3.3.1 Description of the Data ..........................................................................................................................27 

3.3.2 Method and System of Analysis ............................................................................................................29 

3.3.3 Results from the Data Query by Goods Code.......................................................................................30 

3.3.4 Search by Keywords..............................................................................................................................34 

3.3.5 Summary ...............................................................................................................................................36 

3.4 USED CARS.................................................................................................................................................37 

3.5 ANALYSIS OF THE GERMAN FEDERAL ATLAS DATA ............................................................................39 

3.6 IMPORT STATISTICS..................................................................................................................................40 

3.7 COMPARISON OF DECLARED QUANTITIES............................................................................................42 

3.8 SUMMARY ...................................................................................................................................................46 

4 SITUATION IN THE COUNTRIES OF DESTINATION.......................................................................................49 

4.1 APPROACH..................................................................................................................................................49 

4.2 NIGERIA.......................................................................................................................................................49 

4.2.1 Treatment Situation ...............................................................................................................................49 

4.2.2 Pricing Situation for the Sale of Equipment and Components ..............................................................50 

4.3 GHANA.........................................................................................................................................................51 

4.4 SOUTH AFRICA...........................................................................................................................................52 

4.5 INDIA ............................................................................................................................................................53 

4.6 PHILIPPINES................................................................................................................................................56 

4.7 VIETNAM......................................................................................................................................................57 

4.8 OTHER COUNTRIES...................................................................................................................................57 

4.9 SUMMARY ...................................................................................................................................................58 

5 PARTIES INVOLVED IN THE EXPORT CHAIN ................................................................................................61 

5.1 COLLECTION POINTS ................................................................................................................................61 

5.2 OTHER PARTIES INVOLVED .....................................................................................................................64 

6 ORIGIN OF THE EQUIPMENT ...........................................................................................................................66 

6.1 COLLECTION OF BULKY WASTE ..............................................................................................................66 

6.2 COLLECTION OF SCRAP METAL BY COMMERCIAL COLLECTORS .....................................................70 

6.3 PRINT MEDIA...............................................................................................................................................70 

6.4 FLEA MARKETS ..........................................................................................................................................71 

6.5 “CASCADING VALUES”...............................................................................................................................72 

6.6 RECYCLING YARDS, FIRST TREATMENT OPERATORS ........................................................................72 

6.7 RE-USE ORGANISATIONS .........................................................................................................................75 

6.8 WASTE TRANSPORTERS ..........................................................................................................................76




6.9 ONLINE AUCTIONS AND TRADE – EXAMPLE OF EBAY .........................................................................76 

6.10 RE-MARKETING COMPANIES....................................................................................................................79 

6.11 HAND-OVER TO RETAILERS – PRIVATE SECTOR..................................................................................80 

6.12 ECONOMIC ASPECTS ................................................................................................................................81 

6.13 SUMMARY ...................................................................................................................................................82 

7 EXPORT MONITORING......................................................................................................................................85 

7.1 HAMBURG ...................................................................................................................................................85 

7.1.1 Office for Urban Development and Environment...................................................................................85 

7.1.2 Police .....................................................................................................................................................86 

7.1.3 Customs.................................................................................................................................................87 

7.2 BREMEN ......................................................................................................................................................87 

7.2.1 Bremen Environment Office...................................................................................................................87 

7.2.2 Bremen Police .......................................................................................................................................87 

7.3 NORTH RHINE-WESTPHALIA - DISTRICT GOVERNMENT OF DÜSSELDORF......................................88 

7.4 FEDERAL OFFICE FOR THE TRANSPORT OF GOODS ..........................................................................89 

7.5 CRIMINAL POLICE OFFICES......................................................................................................................89 

8 RECOVERY OF RAW MATERIALS...................................................................................................................90 

8.1 EXPORTED RAW MATERIALS VOLUMES ................................................................................................90 

8.2 RECOVERY OF RAW MATERIALS.............................................................................................................92 

9 MEASURES/OPTIONS .......................................................................................................................................93 

9.1 STATISTICS AND DATA..............................................................................................................................93 

9.2 SOURCES OF EXPORTED EQUIPMENT...................................................................................................94 

9.3 LEGAL REGULATIONS AND CONTROLS..................................................................................................97 

9.4 WASTE TREATMENT STRUCTURES IN THE COUNTRIES OF DESTINATION......................................100 

9.5 SUMMARY OF THE PROPOSED MEASURES ..........................................................................................101 

10 SOURCES...........................................................................................................................................................105 

11 APPENDIX ..........................................................................................................................................................108 

11.1 ZAPP/ATLAS CRITERIA ..............................................................................................................................108 

11.2 SELECTED COUNTRIES OF DESTINATION .............................................................................................111 

11.3 ELEMENTS OF THE VARIANT CALCULATIONS.......................................................................................112




List of Tables 

Table 1: Overview of the scope of Regulation 1013/2006 on shipments of waste out of the EU.....................11 

Table 2: Waste classification according to Decision 2000/532/EC ..................................................................12 

Table 3: Export from Germany to select countries of destination (reference year 2007).................................22 

Table 4: Export data returned from the query by goods code in the ZAPP system for refrigerators and 

freezers..........................................................................................................................................33 

Table 5: Export data returned from the query by goods code in the ZAPP system for monitors (MT).............33 

Table 6: Export data returned from the query by goods code in the ZAPP system for televisions ..................34 

Table 7: Export quantities of the most quantitatively relevant goods returned from the query by keywords in the 

ZAPP and ATLAS-HH systems (reference year: 2008).................................................................35 

Table 81: Examples of exports of “other equipment” to Ghana and Nigeria ....................................................36 

Table 9: Export of used cars (ZAPP) ...............................................................................................................38 

Table 10: Export of used cars (ATLAS-HH) .....................................................................................................38 

Table 11: Analysis of the German federal ATLAS data (reference year 2008)................................................39 

Table 12: Total Nigerian imports of select product groups (reference year 2006) ...........................................41 

Table 13: Nigerian imports of select product groups from Germany (reference year 2006) ............................41 

Table 14: South African imports of select product groups from Germany (reference year 2006)....................42 

Table 15: Comparison of select ZAPP data with corresponding data from the Federal Statistical Office 

(reference year 2008)....................................................................................................................42 

Table 16: Comparison of import and export declarations for Nigeria based on the Nigerian import 

statistics and the German foreign trade statistic............................................................................43 

Table 17: Comparison of import and export data: Ghana (reference year 2006) ............................................44 

Table 18: Comparison of import and export data: South Africa (reference year 2006)....................................45 

Table 19: Comparison of import and export data: India (reference year 2006) ...............................................45 

Table 20: Comparison of import and export data: Philippines (reference year 2006)......................................46 

Table 21: Investigated goods groups...............................................................................................................46 

Table 22: Dismantling and recycling techniques in the informal sector ...........................................................54 

Table 23: Overview of property profiles of electrical and electronic equipment for export...............................60 

Table 24: Selected used equipment traded on ebay.de between 01.01.2009 and 27.03.2009 .......................77 

Table 25: Price distribution of selected used equipment traded on ebay.de....................................................79 

Table 26: Price structure for the acquisition of appliances in Germany (estimate) ..........................................82 

Table 27: Export relevance of different areas of origin ....................................................................................83 

Table 28: Variants of material flow calculations ...............................................................................................90 

Table 29: Overview of the proposed measures .............................................................................................102 

Table 30: Goods codes used in an evaluation of the database .....................................................................108 

Table 31: Variants of the exported appliance mix ..........................................................................................112 

Table 32: Material flows from the export of electrical and electronic equipment and WEEE .........................112




List of Figures 

Figure 1: Overview of regulations on shipment of waste .................................................................................13 

Figure 2: Duties according to AbfVerbrG and Regulation 1013/2006..............................................................15 

Figure 3: Communication channels in Hamburg ..............................................................................................16 

Figure 4: Information flow between customs and DESTATIS up until 31/06/2009 ..........................................20 

Figure 5: Information flow between customs and DESTATIS from 01/072009................................................21 

Figure 6: Specific prices of computers exported out of Germany by country of destination (€/kg) ..................23 

Figure 7: Specific prices of televisions exported out of Germany by country of destination (€/kg) ..................23 

Figure 8: Weight/price ratios of televisions and monitors exported out of Germany for various countries of 

destination .....................................................................................................................................24 

Figure 9: Specific prices of telephones exported out of Germany to other countries of destination (€/kg) ......25 

Figure 10: Access to mobile and fixed line networks in select countries .........................................................25 

Figure 11: Specific prices of refrigerators and freezers exported out of Germany to other countries of 

destination (€/kg)...........................................................................................................................26 

Figure 12: Specific prices of washing machines exported out of Germany to other countries of 

destination (€/kg)...........................................................................................................................26 

Figure 13: Goods declared as used goods in the respective IT system (reference: number of declarations) .30 

Figure 14: Goods declared as used goods in the respective IT system (reference: gross weight)..................31 

Figure 15: Distribution of declarations over various types of electrical/electronic equipment (reference year: 

2008) .............................................................................................................................................31 

Figure 16: Distribution of gross weight over various types of electrical/electronic equipment (reference year: 

2008) .............................................................................................................................................32 

Figure 17: Number of records relating to used cars, according to different value thresholds ..........................37 

Figure 18: Monitor exports >1 t out of the German federal states to the selected countries of destination .....40 

Figure 19: Variants of the exported mixture of equipment ...............................................................................48 

Figure 20: Prices for different types of electrical and electronic equipment in Lagos (good quality) ...............50 

Figure 21: Prices for different types of electrical and electronic equipment in Lagos (low quality) ..................50 

Figure 22: Prices of used components from electrical and electronic equipment in Lagos .............................51 

Figure 23: WEEE flow chart for select product groups in South Africa ............................................................53 

Figure 24: WEEE flow chart for select product groups in India........................................................................55 

Figure 25a to d: Collection points (trade) .........................................................................................................62 

Figure 26a to b: Collection points (no trade)....................................................................................................63 

Figure 27: Example of an Africa route..............................................................................................................65 

Figure 28: Type of bulky waste collection in Germany 2006............................................................................67 

Figure 29: Most used type of bulky waste collection in Germany 2006 ...........................................................67 

Figure 30a and b: WEEE volumes recorded separately by the city of Wuppertal............................................69 

Figure 31 a to f: Number of municipalities which have opted for the respective collection group....................74 

Figure 32: Price distribution of selected used equipment traded on ebay.de (1. 1. 2009 and 27. 3. 2009) .....78 

Figure 33: Range diagram of exported materials (figures in t for 2008)...........................................................91 

Figure 34: Range diagram of exported precious metals (figures in t for 2008) ................................................91




List of Abbreviations 

AbfVerbrG Abfallverbringungsgesetz – German Transboundary Shipment Law 

OJ Official Journal of the European Union 

ATLAS Automatisiertes Tarif- und Lokales Zoll-Abwicklungs-System – Automated Tariff and Local Customs 

Clearance System 

BAG Bundesamt für Güterverkehr – Federal Office for the Transport of Goods 

b2b Business to Business 

b2c Business to Consumer 

BE Belgium 

BGBl. Bundesgesetzblatt – Federal Law Gazette 

BKA Bundeskriminalamt – Federal Criminal Police Office 

BMF Bundesministerium der Finanzen – Federal Ministry of Finance 

BMU Bundesministerium für Umwelt, Naturschutz und Reaktorsicherheit – Federal Ministry for the 

Environment,Nature Conservation and Nuclear Safety 

BMZ Bundesministerium für wirtschaftliche Zusammenarbeit und Entwicklung – Federal Ministry for 

Economic Cooperation and Development 

BSU Behörde für Stadtentwicklung und Umwelt der Hansestadt Hamburg – Urban Development and 

Environment Authority for the Free and Hanseatic City of Hamburg 

CRT Cathodic Ray Tube 

DESTATIS Statistisches Bundesamt Deutschland – German Federal Statistical Office 

R/yr Residents per year 

WEEE Waste electrical and electronic equipment 

EFTA European Free Trade Association 

EC European Community 

ElektroG Elektro- und Elektronikgerätegesetz – Electrical and Electronic Equipment Act 

ES Electrical and electronic scrap, e-scrap 

EU European Union 

CFC Chlorofluorocarbon 

FKZ Forschungskennzeichen – Grant No. 

UEEE Used electrical and electronic equipment 

GüKG Güterkraftverkehrsgesetz – Road Haulage Law 

HH Hanseatic City of Hamburg 

HS Harmonized Goods Description and Coding System 

IMPEL - Implementation and Enforcement of Environmental Law Transfrontier Shipments of Waste – 

TFS European network of enforcement authorities on transborder shipments 

IT Information technology 

R&F Refrigerators and Freezers 

CN Combined Nomenclature 

LAGA Bund/Länder-Arbeitsgemeinschaft Abfall – Federal/State Working Group for the Handling of 

Waste 

LCD Liquid Cristal Display 

Ni Nickel 

NL Netherlands 

OECD Organisation for Economic Co-operation and Development 

OFD Oberfinanzdirektion - Regional Finance Office




List of Abbreviations (Continued) 

Pb Lead 

PC Personal computer 

PCB Polychlorinated biphenyls 

PCDD/F Polychlorinated dibenzodioxins and -furans 

Pd Palladium 

PI-IV, PM Pentium® I-IV, Pentium® M 

SITC Standard International Trade Classification 

TC Telecommunication 

TFT Thin Film Transistor 

TV Television 

UBA Umweltbundesamt – Federal Environment Agency 

CE Consumer electronics 

VKS Verband kommunale Abfallwirtschaft und Stadtreinigung – Association of municipal waste 

management and city cleaning 

VKU Verband kommunaler Unternehmen e. V. – Association of Local Utilities 

VVA Regulation (EC) No. 1013/2006 on shipments of waste 

WA Warenverzeichnis für die Außenhandelsstatistik – Goods Index for Foreign Trade Statistics 

WEEE Waste Electrical and Electronic Equipment 

ZAPP Zoll Ausfuhrüberwachung im Paperless Port




1 Introduction 

At present, significant quantities of used electrical and electronic equipment (hereafter referred 

to as UEEE) are being exported from Germany. Notified exports (i.e. those with consent by authorities) 

of waste electrical and electronic equipment (hereafter referred to as WEEE) to countries 

outside the European Union (EU) have not taken place in any appreciable volume in the 

past years. The condition and quality of the exported UEEE, however, give rise to the suspicion 

that a significant percentage of this equipment is not fully functional, or can only be used in the 

countries of destination as a source of spare parts, or has only a short remaining service life. 

In the countries of destination, the equipment enters into waste management structures far below 

the standard that the European Community considers necessary, for itself, as the minimum 

level of protection. The treatment of WEEE in these countries of destination thereby poses risks 

to human health and the environment. Furthermore, valuable resources are lost if, in the countries 

of destination, the WEEE is not fully collected, and if treatment methods that do not ensure 

optimal reclamation rates are applied for the WEEE that is collected. 

Concrete knowledge of the extent and exact routes of the export flow and the parties or chains 

of parties involved is, however, very limited. 

In light of this situation and with emphasis in this research project on the example of the Port of 

Hamburg 1 the export of UEEE and WEEE were quantified as completely as possible on an empirical 

basis, the qualities of the exported goods were recorded, and approaches, measures and 

regulatory structures were developed with the aim of optimizing environmental protection, human 

health and resources. 

The following terms are used in this report: 

• Country of destination: The country to which goods from Germany are exported (or from 

the reciprocal perspective: the country that imports goods from Germany), 

• Country of dispatch The country that exports the goods; in the scope of this report, this 

refers to Germany in most cases, 

• Used electrical and electronic equipment (UEEE): Used equipment that is subject to 

the product regime, 

• Spare parts: Parts that originate from equipment that is subject to the product regime 

(newly produced replacement parts are less relevant in the context of this study, but are 

also included under this term), 

• Waste electrical and electronic equipment (WEEE): Equipment that is subject to the 

waste regime according to the WEEE Directive or ElektroG, 

• Equipment components: Parts from waste electrical and electronic equipment (WEEE) 

(waste regime), 

• E-scrap (ES): Fractions from the processing of WEEE (waste regime). 

1 Furthermore, the situations in the ports of Bremen, Antwerp and Amsterdam were taken into account.




2 Legal Framework for the Transboundary 

Shipment of Waste 

There is a series of international and national regulatory instruments, recommendations, compliance 

guides and guidelines to be considered regarding the monitoring and control of shipment 

of waste to other countries. The following are of particular importance in conjunction with 

WEEE/UEEE: 

1. Basel Convention of 22 March1989 on the Control of Transboundary Movement of 

Hazardous Wastes and their Disposal [Basel Convention] 2 , 

2. OECD Council Decision C(2001)107/Final of the OECD Council concerning the revision 

of Decision C(92)39/Final on the Control of Transboundary Movement of Wastes 

Destined for Recovery Operations [OECD Council Decision] 3 , 

3. Regulation (EC) No. 1013/2006 on shipments of waste [EC Waste Shipment Regulation] 

4 , 

3a. Commission Regulation (EC) No. 1418/2007 concerning the export for recovery of 

certain waste listed in Annex III or IIIA to Regulation (EC) No. 1013/2006 of the European 

Parliament and of the Council to certain countries to which the OECD Decision 

on the control of transboundary movements of wastes does not apply [Commission 

Regulation (EC) No. 1418/2007] 5 , 

4. German Waste Shipment Law [Abfallverbringungsgesetz] 6 , 

5. Instruction for the cooperation of (German) customs offices and (German) environment 

authorities within the framework of the shipment of wastes [Customs Instruction] 

7 , 

6. Revised correspondents' guidelines No 1 - Shipments of Waste Electrical and Electronic 

Equipment (WEEE) [Correspondents' Guidelines No 1] 8 , 

2 Basel Convention of 22 March 1989 on the control of transboundary movements of hazardous wastes and their disposal (enacted in Bundesgesetzblatt 

BGBl. II 1994, p. 2703), amended by Decisions on 22 September 1995 and 27 February 1998 (BGBl. II 2002 p. 89), from 9 to 13 

December 2003 (BGBl. II, p. 1626) and from 25 to 29 October 2005 (BGBl. II 2005, p. 1122). 

3 OECD Council Decision C(2001)107/Final concerning the revision of Decision C(92)39/Final on the control of transboundary movements of 

wastes destined for recovery operations, last amended 26 October 2005 with Decision C(2005)141. 

4 Regulation (EC) No 1013/2006 of the European Parliament and of the Council of 14 June 2006 on shipments of waste, OJ L 190 of 12 July 

2006, p. 1, as amended. 

5 Commission Regulation (EC) No 1418/2007 of 29 November 2007 concerning the export for recovery of certain waste listed in Annex III or IIIA 

to Regulation (EC) No 1013/2006 of the European Parliament and of the Council to certain countries to which the OECD Decision on the control 

of transboundary movements of wastes does not apply, OJ L 316 from 04 December 2007, p. 6, as amended. 

6 Act on the monitoring and control of transboundary shipment of waste, Abfallverbringungsgesetz of 19 July 2007, BGBl. I p. 1462. 

7 Handlungsanleitung für die Zusammenarbeit der Zolldienststellen und Abfallbehörden im Rahmen der Ver¬bringung von Abfällen, 

http://laga-online.de/laganeu/images/stories/pdfdoc/veroeffentlichungen/Handlungsanleitung%20Zoll_02_2008.pdf 

8 REVISED CORRESPONDENTS' GUIDELINES No 1 on the Shipments of Waste Electrical and Electronic Equipment (WEEE), 

http://www.umweltdaten.de/abfallwirtschaft/gav/Correspondents_guidelines_No_1.pdf.




7. Correspondents' Guidelines No 4 - Classification of waste electrical and electronic 

equipment according to Annex IV part I note (c) of Regulation (EC) No 1013/2006 on 

shipments of waste [Correspondents' Guidelines No 4] 9 , 

8. Enforcement guidance for the shipment of waste of the Working Group of the German 

Federal States and the Federal Government on Waste [Enforcement guidance 

LAGA] 10 , 

9. Directive 2002/96/EC on Waste Electrical and Electronic Equipment [WEEE Directive] 

11 , 

10. Directive 2002/95/EC on the restriction of the use of certain hazardous substances in 

electrical and electronic equipment [RoHS Directive] 12 , 

11. German Electrical and Electronic Equipment Law [ElektroG] 13 , 

12. Recommendation providing for minimum criteria for environmental inspections in the 

Member States 2001/331/EC [Recommendation 2001/331/EC] 14 . 

The most important international bases are the Basel Convention and the OECD Council Decision. 

The Basel Convention is a global control system for transboundary shipment of hazardous 

waste. An export ban on hazardous wastes from OECD member countries to OECD nonmember 

economies was formally incorporated into the Convention with Decision III/1. However, 

due to a lack of ratification by a sufficient number of Parties to the Convention, this export prohibition 

has not yet entered into force internationally; yet it has been transposed by the EU. 

The OECD Council Decision is a controlling system for the import and export of wastes destined 

for recycling, in order to allow their tradability within the OECD member countries. 

9 CORRESPONDENTS' GUIDELINES No 4 on the Classification of waste electrical and electronic equipment and fly ash from coal-fired power 

plants according to Annex IV part I note (c) of Regulation (EC) No 1013/2006 on shipments of waste, 

http://www.umweltdaten.de/abfallwirtschaft/gav/Correspondents_guidelines_No_4.pdf 

10 Vollzugshilfe zur Abfallverbringung der Bund/Länder-Arbeitsgemeinschaft Abfall (Mitteilung 25), 

http://laga-online.de/laganeu/index.php?option=com_content&task=view&id=22&Itemid=35. 

11 Directive 2002/96/EC of the European Parliament and of the Council of 27/01/2003 on waste electrical and electronic equipment, OJ L 37 from 

13/02/2003, p. 24, as amended. 

12 Directive 2002/95/EC of the European Parliament and of the Council of 27/01/ 2003 on the restriction of the use of certain hazardous substances 

in electrical and electronic equipment, OJ L 37 from 13/02/2003, p. 19, as amended. 

13 Elektro- und Elektronikgerätegesetz (ElektroG) from 16/03/2005, BGBl. I p. 762. 

14 Recommendation providing for minimum criteria for environmental inspections in the Member States 2001/331/EC, 

http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2001:118:0041:0046:EN:PDF.




2.1 Basel Convention and OECD Decision 

The Basel Convention contains lists of wastes in two annexes (Annex VIII and Annex IX). The 

wastes listed in Annex VIII are hazardous wastes. 

One entry concerning waste electrical and electronic equipment in Annex VIII is A 1180 “Waste 

electrical and electronic assemblies or scrap containing components such as accumulators and 

other batteries included on list A, mercury-switches, glass from cathode-ray tubes and other activated 

glass and PCB capacitors, or contaminated with Annex I constituents (e.g., cadmium, 

mercury, lead, polychlorinated biphenyl) to an extent that they possess any of the characteristics 

contained in Annex III (note the related entry on list B B1110)” 15 . 

The wastes listed in Annex IX are not covered by the relevant article of the Basel Convention. 

One entry concerning waste electrical and electronic equipment in Annex IX is B1110: 

“Electrical and electronic assemblies: 

– Electronic assemblies consisting only of metals or alloys 

– Waste electrical and electronic assemblies or scrap (including printed circuit boards) not containing 

components such as accumulators and other batteries included on list A, mercuryswitches, 

glass from cathode ray tubes and other activated glass and PCB-capacitors, or not 

contaminated with Annex I constituents (e.g., cadmium, mercury, lead, polychlorinated biphenyl) 

or from which these have been removed, to an extent that they do not possess any of 

the characteristics contained in Annex III (note the related entry on list A A1180) 

– Electrical and electronic assemblies (including printed circuit boards, electronic components 

and wires) destined for direct reuse 16 , and not for recycling or final disposal 17 .” 

The wastes regulated in the OECD Decision are grouped into risk categories as two lists (Green 

and Amber). Green Listed wastes are not subject to any waste-law control, and are treated as 

goods. Amber List wastes are subject to a control procedure; they require notification (application) 

and the consent of the applicable authorities. Also required are legally binding contracts 

from the parties involved in the exporting of wastes, who have legal control of the wastes and 

the recycling plants [Wuttke, Baehr 2008]. 

These two waste lists of the Basel Convention have been integrated into the OECD lists in such 

a way that the “Green Procedure” applies to Annex IX and the “Amber Procedure" applies to the 

wastes listed in Annex VIII of the Basel Convention. 

15 The Amended Correspondents’ Guidelines also list a series of other possible categories of waste electrical and electronic equipment as defined 

in Regulation 1013/2006. 

16 “Reuse can include repair, refurbishment or upgrading, but not major reassembly.” 

17 “In some countries these materials destined for direct re-use are not considered wastes.”




2.2 EC Regulation on Shipments of Waste 

Regulation (EC) No. 1013/2006 on shipments of waste is the European transposition of the international 

body of regulations on shipments of waste. 

This Regulation implements the international obligations of the Basel Convention and of the 

OECD Decision, and includes the internationally agreed objective that wastes shall be disposed 

of in an environmentally sound manner. It also forbids the shipment of hazardous wastes in particular 

(see Annex V of the Regulation) from EU to non-OECD countries 18 . The Regulation includes 

the following waste lists: 

• Annex III for Green Listed wastes 19 , 

• Annex III A for mixtures of Green Listed wastes, 

• Annex IV for Amber Listed wastes, and 

• Annex V, which covers wastes subject to the export prohibition. 

• Annex IX is B1110 

Table 1 below provides an overview of the scope of Regulation 1013/2006 on shipments of 

waste out of the EU [Wuttke, Baehr 2008]. 

Table 1: Overview of the scope of Regulation 1013/2006 on shipments of waste out of the EU 20 

Transboundary Shipment Export out of the EU into countries 

to which the OECD Decision 

applies; Art. 18, 34, 35 and 38 

Wastes for recycling Annex III, III A Duty to notify within the EU: Art. 18; 

Art. 38 

Wastes for recycling Annex IV, IV A Permissible, notification in accordance 

with Art. 38 

Hazardous wastes for recycling according 

to Annex V 

Waste for disposal Prohibited, with exceptions22 , notification 

in accordance with Art. 35 

[Wuttke, Baehr 2008] 

Not applicable Prohibited 

Export out of the EU into countries 

to which the OECD Decision does 

not apply; Art. 18, 36 and 37 

Duty to notify within the EU: Art. 18; 

however individual case regulations 21 

according to Art. 37 

Not applicable 

Prohibited 

All Annexes comprise the corresponding lists/annexes of the Basel Convention and the OECD 

Decision, or of the EU-wide valid waste list according to Decision 2000/532/EC 23 . 

18 This ban is not yet in force worldwide. 

19 Annex IIIB can still be worked out in a committee procedure. This regards Green wastes not listed at the Basel/OECD level, but which can be 

shipped between EU Member States without notification. 

20 Articles or annexes specified in the Table are articles or annexes from Regulation 1013/2006. 

21 Individual case regulations as defined in Commission Regulation (EC) No 1418/2007, as amended. 

22 Export is only allowed in EFTA countries that are also Parties to the Basel Convention.




Annexes III and IV list out the wastes that may be exported according to the Green or Amber 

control procedure. Of relevance to hazardous WEEE is the entry A1180. The entry of relevance 

to WEEE in the Basel Convention List B (B1110) is not valid in EU law. OECD entries GC010 24 

and GC020 25 apply instead. 

Annex V additionally contains Waste List 2000/532/EC, which is valid throughout the EU only. 

The waste classifications in Decision 2000/532/EC relating to WEEE are listed in Table 2All Annexes 

comprise the corresponding lists/annexes of the Basel Convention and the OECD Decision, 

or of the EU-wide valid waste list according to Decision 2000/532/EC. 

A general prohibition of export to non-OECD countries applies to wastes listed in Annex V Part 

1 List A (inter alia A1180) and according to Annex V Part 2 (inter alia the wastes in Table 2). An 

explanation of this regulation is given in the Correspondents’ Guidelines No 4, which state, “that 

hazardous WEEE according to the European list of wastes […] should, for the purposes of 

Regulation (EC) No 1013/2006, be classified as hazardous WEEE by using the Basel entry 

A1180, unless another entry contained in Annex IV applies, and that hazardous WEEE cannot 

be classified appropriately as either GC010 or GC020.” 

Table 2: Waste classification according to Decision 2000/532/EC 

Waste key 

Plain text 

16 02 10* Discarded equipment containing or contaminated by PCBs or PCTs other than those mentioned in 

16 02 09 

16 02 11* Discarded equipment containing chlorofluorocarbons 

16 02 12* Discarded equipment containing free asbestos 

16 02 13* Discarded equipment containing hazardous components 26 other than those mentioned in 16 02 09 to 

16 02 12 

16 02 15* Hazardous components removed from discarded equipment 

20 01 21* Fluorescent tubes and other mercury-containing waste 

20 01 35* Discarded equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components27 

[Correspondent’s Guidelines No. 4] 

Differences from the Basel Convention exist in Annex III, IV and V of Regulation 1013/2006 with 

regard to WEEE. 

A simplified overview of the regulations of these three bodies of regulations is provided in Figure 

1 below. 

23 OJ L 226 from 6/9/2000, p. 3, as amended. 

24 Electrical assemblies consisting only of metals or alloys. 

25 Electronic scrap (e.g. printed circuit boards, electronic components, wire, etc.) and reclaimed electronic components suitable for base and 

precious metal recovery. 

26 “Hazardous components of electrical and electronic equipment include, e.g., accumulators and batteries listed under 16 06 and classified as 

hazardous, mercury-switches, glass from cathode ray tubes and other coated glass.” [Anlaufstellen-Leitlinien Nr. 4]. 

27 See previous footnote.




Effective geographical area 

172 parties OECD countries only EU 27 

Basel Convention 

Annex IX: List with 

non-hazardous wastes 

e. g. B1110 

Annex VIII: List with 

hazardous wastes, 

e. g. A1180 

Export ban 

65 ratifications (i. a. the 

EU). Not in force 

internationally. 

Part 1 

Part 2 

Part 3 

List A 

List B 

Waste 

lists 

are 

almost 

identical 

EC Waste Shipment Regulation – Annex V 

B1110 is not 

valid in the 

EU instead 

GC010 and 

GC020 

Characterised as non-hazardous 

Characterised as hazardous, 

e. g. 20 01 35* 

OECD-Council Decision 

Green waste list/ 

procedure 

Amber waste list/ 

procedure 

Figure 1: Overview of regulations on shipment of waste 

B1110 is not 

valid in the 

EU instead 

GC010 and 

GC020 

EC Shipments of 

Wastes Regulation 

Annex III: 

Green waste list/procedure 

Annex IV: 

Amber waste list/procedure 

Annex V: 

Export ban for hazardous wastes 

(acc. to the Basel Convention 

and the European List of Waste) 

Export ban in countries in which the OECD Council 

Decision does not apply 

Export into countries in which the OECD Council 

Decision does not apply is potentially permitted 

When exporting wastes of Annexes III and IIIA, i.e. non-hazardous wastes for recovery, to a 

country to which the OECD Decision does not apply, various control procedures according to 

Art. 37 of 1013/2006 apply. Which procedure is required for specific countries of destination and 

for specific types of waste is defined in Regulation (EC) 1418/2007. This defines, in tabular 

form, whether 

• “the export of wastes listed in Annex III to Regulation 1013/2006 to the respective country 

of destination is prohibited or 

• a waste may only be shipped to the respective country of destination with prior written notification 

and approval or 

• a waste may be shipped without notification under consideration of the general duties to 

notify of Art. 18 of Regulation 1013/2006”“ 28 [Wuttke, Baehr 2008]. 

28 The procedure according to Art. 37 par. 2 of 1013/2006 applies to unlisted countries of destination.




2.3 German Waste Shipment Law 

The German Waste Shipment Law (Abfallverbringungsgesetz AbfVerbrG) is the German transposition 

of Regulation (EC) No 1013/2006 and the Basel Convention, and supplements 

1013/2006 in numerous points. One such supplement that is also of particular importance to the 

export of WEEE is the allocation of authority responsibilities. Generally, according to Section 14 

par. 1, the federal state authorities of the state in which the waste shipment begins or should 

begin are responsible for measures and duties relating to shipments of wastes out of Germany. 

Also authorized to conduct inspections according to Section 14 par. 2 are the federal state authorities 

in whose territory the wastes destined for shipment out of Germany are located, as well 

as certain federal authorities. 

According to Section 11 par. 2 of AbfVerbrG, the Federal Office for the Transport of Goods and 

the customs offices shall cooperate with the responsible authorities “to the best of their ability” in 

the inspection of waste shipments. According to state laws, the duty to inspect can also reside 

with parties other than the authorities responsible for the waste shipment, such as the water police, 

for example [Kropp 2008, Deutscher Bundestag 2006] 29 . [BKA pers. com.] states that “according 

to the literature, police authorities in the other federal states are also entitled to conduct 

waste transport inspections without concrete initial suspicion”. 

Suspicious cases of illegal waste exports are detected during export inspections 30 , by customs 

for example, and then “the responsible waste management authority is called in” [Deutscher 

Bundestag 2006]. 

In the case of a suspected violation against the provisions of Regulation 1013/2006 or AbfVerbrG, 

or an illegal waste shipment (1) 31 , the inspection authority may seize or impound the 

shipment and packaging (2). If there is only initial suspicion, then the inspection authority must 

gather information in order to clarify the situation (3). This can also be done together with the 

responsible authorities at the shipping and/or inspection location. In the case of shipments out 

of Germany, the inspection authority must inform the authority at the shipping/inspection location 

of their measures (4a and 5). The responsible state authority must decide upon the validity 

of the suspicion in accordance with Art. 11 par. 4 of AbfVerbrG (4b). 

The responsible authority must decide how to proceed with the transport (6) and then forward 

this decision (7). 

Possible further procedures would be: return 32 to the place of dispatch, transport to the place of 

destination or other recycling or disposal of the waste. The responsible competent authority that 

finally decides upon the procedure can be the authority at the shipping location 33 [Kropp 2008]. 

29 According to [Braun 2009], police responsibility for waste transport inspections only exists in a few federal states, such as Hamburg, Hessen, 

Baden-Württemberg and Saxony-Anhalt. 

30 Which generally relate to goods including wastes. 

31 The numbers in the text refer to figure 2. 

32 In the past, there have been isolated complaints by exporters against returns. So far, the courts have adjudicated very differently in cases of 

such complaints. According to statements from parties involved, the different decisions were due, aside from the fact that every decision is in 

part an individual case review, to the courts’ lack of decision criteria to distinguish between UEEE and WEEE. At least one recent case is 

known of that was won in the first instance by the defendant waste authority [pers com. Regb. Düsseldorf].




The procedure for notifying the waste authorities, if the inspecting authority is a customs office, 

is specified in the Guidelines for cooperation with customs offices and waste authorities regarding 

shipment of waste (Handlungsanleitung Zoll) and is as shown in figure 2. 

(7) informs about the 

procedure which has to 

be followed 

(3) possibly clarifies the facts 

(if necessary together 

with A & B) 

A) Competent authority 

of dispatch 

(6) decides upon 

procedure 

Competent technical 

authority* 

Control Authority 

(1) identifies an illegal shipment 

or is suspecting one 

(2) is stopping the transport 

(Seizure, custody, if needed) 

(5) (4a) 

is notifying 

Figure 2: Duties according to AbfVerbrG and Regulation 1013/2006 

(4b) confirms that the 

suspicion is valid 

B) Competent federal 

authorithy at the location 

the control 

*The compentent technical authority may be the competent 

authority of dispatch or the competent authority of 

destination. In cases of unclear jurisdiction both authorithies 

have to reach a common decision. 

Sources: VVA, Kropp 2008, BSU 

In the case of Hamburg, the responsible state authorities at the inspection site, the regional authority 

for environment Behörde für Stadtentwicklung und Umwelt (BSU), the regional water police 

Hamburg Wasserschutzpolizei (WSP) and customs as the inspecting authorities have 

agreed that BSU shall initiate and manage the communications with the corresponding state authorities 

in order to improve pooling of information. In the case of Hamburg, this results in the 

following communication channels (see figure 3). 

33 “Which authority must take the final decision depends on who is responsible for the illegal shipment on the merits of the case. If this is the notifier 

in the sense of Art. 2 No 15 of Regulation 1013/2006 or the party that should have made the notification, then the authority at the shipping 

location must decide. If the consignee in the sense of Art. 2 No. 14 of Regulation 1013/2006 is responsible for the illegal shipment, then the 

decision resides with the responsible authority at the place of destination. If the responsibility cannot be clarified, or cannot be clarified without 

time-consuming investigations, then both authorities must decide together” [Kropp 2008].




possibly clarifies the facts 

with BSU 

Competent authority 

of dispatch 

decides upon 

procedure 

Competent 

technical 

authority 

WSP & Customs 

Hamburg 

identifies an illegal shipment 

or is suspecting one 

stops the transport 

(seizure, custody, if needed) 

notifies 

is notifying 

Figure 3: Communication channels in Hamburg 

informs about the procedure 

which has to be followed 

confirms that the 

suspicion is valid 

BSU* 

informs about the procedure which has to be followed 

*The BSU is the competent federal authority in Hamburg 

(which is in this case, the location of the 

the control) 

2.4 WEEE Directive and German Electrical and Electronic Equipment Law 

Aside from the aims established in Article 1, it is also the intention of the WEEE Directive and its 

German implementation in the Elektro- und Elektronikgerätegesetz, ElektroG (electrical and 

electronic equipment law) to take into consideration requirements of later disposal and environmentally 

sound processing, reuse and recycling of equipment at the end of its useful life already 

in the product design. This Directive and ElektroG apply to the following categories of electrical 

and electronic equipment: 

• Large and small household appliances; 

• IT and telecommunications equipment; 

• Consumer electronics equipment; 

• Lighting equipment; 

• Electrical and electronic tools 34 ; 

• Toys, leisure and sports equipment; 

• Medical devices 35 

• Monitoring and control instruments; 

• Automatic dispensers. 

34 With the exception of large-scale stationary industrial tools. 

35 With the exception of all implanted and infectious products.




Alongside provisions that provide for separated collection and acceptance, they also specify 

that the best available treatment, recovery and recycling techniques must be used. Such treatment 

can also be performed outside the European Union, under consideration of Regulation 

1013/2006. Nevertheless, in the case of treatment outside the EU, the obligations and targets of 

the Directive are only considered fulfilled if the exporter can prove that the treatment took place 

under conditions that are equivalent to the requirements of the Directive. 

Paragraph 23 of the preamble of the WEEE Directive states that “Member States should ensure 

that inspection and monitoring infrastructure enable the proper implementation of this Directive 

to be verified, having regard, inter alia, to Recommendation 2001/331/EC […] providing for 

minimum criteria for environmental inspections in the Member States.” 

The WEEE Directive is presently under revision. One of the debated amendments of relevance 

to this study is the introduction of a provision that shall place the clarification of the property of 

exported electrical/electronic equipment as waste or non-waste on a legally binding basis. The 

corresponding annex to the WEEE amendment is oriented along the amended Correspondents’ 

Guidelines No 1 36 and reproduces its essential content. 

Material Flows in Germany 

According to Germany’s reports to the European Commission, approximately 1.8 million t of 

electrical and electronic equipment was put on the market in 2006 [BMU 2008]. A total of approximately 

754,000 t was collected and treated in the system according to ElektroG, of which 

approximately 19,000 t was in other Member States. In the IT and telecommunication equipment 

category, approximately 315,000 t was in put on the market and approximately 102,000 t 

collected and treated in the system according to ElektroG (of which 7,000 t in other Member 

States) [BMU 2008]. 

There are no statistics available for the total incidence 37 of WEEE in Germany. In order to approximate 

the data regarding material flows outside the monitored systems, conclusions must 

therefore be drawn from other sources. [UNU 2007] determined an average WEEE volume of 

16 to 18 kg per inhabitant and year in “old” EU Member States (EU 15). Applying these externally 

determined figures, one obtains a total WEEE volume in Germany of 1.3 to 1.5 million 

tonnes per year. 

36 See http://www.bmu.de/abfallwirtschaft/abfallverbringung/doc/39643.php. 

37 Unlike the collected quantities included in the BMU communication to the Commission [BMU 2008].




2.5 Revised Correspondents’ Guidelines No 1 for Shipments of Waste Electrical and 

Electronic Equipment 

These guidelines are directed at authorities responsible for implementation of Regulation 

1013/2006, and discuss the subject of shipments of waste electrical and electronic equipment. 

One essential element is the distinction between used equipment and waste equipment. These 

guidelines are intended primarily as a support for enforcement. 

Paragraph 7 of the Guidelines – which, as already mentioned, have no legally binding character 

– states that, where the holder of the material claims that he intends to ship or is shipping used 

EEE and not WEEE, the following should be provided to back up this claim to an authority on its 

request: 

“a) a copy of the invoice and contract relating to the sale and/or transfer of ownership of the 

EEE which states that the equipment is for direct re-use and fully functional; 

b) evidence of evaluation/testing in the form of copy of the records (certificate of testing – proof 

of functional capability) on every item within the consignment and a protocol containing all record 

information (see below); 

c) a declaration made by the holder who arranges the transport of the EEE that none of the material 

or equipment within the consignment is waste as defined by Article 1(a) WFD; and 

d) sufficient packaging to protect it from damage during transportation, loading and unloading.” 

Paragraph 8 of the Guidelines state that electrical and electronic equipment would (normally) be 

considered waste if: 

“a) the product is not complete - essential parts are missing; 

b) it shows physical damage that impairs its functionality or safety, as defined in relevant standards; 

c) the packaging for protecting it from damage during transport and loading and unloading operations 

is insufficient; 

d) the appearance is generally worn or damaged, thus reducing the marketability of the item(s); 

e) the item has among its constituent part(s) anything that is required to be discarded or is prohibited 

under community or national legislation 38 ; 

f) the EEE is destined for disposal or recycling instead of re-use; 

g) there is no regular market for the EEE (see further indicators); or 

h) it is old or out-dated EEE destined for cannibalization (to gain spare parts).” 

38 E.g. asbestos, PCBs, CFCs.




More examples are provided in the annex to the guidelines, which are to make it easier for authorities 

to distinguish between types of used electrical and electronic equipment. Paragraph 27 

of the Guidelines provides that inspections are undertaken by state authorities (e.g. police, customs, 

and inspectors) at facilities and during the transport. 

BSU and the Ministry of Environment Baden-Württemberg 39 have published guidance documents 

based on the Correspondents’ Guidelines. These are intended, inter alia, to inform potential 

UEEE exporters on the criteria that are applied during an inspection of their UEEE. 

Since it is still unknown how long it will be until the WEEE amendment is implemented in Germany, 

and thereby becomes legally binding, the Hamburg BSU has undertaken further action in 

order to operationalise the requirements of the Correspondents' Guidelines. In this context, a 

matrix for TV sets and monitors has been developed that should provide inspection authorities 

with decision aids, based on the criteria functionality/reparability, documents on re-use in the 

country of destination, type of packaging and the condition of the equipment, to help distinguish 

between WEEE and UEEE. 

It must also be mentioned that at the European level, Regulation (EC) No 2037/2000 40 on substances 

that deplete the ozone layer includes a prohibition of the trade of CFC-containing refrigerators. 

This Regulation is being revised, and new requirements are being worked out 41 . 

3 Quantitative Aspects of Export 

This section presents the results obtained from analyzing various statistics. From discussions 

with parties involved and other publications, it became clear that exports of significant quantities 

are made above all into the countries Ghana, Nigeria, South Africa, Vietnam, India and the Philippines. 

Accordingly, focus has been on these countries in the following sections. 

3.1 Statistical Systems 

Exporters declare their data on goods exported from Germany into other countries 42 to customs 

using the customs IT system ATLAS, as paper documents, on data carriers and over the Internet. 

From January to September 2008, approximately 48 % of declarations were submitted in 

paper form, 33 % via online systems or data carriers, and 19 % directly via ATLAS [DESTATIS 

2009]. Given the shift in data flow (see below), the percentage of direct declarations via ATLAS 

is continually increasing. In the month of October 2008, this was already up to 35 %. Major exporters 

figure more often among declarations via electronic systems, while the majority of minor 

exporters make their declarations in paper form. 

39 See . 

40 OJ L 244 from 29/09/2000, p. 1 

41 2008/0165/COD, “Substances that deplete the ozone layer”, Strasburg, 25/03/2009. 

42 By this, we refer to countries outside the European Union [DESTATIS 2008].




The goods are identified according to the internationally used, six-figure “Harmonized Goods 

Description and Coding System” (HS), and supplemented with two more digits by the tariff classification 

and statistical nomenclature of the European Union (“Combined Nomenclature” or CN) 

[Hoeppner 2005]. In the case of electrical and electronic equipment, the goods codes do not 

distinguish between used and new goods. 

Two significant value thresholds must be taken into consideration when making customs declarations. 

Generally, in the case of goods to the value of less than € 1,000, the exporters may declare 

their goods verbally to the respective customs officials. This declaration satisfies the legal 

customs requirements, and no data is forwarded to the Federal Statistical Office (DESTATIS). 

If, however, the goods amounting to this value are heavier than 1,000 kg, then the data must 

still be forwarded to DESTATIS [DESTATIS 2009-1]. In Hamburg, goods to the value of less 

than € 1,000 are recorded in the ZAPP 43 system belonging to the Hamburger Seehafenverkehrswirtschaft 

(seaport traffic economy). Communication with the officials involved in the 

export process is organized in the ZAPP system. In Hamburg these are, for example, the exporter, 

ship owner, liner agent and broker as well as Ericus customs clearance of the Waltershof 

customs office for the purposes of export clearance and export monitoring [OFD-HH 2002] 44 . 

The analyses of the export data from these IT systems are presented in Chapters 3.2 and 3.3. 

Figure 4 illustrates the flow of information between customs and the Federal Statistical Office for 

2008. 

ZAPP(HH) 

Information flow between customs and Destatis 

for export to third countries (status of 2008) 

Reconciliation of the data 

>1,000€ 

�Goods description 

�Individual reports 

�Values 

1,000-3,000€, 

>3,000€ 

�In part number of items 

�Country of destination 

�…. 

German Federal 

Statistical Office 

19%* 

ATLAS 

Customs 


�Individual reports 

Weight > 1,000kg 

�Value >1,000€ 



�….. 

�Sum of all individual reports 


�Weight >1,000 kg 

�Value > 1,000 € 



�….. 

33%* 48%* 

Online reports/ 

Data media 

Figure 4: Information flow between customs and DESTATIS up until 31/06/2009 

Paper reports 

Source: Destatis, Customs Hamburg 

*As at January to October 2008 

Since 01 July 2009, exports have been declared to the Federal Statistical Office almost exclusively 

via the ATLAS system. Accordingly, low-valued goods previously recorded in the ZAPP 

system in Hamburg can also be entered into the ATLAS system [Zoll Hamburg pers.com.]. The 

43 “Zoll Ausfuhrüberwachung im Paperless Port”. Goods of greater value are also recorded in this system. These flow into the ATLAS system. 

44 Oberfinanzdirektion Hamburg Hauptzollamt Hamburg-Hafen -Zollamt Waltershof- Abfertigung Ericus- Hamburg, Verbindliche Regeln für die 

Eingabe zollrelevanter Daten des Hafendatensatzes (HDS)/ der Gestellungsmitteilung (GM01) in ZAPP in drei Teilen, November 2002.




ZAPP system will also continue to be used. Figure 5 provides an overview of the now valid procedure. 

The data of the Federal Statistical Office were available early on in the project and were analyzed 

at the end of 2008. The ZAPP data and the Hamburg export data from the ATLAS HH 

system became available at the end of March 2009 (see Chapter 3.3). The German-wide AT- 

LAS data were provided mid July 2009. 

None of the statistics distinguishes between new and used equipment. As a way to derive information 

relating to the export of used equipment, declared price were referenced in addition to 

declared quantities, since it can be assumed that the price of exported used equipment is significantly 

lower than that of new equipment. The basis for this examination was the specific 

price per kilogram (€/kg). 

The statistics are based largely on the exporters’ own declarations of the exported goods and 

their values. Since the declared values are of relevance to the customs duties and involve 

lengthy verification, it can be assumed that the data regarding values is less precise than the 

data regarding declared weights, for example. 

ZAPP(HH) 

�Values




3.2 Data from the Federal Statistical Office (DESTATIS) 

The export data in this section are based on data from the Federal Statistical Office of Germany. 

Accordingly, low-value exports are not included in the data at this stage (See Chapter 3.3 

regarding the characteristics of the data systems ATLAS and ZAPP and the corresponding 

flows of information). 

3.2.1 Declared Quantities 

Table 3 below summarizes the data from the Federal Statistical Office on export quantities of 

select goods groups in 2007 

n. 

45 . According to this source, approximately 22,000 t of electrical 

and electronic equipment of the 13 goods groups was exported into the 6 selected countries of 

destinatio 

Table 3: Export from Germany to select countries of destination (reference year 2007) 

Goods 

code 

Plaintext 

Weight in t 

WA8415 Air conditioning units 33 32 778 83 46 525 

WA8418 Refrigerators, freezers, heat pumps 64 312 791 169 24 517 

WA8443 Printing machines and accessories for printing machines 106 722 5.154 754 178 2.875 

WA8450 Machines for washing or drying clothes 22 19 358 19 27 49 

WA8469 Typewriters, word processing machines 1 - - 0 1 1 

WA8471 Automatic data processing machines 56 152 782 170 24 108 

WA8510 Razors, shears with electric motor 0 - 25 - 0 1 

WA8516 Electric hot water heaters and immersion heaters 20 56 1.106 3 85 68 

WA8517 Telephone sets, telecommunication equipment 10 478 1.234 116 34 1.737 

WA8521 Audio/video recording equipment 1 60 6 0 0 0 

WA8525 

Transmission equipment for broadcast etc., television 

cameras 

1 56 64 24 3 25 

WA8527 

Receiving equipment for radiotelephone traffic or broad- 

1 4 149 0 0 10 

cast 

WA8528 Television sets, video monitors 153 787 145 802 1 129 

Total 468 2.678 10.592 2.140 423 6.045 

[DESTATIS 2008] 

3.2.2 Specific Prices 

The declared values in the export data from the Federal Statistical Office were analyzed for the 

selected countries of destination. In order to classify and evaluate the specific price declarations 

(€/kg) ascertained for the countries of destination, they were compared with the values of exports 

from Germany to other European Member States. 

45 For details about goods codes and the related equipment, see the Warenverzeichnis für die Außenhandelsstatistik, Issue 2009; or 

http//:www.destatis.de 

Ghana 

Nigeria 

South Africa 

Vietnam 

Philippines 

India




When classifying the specific values in an overall context, it must be noted that low-value exports 

are not accounted for the data from the Federal Statistical Office (see also Chapter 3). 

3.2.2.1 Personal Computers 

Figure 6 shows specific prices of computers exported out of Germany by country of destination. 

The average specific price of exports in the EU Member States of interest is ~83 €/kg. This 

value corresponds relatively well to the average specific price of PCs sold in Europe of 

~70 €/kg 46 . The specific prices for the investigated countries of destination reside between 

17 €/kg and 27 €/kg. 

100,0 

90,0 

80,0 

70,0 

60,0 

50,0 

40,0 

30,0 

20,0 

10,0 

0,0 


Figure 6: Specific prices of computers exported out of Germany by country of destination (€/kg) 

3.2.2.2 Televisions 

For television sets / video monitors, the export data from the Federal Statistical Office provides 

the following picture regarding specific prices (see figure 7). 

40 

35 

30 

25 

20 

15 

10, 

5 

0 


Figure 7: Specific prices of televisions exported out of Germany by country of destination (€/kg) 

46 This calculation was based on an average PC price of 700 €/piece according to [EITO 2007] and a weight of 10 kg/PC.




It can be assumed that the specific prices of the illustrated EU Member States are significantly 

influenced by high-priced (large format) flat-screen monitors. The average price of CRT TVs 

sold in Europe in 2007 was € 100 per set [EITO 2007]. At an average weight of 20 kg/piece, this 

equates to a specific price of 5 €/kg. The average price of screens employing advanced technology 

(predominantly plasma and LCD screens) was 1,000 €/piece on average. At an average 

weight of 17 kg/piece, this equates to a specific price of ~60 €/kg. 

For the countries of destination, there is a relatively widely scattered price/weight ratio with a 

relatively low coefficient of determination of the relationship between price and weight (see figure 

8below). It can be supposed that high-price flat-screens influence the results here, as well. 

Figure 8: Weight/price ratios of televisions and monitors exported out of Germany for various countries of destination 47 

3.2.2.3 Telephones 

For telephones, the export statistics from the Federal Statistical Office reveal relatively large differences 

in specific prices (see figure 9). The specific prices of exports to Nigeria, South Africa 

and Vietnam, however, are higher than those to Belgium, France and the Netherlands. 

47 Ethiopia, Burkina Faso, D.R. Congo, Gambia, Ghana, Cameroon, Kenya, Mauretania, Nigeria, R. Congo, Senegal, Togo, Tansania, Hong 

Kong, Indonesia, Malaysia, Vietnam, Egypt). Data basis: [DESTATIS 2008], [own calculations and illustrations]. The coefficient of determination 

R 2 is a statistical measure for the declared proportion of variability of a dependent variable Y accounted for by a statistical model. In the 

case of the linear regression model shown here, R 2 is the square of the coefficient of multiple correlation. The clustering of points near the 

zero value results from countries that import small quantities at small values.




250 

200 

150 

100 

50 

0 


Figure 9: Specific prices of telephones exported out of Germany to other countries of destination (€/kg) 

One possible reason for this picture could be that telephone switch boxes are also exported under 

the same goods code. 

The analysis is probably also influenced by the differences in prices and weights between fixed 

line and mobile phones. The significance of mobile phones becomes clear from data provided 

by the World Bank on the propagation of mobile phones in the countries of destination which 

show that, in most of the countries observed, there are more “mobile subscribers” than people 

with “access to phones” (see Figure 10). It can be assumed that a significant percentage of 

telephones exported are among the new, mobile technologies, and that there is rather a saturated 

market for the “old” technologies of fixed line telephones, where the replacement rates for 

old telephones with new telephones are lower than for (shorter-lived) mobile phones. It can also 

be presumed that no significant quantities of used mobile phones were exported from Germany 

to Belgium, France or the Netherlands. 

GDP 

6000 

5000 

4000 

3000 

2000 

1000 

0 

Philippines 

Ghana 

[WDI 2006, own calculations] 

Thailand 

Vietnam 

South Africa 

Nigeria India 

Access to phones per 1000 people 

Mobile subscribers per 1000 people 

Philippines 

South Africa 


0 100 200 300 400 500 

Figure 10: Access to mobile and fixed line networks in select countries




3.2.2.4 Refrigerators 

The specific values of exported refrigerators and freezers are summarized in figure 11 below. 

Philippines 

Vietnam 

South Africa 

Nigeria 

France 

Netherlands 

Ghana 

Spain 

Belgium 


0,0 5,0 10,0 15,0 20,0 25,0 

Figure 11: Specific prices of refrigerators and freezers exported out of Germany to other countries of destination (€/kg) 

Once again, we see a picture that does not match the patterns determined for other types of 

equipment (lower valued exports to Africa and Asia). This is probably because higher-priced air 

conditioning units were also sometimes found to be included under the same goods codes. 

The fact that lower-valued exports are not included in the data from the Federal Statistical Office 

could possibly also affect this (see Chapter 3). 

3.2.2.5 Washing Machines 

The equipment type “Washing Machines” produced a similarly atypical picture to that of refrigerators 

(see figure 12). 

7 

6 

5 

4 

3 

2 

1 

0 


Figure 12: Specific prices of washing machines exported out of Germany to other countries of destination (€/kg) 

The reasons for this atypical pattern are unknown. It is possible that commercial washing machines 

influence this picture. The fact that lower-valued exports are not included in the data 

from the Federal Statistical Office could possibly also affect this (see Chapter 3).




3.3 Export Data from Hamburg Port 

3.3.1 Description of the Data 

In order to make better recordings of the volume flows of UEEE, export data from Hamburg Port 

was purchased from Dakosy AG. Dakosy AG manages the ZAPP system and has access to the 

ATLAS system. We were therefore able to obtain data from the ZAPP system as well as the 

ATLAS data for the city of Hamburg (hereafter referred to as ATLAS-HH). 

Both IT systems contain information on transits, i.e. exports, that are only exported via Hamburg, 

but which originate from other federal states of Germany. Apart from data in Chapter 

3.3.4, all depicted data relate only to exports that originated in Germany 48 and were made 

through Hamburg Port. Exports made through other customs officials are not included. 

The data output of DAKOSY AG was divided into the following criteria: 

1. Goods code, 

2. Country of destination, 

3. Number of declarations, 

4. Type of packaging, 

5. Gross weight of the declaration, 

6. Ship name, 

7. Value of goods, 

8. Description of goods, 

9. Year of export. 

These criteria are briefly explained below. 

1) Goods codes 

The data obtained are structured according to the goods codes of the foreign trade statistics. 

From a total of more than 10,000 codes, 150 were selected (see the Annex to this report in 

chapter 11.1) that concerned electrical and electronic equipment that was exported predominantly 

through Hamburg port. For the analysis presented in chapters 3.3, the goods codes were 

aggregated into groups, for refrigerators and freezers, stoves and ovens, copiers, computers, 

televisions, monitors and telephones respectively. Given the possible payload of UEEE in used 

vehicles, seven goods codes for used personal vehicles and caravans were included in the selection. 

48 A comparison of exports from Germany and transits through Germany revealed that the percentage of transit differs between the equipment 

categories. This was approx. 30 % for refrigerators and freezers and between 2 % and 10 % for the other two equipment categories, based on 

gross weight.




2) Country of Destination 

Based on the analyses of the data from the Federal Statistical Office and from interviews with 

experts, 53 countries were selected that come into question as countries of destination for the 

goods codes selected under 1). The list of countries is provided in Annex to this report in chapter 

11.2. 

3) Number of Declarations 

This refers to the number of customs declarations. A customs declaration is defined according 

to the Zollkodex-Durchführungsverordnung (Customs Code Implementing Provision) Art. 4a 

par. 1 as “Handling by which a person … announces the intention to move a good in a specific 

customs procedure” [BFD 2009]. 

In the case of the data presented here, it must be observed that one declaration can cover several 

pieces of equipment as well as the number of outer packaging pieces (see 4 for a more detailed 

explanation). 

4) Type of Packaging 

This criterion describes the outer packaging of the goods. This could be containers, crates, cartons, 

pallets, parcels and much more. Since the packaging may have been included in 3), this 

factor was required in order to computationally eliminate the outer packaging if necessary in the 

event of implausible values. 

5) Gross weight of the Declaration 

This criterion describes the weight of the exported goods. It must be observed here that the 

gross weight may possibly also include the outer packaging. 

6) Ship Name 

The name of the ship on which the goods were exported. 

7) Value of Goods 

In the ZAPP system, the approximate value of the goods must be specified for some declaration 

types, so as to identify declarations to a value of less than € 3,000 or of less than € 1,000. The 

value of the declaration was not specified in the ATLAS-HH record provided. 

8) Description of Goods 

The description of goods is a specification of the goods in plaintext. This could be a highly specific 

description 49 . The quantity of goods in the individual declaration can also be specified. 

49 There was, for example, one entry under goods code 85183095 “GOODS FOR REPAIR RETURN HEADPHONES” or under goods code 

84182191 “USED CFC-FREE REFRIGERATORS”.




9) Year of Export 

Given the different archiving routines between the ZAPP and the ATLAS-HH systems (18 vs. 6 

months), the available data was dated from September 2007 to February 2009 (ZAPP) and from 

July 2008 to February 2009 (ATLAS-HH). Only the data from 2008 were analyzed. 

3.3.2 Method and System of Analysis 

Two queries were developed for analyzing the databases. One “Search by Goods Code” and 

one “Search by Keywords”: 

• In the search by goods code, the ZAPP and ATLAS-HH databases were searched for 

150 relevant goods codes and the selected countries of destination. The queries returned 

a hit, or a record, if the given goods code appeared together with one of the 

specified countries of destination in an export consignment. 

• The search by keywords was performed in order to capture also the volume flows of 

electrical/electronic equipment that did not fall under the selected goods codes. In the 

case of all goods codes that were not queried in the search by goods code, an additional 

query was made as to whether the term “old” or the term “used” appeared in the 

plaintext description of the declaration. A hit was made if one of the terms was included 

in a declaration for one of the selected countries of destination and the goods code was 

not included in the first search by goods code. In order to focus the search on used 

equipment, only exports valued at € 3,000 or less were analyzed. 

The data analyses focussed on the aspect of volume relevance. That means, as soon as those 

countries were identified that made up more than 75 % of the total exports of a group of equipment 

based on gross weight and/or declarations, no detailed analysis of the remaining countries 

was made. 

Given the data situation described in Section 3.3, it was necessary to have both queries each 

run on both the ZAPP and the ATLAS-HH system. Only that way could the total statistically recorded 

quantity of goods exported through Hamburg Port to the selected countries of destination 

be analyzed. The ZAPP system only archives data for a maximum of 18 months. The AT- 

LAS system only archives data for six months. The data obtained from the ATLAS system were 

therefore doubled in order to obtain an approximation of the entire year 2008.




3.3.3 Results from the Data Query by Goods Code 

3.3.3.1 General Analysis 

2,281 records were output on the basis of the selected goods codes for electrical/electronic 

equipment and for the selected countries of destination for the year 2008. Of these, 1,619 came 

from the ZAPP system. Of the records from the ZAPP system that contained declared values, 

16 % related to declarations valued at >€ 3,000. 78 % resided in the value range between 

€1,000 and € 3,000, and 6 % in the value range € 3,000. 92 % resided in the value range between 

€ 1,000 and € 3,000, and 7 % in the value range




1631; 16% 

580; 6% 

406; 4% 

7320; 74% 

ATLAS (extrapolated) 

equipment declared as 

used goods 

ATLAS (extrapolated) 

eqipment declared as non‐ 

used goods 

ZAPP equipment declared 

as non‐used goods 

ZAPP equipment declared 

as used goods 

Figure 14: Goods declared as used goods in the respective IT system (reference: gross weight) 

It can be seen that the number of declarations of goods not declared as used goods is significantly 

higher in the ATLAS-HH system than in the ZAPP system. At 74 %, however, the bulk of 

the weight is made up of used goods from the ZAPP system. 

The query by goods code showed that televisions, monitors, ovens, refrigerators and freezers, 

small appliances and washing machines were quantitatively the most relevant equipment types 

in the declarations in 2008 (more than 10,000 declarations each). Furthermore, small appliances, 

washing machines and computers were other equipment types frequently named in the 

declarations (see also figure 15). 

30000 

25000 

20000 

15000 

10000 

5000 

0 

24983 

23169 

13022 

TV Monitors Cooling and 

freezing 

appliances 

19746 

8263 

Oven Small 

appliances, 

washing 

machines 

1925 

Computer 

Figure 15: Distribution of declarations over various types of electrical/electronic equipment (reference year: 2008) 

Nearly 7,000 t of the declarations were related to televisions. Other equipment types reside 

around 1,000 t or below 1,000 t (see figure 16).




8000 

7000 

6000 

5000 

4000 

3000 

2000 

1000 

0 

6766 

1324 

1022 

TV Monitors Cooling and 

freezing 

appliances 

622 

Oven Small 

appliances, 

washing 

machines 

114 89 

Computer 

Figure 16: Distribution of gross weight over various types of electrical/electronic equipment (reference year: 2008) 

3.3.3.2 Equipment-Based Analysis 

Given the large quantity of used electrical and electronic equipment recorded in the ZAPP system, 

and because reference is only made to the approximate value of the exported electrical or 

electronic equipment in the ZAPP system, the following analyses are based solely on the data 

from the ZAPP system. Furthermore, only the equipment types television, monitors, refrigerators 

and freezers are dealt with, since they make up the bulk of the volume flow. 

3.3.3.2.1 Refrigerators and Freezers 

In 2008, 862 t of refrigerators and freezers (R&F) were recorded in the ZAPP system as exports 

through Hamburg Port (see Table 4). R&F made up 75 % of the declarations and 50 % of the 

gross weight, at a value of less than € 3,000 per declaration. The main countries of destination 

for these types of equipment were Nigeria and Cameroon (76 % in this value category based on 

weight). Neither of these countries imported R&F valued at more than € 3,000. Ghana imported 

only a very insignificant quantity of R&F of greater value. 

The data from the ZAPP query did not specify the precise value the exporters had declared for 

each declaration, rather only specified the value categories, as illustrated. In most cases, however, 

these are relatively broadly defined (




Table 4: Export data returned from the query by goods code in the ZAPP system for refrigerators and freezers 

Number of declara- Gross Percentage of Percentage of 

tions (minimum) weight in t declarations gross weight 

Total export of refrigerators and freezers (R&F) 10,114 862 100 % 100 % 

R&F > € 3,000 2,523 429 25 % 50 % 

R&F < € 3,000 7,591 433 75% 50 % 

of which to Nigeria 5,868 233 77 % 54 % 

of which to Cameroon 41 96 1 % 22 % 

of which to Ghana 1,064 41 14 % 9 % 

of which to the remaining countries 618 63 8 % 15 % 

The quantity of pieces of equipment was specified for three low-valued export declarations, valued 

at < € 1,000, to Nigeria (in total 91). If one applies the maximum declared value 

(€ 1,000 €) 53 , then this results in an average value of maximum € 33 per piece of equipment. 

3.3.3.2.2 Monitors 

In 2008, 947 t of monitors were recorded in the ZAPP system as export through Hamburg Port 

(see Table 5). Monitors of a value of less than € 3,000 made up 16 % of the declarations and 

55 % of the gross weight. The main countries of destination for these monitors were Vietnam 

and Egypt, which accounted for 30 % of the declarations and 93 % of the gross weight in total. 

There was no data available on how many of these were valued at less than € 1,000. 

Table 5: Export data returned from the query by goods code in the ZAPP system for monitors (MT) 

Number of declarations Gross Percentage of dec- Percentage of 

(minimum) weight in t larations gross weight 

Total exports 985 947 100 % 100 % 

MT > € 3,000 830 422 84 % 45 % 

MT < € 3,000 155 525 16 % 55 % 

of which to Vietnam 16 296 10 % 56 % 

of which to Egypt 30 203 19 % 39 % 

of which to the remaining countries 109 27 70 % 5 % 

Of the declarations to Vietnam valued at < € 3,000, the quantity of shipped monitors was specified 

in the goods descriptions of only three declarations (at a total of 2,700 pieces). The average 

weight for these declarations was calculated to be 20 kg per piece of equipment. If this weight is 

then used as the basis for the other declarations as well, then this equates to an exported volume 

of monitors to Vietnam alone of approximately 14,505 pieces. If one assumes that each 

declaration is valued at maximum € 3,000, then this equates to a maximum average price of € 

3.31 per monitor. 

53 The value of € 1,000 is a category and not the actual value. Accordingly, the value of the goods could vary between € 1 and € 1,000.




3.3.3.2.3 Televisions 

In 2008, 6,594 t of televisions were recorded in the ZAPP system of Hamburg Port (see Table 

6). Televisions of a value of less than € 3,000 made up 99 % of the declarations and 98 % of 

the gross weight. The main countries of destination for these televisions were Nigeria and 

Ghana, which accounted for 92 % of the declarations and 96 % of the gross weight. Of the televisions 

that were exported to Ghana, the bulk of the volume of sets was also valued at less than 

€ 1,000. Both countries imported no or only an insignificant volume of televisions whose value 

exceeded € 3,000 per declaration. 

Table 6: Export data returned from the query by goods code in the ZAPP system for televisions 

Type of EEE/Value of EEE/country 

of destination 

Number of declarations 

(minimum) 

Gross weight 

in t 

Percentage of 

declarations 

Percentage of 

gross weight 

Total exports of televisions (TV) 17,793 6,594 100 % 100 % 

TV >€ 3,000 132 127 1 % 2 % 

TV




Table 7: Export quantities of the most quantitatively relevant goods returned from the query by keywords in the ZAPP 

and ATLAS-HH systems (reference year: 2008) 

Total exports Gross weight in t 

Removal goods 1,227 

Copiers 681 

Other equipment55 381 

Televisions 162 

The countries of destination for these goods differ for each type of goods. In summary, it can be 

stated, however, that television sets were shipped primarily to Ghana and copiers primarily to 

India, Egypt, Thailand and Malaysia. Removal goods are spread relatively evenly over a series 

of countries, but greater quantities of removal goods were observed moving into China and the 

United Arab Emirates. 

Other types of equipment were exported primarily to Egypt, China, Ghana and Nigeria in 2008. 

A detailed analysis reveals that the exports to Egypt were in fact exclusively CRT and TFT 

monitors, and the exports to China were almost exclusively microwaves (4,611 pieces). 

The Ghanaian and Nigerian goods comprised many different types of goods, as Table 8 below 

shows. The fact that, despite the specification of gross weight, there is no specification of quantity 

in the declaration is not plausible. However, the reason for such entries could not be explained. 

The other seemingly implausible entries were payloads [Dakosy pers.com.]. 

55 “Other equipment” covers a series of electrical and electronic goods (e.g. clothes irons, vacuum cleaners, laser printers and coffee machines) 

that figure in relatively low quantities in their respective categories.




Table 81: Examples of exports of “other equipment” to Ghana and Nigeria 56 

Number of 

Gross 

weight (in 

declarations 

Ghana 

kg) Description of goods 

0 60 6 gas stoves, used 

0 70 1 wood charcoal grill, used 

0 2 Camping stoves, gas, used 

1 75 Used gas stoves 

0 15 1 set 10 kg scales, used 

25 375 Printers 

0 Printers, used 

19 635.93 Used printers 

4 48 Fax machines, used 

0 300 6 washing machines, used 

10 70 Netbooks, used 

8 58 Used netbooks 

260 3,140 DP units, used PC PIII, PC P4 and server with keyboard, mouse 

991 391 Keyboards, as input devices for automatic data processing machines 

1216 741.76 Used input or output units 

100 35 Hard disk drives, used 

324 324 Used drives 

79 79 CD-ROM drives, used 

0 Clothes irons, used 

0 70 1 quick heating hot water tank 80 ltr., used 

0 Rice cooker, used 

0 200 10 music systems, used 

150 750 Used video recorders 

0 DVD players, used 

572 

Nigeria 

8,645.32 Used monitors, not with cathode ray tubes, for colour picture 

86 1,270 Used printers 

5 50 Used fax machines 

2 13,857 166 used netbooks 

0 0 Output units for DTP, in this case: monitors, used 

30 60 30 loudspeakers, used 

210 2,550 190 music systems, used 

0 DVD machines, used 

50 200 50 TFT monitors, used 

0 Monitors for colour picture, used 

3.3.5 Summary 

In summary, it can be stated that a series of records contained no information on the value 

categories, and that these could therefore not be analyzed in the country-specific and valuerelated 

scenario. Furthermore, the most numerous records were those that contained goods 

valued between € 1,000 to




The exported equipment types that make up the greatest quantities in the ZAPP and ATLAS-HH 

databases were televisions, refrigerators, freezers and monitors. 

Of the six countries of destination originally focussed on – Nigeria, Ghana, Vietnam, South Africa, 

Philippines and India –, Nigeria, Ghana and Vietnam imported the greatest quantity of lowvalued 

electronic equipment in the value category 3,000 € 

No value reported 

Figure 17: Number of records relating to used cars, according to different value thresholds 

The majority of records (79 %) regarding used cars were in the value category between € 1,001 

and € 2,999. 14 % were valued at less than € 1,000 and 2 % at € 3,000 or more. 5 % of the 

used cars were not assigned to an individual value category 59 . 

58 In fact, only 17 refrigerators and 28 televisions were identified as used car payloads in the data. While it would have been possible in principle 

to determine the equipment payloads in a separate query, this would have involved an excessive amount of effort. 

59 The number of records cannot be equated with the number of declarations or the number of exported used cars, since each record can contain 

more than one declaration and each declaration more than one vehicle.




Table 9: Export of used cars (ZAPP) 

Number of declara- Gross Percentage of Percentage of 

tion cases (minimum) weight in t declarations gross weight 

Total exports 153,608 71,268 

of which to Nigeria 115,948 26,285 75 % 37 % 

of which to Benin 15,382 15,894 10 % 22 % 

of which to Cameroon 2,779 3,082 2 % 4 % 

of which to Ghana 4,641 5,707 3 % 8 % 

of which to other countries 14,858 20,300 10 % 28 % 

According to the information from the ZAPP system (see also Table 9), 71,268 t of used cars 

were exported in 2008. If one assumes an average weight of 1,000 kg per used car, and one 

declaration per vehicle, then the number of declarations ought to be of equal magnitude to the 

tonnage.In reality, however, the number of declaration cases is more than twice this quantity.One 

reason for this could be that the respective weight of the goods was not always specified 

upon declaration, and that the quantities given in the ZAPP system are far too low. 

Despite this uncertainty in the data, the ZAPP system does reveal a trend of exports to Nigeria, 

since 75 % of declarations and 37 % of the gross weight were exported to this country. 

Table 10: Export of used cars (ATLAS-HH) 

Number of declaration 

cases (mini- Gross Percentage of Percentage of 

mum) 

weight in t declarations gross weight 

Total exports 5,682 3,091 

of which to Benin 596 700 10 % 23 % 

of which to Ghana 3,578 236 63 % 8 % 

of which to Nigeria 676 1,132 12 % 37 % 

of which to Togo 163 210 3 % 7 % 

of which to Cameroon 129 172 2 % 6 % 

In the data from the ATLAS-HH system, there was no specification of gross weight in 2,480 of 

the declarations of used cars destined for Ghana. This is why these declarations amount to only 

8 % of the gross weight while they also amount to 63 % of the total number of declarations. The 

actual weights of the used cars exported to Ghana should therefore be many times higher than 

the 236 t we see in Table 10 above. The volume of exports to Ghana of 5,707 t as shown in 

Table 9 also bears out this supposition. 

Making an allowance for the abovementioned uncertainty in the data and assuming each used 

car weighs 1,000 kg, one can assume the number of exported used cars is approximately 

70,000. 

Experience at Hamburg Port shows that the electrical and electronic equipment exported as 

payloads in used cars are less frequently white goods and more frequently equipment from the 

consumer electronics, IT, telecommunications and small household appliances segments. The 

exported vehicles are often station wagons and vans. Assuming that every second used car ex-




ported contains a payload of used electrical or electronic equipment, one can estimate a total 

export volume in used cars through Hamburg Port of 3,500 t/a 60 . 

According to expert estimates, approximately 20 % to 30 % of UEEE exports are made in used 

cars. Based on this estimate and on the ZAPP/ATLAS-HH data, the total export quantities of the 

relevant equipment types in used car exports would be 3,000 t to 6,000 t 61 . 

3.5 Analysis of the German Federal ATLAS Data 

Upon analyzing the Federal German ATLAS data according to federal states, equipment groups 

and countries of destination, it becomes clear that there are considerable regional differences 

regarding the information on exported volumes (see Table 11). 

Table 11: Analysis of the German federal ATLAS data (reference year 2008) 

Equipment group Specific weight (t) Value (€) 

Percent specific 

weight 

(%) 

Percentage 

(%) 

Selected equipment groups in total 32,837 46,334,252 

Televisions in total 138 1,172,439 0.4 % 3 % 

Refrigerators 141 689,340 0.4 % 1 % 

Monitors 5,470 1,613,387 17 % 3 % 

Monitors from Bavaria 4,857 501,436 89 % 31 % 

Monitors from Bavaria to Egypt 3,121 48,296 64 % 10 % 

Computers 26,748 16,260,815 81 % 35 % 

Computers from Bavaria 24,429 6,115,632 91 % 38 % 

Computers from Bavaria to Egypt 13,058 717,775 53 % 12 % 

Computers from Bavaria to Tunisia 5,684 952,003 23 % 16 % 

Computers from Bavaria to Morocco 3,555 564,836 15 % 9 % 

Based on their weight and value, only minor quantities of televisions and refrigerators were declared 

in 2008. Computers and monitors made up the greatest quantities by weight. The majority 

of these declared monitors and computers originated from Bavaria (89 % and 91 % respectively). 

These equipment types were exported primarily to North Africa. 

Overall, for the countries of destination focussed on – Nigeria, Ghana, Vietnam, South Africa, 

Philippines and India –, only very little export quantities were recorded in the individual federal 

states in comparison to the North African countries and the total volume. Figure 18 below shows 

the federal states of origin that exported more than one tonne of monitors. 

The only export quantities greater than 50 t are to Vietnam, India and South Africa. These originate 

from Brandenburg in the case of Vietnam, and from Bavaria in the case of India and South 

Africa. 52 t were declared for export to Vietnam from Hamburg. 

The price of monitors exported from Brandenburg to Vietnam was € 3.44 per piece. 

60 Assuming: 10 pieces of equipment per vehicle and an average combined equipment weight of 10 kg. 

61 This only accounts for the quantities for Hamburg, since it can be assumed that there are relatively few used car exports through other German 

ports to the select countries of destination.




The picture is more homogeneous for computers. Of these, export quantities greater than 30 t 

were declared exclusively from Bavaria. A total of 284 t of computers were declared for export 

to South Africa from Bavaria. 

in Tonnen 

450 

400 

350 

300 

250 

200 

150 

100 

50 

0 

Vietnam India South 

Africa 

Bavaria 

Berlin 

Brandenburg 

Hamburg 

Hessen 

Philipins Nigeria Ghana 

Figure 18: Monitor exports >1 t out of the German federal states to the selected countries of destination 

The value of this equipment per piece varies considerably according to the country of destination, 

but is not always plausible 62 . This is due to the fact that, according to statements from the 

ministry of finance (Bundesministerium für Finanzen BMF), it is not stipulated that the quantity 

of pieces of equipment is always specified in the available data [BMF 2009 pers. com.]. 

In the case of monitors from Brandenburg and Hamburg, the piece price was similarly low to 

that determined in Chapter 3.3.3.2.2, at 3.44 €/piece and 4.66 €/piece. 

3.6 Import Statistics 

Wherever available, the import statistics of the countries of destination were analyzed with regard 

to the same data as the German statistics. In the case of Nigeria (Table 12 and Table 13) 

there was information on quantities and prices, and for South Africa (see Table 14) there was 

only information on values. These data are evaluated in Chapter 3.3.5. 

62 The average price per exported computer from Bavaria to South Africa, for example, was € 4,752.




Table 12: Total Nigerian imports of select product groups (reference year 2006) 

Goods code Plaintext Weight (t) Value (€) €/kg 

WA8415 Air conditioning units 41,724 52,419,181 1.26 

WA8418 Refrigerators, freezers, heat pumps 105,547 58,373,305 0.55 

WA8443 Printing machines and accessories for printing machines 72,087 290,279,235 4.03 

WA8450 Machines for washing or drying clothes 15,783 2,450,057 0.16 

WA8471 Automatic data processing machines 399,777 134,530,407 0.34 

WA8516 Electric hot water heaters and immersion heaters 297,622 19,616,052 0.07 

WA8517 Telephone sets, telecommunication equipment 4,081 90,908,720 22.28 

WA8521 Audio/video recording equipment 124,577 5,879,726 0.05 

WA8525 Transmission equipment for broadcast etc., television cameras 79,654 235,746,864 2.96 

WA8527 Receiving equipment for radiotelephone traffic or broadcast 128,120 22,258,748 0.17 

WA8528 Television sets, video monitors 1,617,026 51,133,790 0.03 

Total 2.885.999 963.596,085 0.33 

(Data basis [NBS 2008 pers.com.], own calculation) 

The quantities imported from Germany according to the Nigerian statistics are shown in Table 

13 below. 

Table 13: Nigerian imports of select product groups from Germany (reference year 2006) 

Goods 

Codes 

Plaintext Weight (t) Value (€) €/kg 

WA8415 Air conditioning units 250 1,266,546 5.07 

WA8418 Refrigerators, freezers, heat pumps 41,438 1,499,668 0.04 

WA8443 Printing machines and accessories for printing machines 5,849 7,143,154 1.22 

WA8471 Automatic data processing machines 65,684 5,098,886 0.08 

WA8517 Telephone sets, telecommunication equipment 1,980 18,240,274 9.21 

WA8521 Audio/video recording equipment 22,945 325,644 0.01 

WA8525 Transmission equipment for broadcast etc., television 17,878 1,173,474 

cameras 

0.07 

WA8527 Receiving equipment for radiotelephone traffic or broad- 30,713 276,862 

cast 

0.01 

WA8528 Television sets, video monitors 349,738 2,307,553 0.01 

Total 536,475 37,332,061 0.07 

(Data basis [NBS 2008 pers.com.], own calculation) 

What stand out here are the very large quantities declared for some equipment types, such as 

WA8528 television sets and video monitors at a quantity of 349,738 t or WA8471 automatic 

data processing machines at a quantity of 65,684 t. 

Sources in Nigeria [Osibanjo, Oboro pers.com.] and country reports [BAN 2005] estimate the 

quantities of imported used PCs to Nigeria at approximately 4,000 t/a. The imports to Ghana 

can be estimated at a comparable basis at 2,000 t to 3,000 t. The percentage of those coming 

from Germany could not be quantified for these two countries. 

Table 14 summarizes the value declarations for South African imports of select product groups 

from Germany.




Table 14: South African imports of select product groups from Germany (reference year 2006) 

Goods code Plaintext Value (€) 

WA8415 Air conditioning units 3,829,659 

WA8418 Refrigerators, freezers, heat pumps 2,990,898 

WA8443 Printing machines and accessories for printing machines 28,044,640 

WA8450 Machines for washing or drying clothes 985,660 

WA8469 Typewriters, word processing machines 883 

WA8471 Automatic data processing machines 58,267,712 

WA8516 Electric hot water heaters and immersion heaters 5,302,982 

WA8517 Telephone sets, telecommunication equipment 52,288,894 

WA8521 Audio/video recording equipment 65,357 

WA8525 

Transmission equipment for broadcast etc., television cameras 

111,350,335 

WA8527 Receiving equipment for radiotelephone traffic or broadcast 762,320 

WA8528 Television sets, video monitors 1,937,031 

Total 265,826,371 

3.7 Comparison of Declared Quantities 

The statistics from the Federal Statistical Office (DESTATIS) state a total export quantity of 

22,344 t for the selected groups of goods and the selected countries of destination in 2007. 

The data from the ATLAS database state corresponding export quantities of 32,837 t for 2008. 

The Hamburg ZAPP database states export quantities for the selected groups of goods and 

countries of 8,951 t for 2008. 

In the ATLAS-HH system, 986 t were recorded for the goods codes and countries investigated 

in 2008. 

A comparison of the declared quantities from ZAPP and ATLAS for Hamburg shows that lower 

valued goods are systematically undervalued in the data from DESTATIS. Table 15 below compares 

data from the ZAPP system with the corresponding data from the foreign trade statistics 

by way of example. 

Table 15: Comparison of select ZAPP data with corresponding data from the Federal Statistical Office (reference year 

2008) 

IT system DESTATIS 2008 ZAPP 

Area Germany Hamburg 

Represented value range > 1.000 €




Table 15 shows all quantities for Germany in total 63 . The ZAPP data listed in the table describe 

only exports through Hamburg Port valued




It can be seen that the German export statistics consistently show significantly lower quantities. 

Two essential factors possibly influence this data picture: 

• The Nigerian import statistics also include new equipment. From the analyses of the 

data on the situation in Hamburg Port, the specific values of the exports lead one to assume 

that these relate above all to used equipment. The export of new equipment (of 

the selected groups of goods) plays a minor role in the available data. It is possible that 

transit goods that passed through Hamburg Port play a role in the Nigerian import statistics. 

There are no indications of a significant data gap with regard to new equipment 

made in Germany. 

• In regard to the absolute quantities of the imports to Nigeria, it must be observed that 

the Nigerian ports are also important import sites for imports into other African countries, 

where Nigeria plays the part of a transit country only. 

Table 17: Comparison of import and export data: Ghana (reference year 2006) 

Imports out of Germany according 

to data from country 


Weight Value 

(t) (€) €/kg 

Exports into countries of destination 

according to data from 

Federal Statistical Office 

Goods 

code Plaintext 

Weight 

(t) 

Value 

(€) €/kg 

WA8415 Air conditioning units 100 159,608 1.60 38 320,000 8.42 

WA8418 Refrigerators, freezers, heat pumps 

Printing machines and accessories for 

1,157 613,765 0.53 97 1,243,000 12.81 

WA8443 printing machines 107 458,580 4.29 77 1,132,000 14.70 

WA8471 Automatic data processing machines 

Telephone sets, telecommunication 

303 898,189 2.96 35 1,024,000 29.26 

WA8517 equipment 27 249,659 9.25 1 126,000 126.00 

WA8521 Audio/video recording equipment 

Transmission equipment for broad- 

410 464,903 1.13 3 33,000 11.00 

WA8525 cast etc., television cameras 

Receiving equipment for radiotele- 

20 379.700 18.99 3 589,000 196.33 

WA8527 phone traffic or broadcast 376 374.656 1.00 2 95,000 47.50 

WA8528 Television sets, video monitors 3,391 1,029,731 0.30 147 374,000 2.54 

There is a similar picture for Ghana as for Nigeria, although without the extreme differences in 

declared quantities (see Table 17). There is even a similar trend for the value declarations as 

with the statistical comparison for Nigeria. Overall, the picture confirms the suspicion that the 

exported volumes are systematically underestimated, and the reason for this is exports of low 

value, which according to the data from the countries of destination make up significant volumes. 

Possibly, the bigger differences in the case of Nigeria can be taken as indicator that the volumes 

exported to Nigeria were of very low value, e.g. because Nigeria has an essential function 

as transit country for imports into other African countries.




Table 18: Comparison of import and export data: South Africa (reference year 2006) 


to data from country of destination 

Weight Value 

(t) (€) €/kg 


according to data from Fed- 

eral Statistical Office 

Goods 


Weight 

(t) 

Value 

(€) €/kg 

WA8416 Air conditioning units 

Refrigerators, freezers, heat 

342 5,298,922 15.49 890 16,124,000 18.12 

WA8418 pumps 

Printing machines and accesso- 

749 4,157,191 5.55 561 7,369,000 13.14 

WA8443 ries for printing machines 

Automatic data processing ma- 

3,051 38,798,562 12.72 1,795 40,316,000 22.46 

WA8471 chines 

Telephone sets, telecommunica- 

1,319 80,624,538 61.13 1,523 138,437,000 90.90 

WA8517 tion equipment 

Audio/video recording equip- 

831 72,388,484 87.11 332 69,395,000 209.02 

WA8521 ment 

Transmission equipment for 

broadcast etc., television cam- 

5 90,424 18.08 5 923,000 184.60 

WA8525 eras 

Receiving equipment for radio- 

941 154,133,324 163.80 711 184,634,000 259.68 

WA8527 telephone traffic or broadcast 33 1,084,737 32.87 189 20,778,000 109.94 

WA8528 Television sets, video monitors 157 2,704,278 17.22 70 4,919,000 70.27 

There is a different picture for South Africa (see Table 18). Here, the information from the Federal 

Statistical Office shows bigger volumes in 4 of 9 cases. However, the specific prices are 

also higher in the German export statistics here. 

Table 19: Comparison of import and export data: India (reference year 2006) 


to data from country of destination 

Weight Value 

(t) (€) €/kg 




Goods 


Weight 

(t) 

Value 

(€) €/kg 



538 5,300,393 9.85 370 5,894,000 15.93 

WA8418 pumps 


547 4,611,553 8.43 1,008 9,116,000 9.04 



5,175 70,698,321 13.66 5,329 121,609,000 22.82 

WA8471 chines 


405 21,900,350 54.07 287 25,590,000 89.16 

WA8517 tion equipment 

Audio/video recording equip- 

495 28,749,939 58.08 275 28,016,000 101.88 

WA8521 ment 


broadcast etc., television cam- 

22 394,154 17.92 0 163,000 

WA8525 eras 


64 10,409,120 162.64 643 20,137,000 31.32 

WA8527 telephone traffic or broadcast 64 1,979,997 30.94 7 9,074,000 1.296.3 

WA8528 Television sets, video monitors 88 2,450,879 27.85 54 5,180,000 95.93 

For India (see Table 19), the Indian import statistics also only give higher volumes than the 

German export statistics for 6 of 9 goods codes. The specific values are also higher except for 

one goods code.




Table 20: Comparison of import and export data: Philippines (reference year 2006) 


to data from country 


Weight Value 

(t) (€) €/kg 




Goods 


Weight 

(t) 

Value 

(€) €/kg 



17 206,563 12,15 28 592,000 21.14 

WA8418 pumps 


56 682,076 12,18 32 950,000 29.69 



55 1,455,026 26,46 36 1,567,000 43.53 

WA8471 chines 


18 1,911,097 106,17 35 11,237,000 321.06 

WA8517 tion equipment 594 29,220,480 49,19 28 6,936,000 247.71 



2 118,808 59,40 0 83,000 

WA8525 broadcast etc., television cameras 


3 501,922 167,31 488 27,916,000 57.20 

WA8527 telephone traffic or broadcast 0 3,261 0 164,000 

WA8528 Television sets, video monitors 0 25,476 1 197,000 197.00 

For the Philippines (see Table 20), again, the volumes specified by the Federal Statistical Office 

are lower, with the exception of three cases. The specific values are higher in all comparable 

cases except for one in the DESTATIS statistics. 

3.8 Summary 

For the selected goods groups (see Table 21 below) that proved to be of significant volume for 

this study, estimates of the export quantities out of Germany were derived on the basis of the 

available statistics. 

Table 21: Investigated goods groups 66 

Goods 

code 

Plaintext 


WA8418 Refrigerators, freezers, heat pumps 

WA8443 Printing machines and accessories for printing machines 

WA8450 Machines for washing or drying clothes 

WA8469 Typewriters, word processing machines 

WA8471 Automatic data processing machines 

WA8510 Razors, shears with electric motor 

WA8516 Electric hot water heaters and immersion heaters 

WA8517 Telephone sets, telecommunication equipment 


WA8525 Transmission equipment for broadcast etc., television cameras 

WA8527 Receiving equipment for radiotelephone traffic or broadcast 

WA8528 Television sets, video monitors 

66 For details about goods codes and the corresponding equipment, see the Warenverzeichnis für die Außenhandelsstatistik, Ausgabe 2009 or 

http//ec.europa.eu/taxation_customs/dds/tarhome_de.htm.




Total volume: In the year under report, alongside ZAPP and ATLAS, 33 % of declarations were 

recorded from data carriers / online declarations and 48 % from declarations in paper form. Taking 

into account the volumes recorded in ZAPP (8,951 t) as well as the volumes that were 

probably exported as payloads in used cars (20 % of the volume for the reference year), one 

obtains – in a maximum variant – a total export volume of 216,000 t (2008). If it is assumed – in 

a minimal variant – that a greater percentage of the total export volume is recorded in ATLAS, 

then by the same calculation route, one obtains a total export volume of 93,000 t (2008) 

(weighted averaged of the variants: 155,000 t). 

The value and goods analyses showed that the exported equipment can hardly be new equipment. 

The very low price and the results of various export inspections show that a significant 

proportion was equipment in very bad condition. An indeterminable volume was illegally shipped 

as used equipment when it was in fact waste equipment. It is assumed that the bulk of the 

waste equipment from the 155,000 tonnes did not pass through the system according to the 

Electrical and Electronic Equipment Law (ElektroG). 

By comparison: In 2006 67 , 1.8 million tonnes of new equipment were put on the market in 

Germany. The volume collected in the system in accordance with ElektroG was 754,000 t [BMU 

2008]. 

Value of the exported equipment: Detailed analyses of the statistics from Hamburg Port regarding 

the values of the export declarations lead one to assume that the volume-relevant exports 

of the studied goods codes consisted primarily of used equipment, even in the case of the 

derived “best-case estimates“ 68 . Even in these cases, the prices seen were still low, such as 

€ 3 per video monitor, € 4 per television or € 20–30 per refrigerator or freezer. Yet, the actual 

value will certainly not match the best-case scenario, and will be significantly lower. 

Exported Mixture of Equipment: When differentiating according to equipment types, an additional, 

significant data uncertainty arises because, presumably, the customs declarations were 

not made as differently in every case as one would expect from the contents of the export containers. 

The results of container inspections revealed, for example, that there was not always a 

precise distinction between televisions and video monitors in the declarations. Given undifferentiated 

declarations, it is the small appliances (e.g. consumer electronics) that tend to be underestimated, 

and equipment that is exported in smaller quantities per declaration (e.g. PCs). The 

high total quantity of relevant declarations must be taken into account here (e.g. approx. 

600,000 in 2008). The volumes of smaller appliances are also underestimated because they are 

more frequently payloads in used cars than are large appliances. 

Two variants of the mixture of equipment were therefore developed for the calculation. In Variant 

2, the percentage of exported small appliances was increased in comparison to the specifications 

in the customs declarations (see also figure 19 below). 

67 No monitoring data according to ElektroG exists for the year 2008. 

68 There is substantial uncertainty in the data regarding the actual declarations of values, since no specifications were made on this in the provided 

ZAPP data, rather only value ranges for each declaration (e.g.




100% 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

0% 

1 2 

Variants 

Figure 19: Variants of the exported mixture of equipment 

Computer 

Small household 

equipment 

Other household 

equipment 

TV 

Monitors 

Refrigerators and freezers 

The volume of exported refrigerators and freezers in the studied countries of destination is 

probably to the order of 15,000 t per year, taking into account the volumes not represented in 

the export statistics. Different sources estimate the present-day percentage of waste refrigerators 

that are CFC-free at 10 % to 30 % of the total incidental volume [Becker RAL pers. com., 

UBA pers. com., Weigelt pers. com.]. It is presumed that the volume of CFC-free refrigerators 

arising in Germany in 2008 was less than 10,000 t/a. Based on this assumption, it can be presumed 

that relevant volumes of CFC-containing refrigerators were exported. 

The export volume of monitors, in the averaged variant, is approximately 50,000 t (weighted 

average; range: 28,000 t to 76,000 t); this equates to about 2 million pieces. For this type of 

equipment, again, this can hardly be new equipment, rather a significant proportion must be 

equipment in very bad condition. By comparison: In Group 3 (IT and telecommunications 

equipment), a total of 315,000 t was put on the market in Germany in 2006, and 102,000 t collected 

separately in the system according to ElektroG. 

Note: It must be noted that the exported quantities and the mixture of equipment are probably 

significantly influenced by innovation cycles in the countries of dispatch. In 2008, CRT screens 

(monitors, televisions) were the most relevant equipment type exported in terms of weight, 

which was significantly influenced by the replacement of CRT screens with flat-screens. Inasmuch, 

the view of 2008 can only be regarded as a “snapshot”.




4 Situation in the Countries of Destination 

4.1 Approach 

The situation in the countries of destination was investigated firstly by direct contact with people 

on location, and secondly by analyzing country reports and other subject-related literature. 

4.2 Nigeria 

4.2.1 Treatment Situation 

The Nigerian Harmful Waste Decree No. 42 of 1988 69 restricts the import of wastes for recycling 

and final disposal. Recoverable wastes may only be imported with an approval from the Nigerian 

ministry for the environment [Basel 2006-1]. According to the Nigerian ministry for the environment, 

no approvals were applied for [BAN 2006]. According to [BAN 2006], there is no special 

legislation related to WEEE 70 . According to the Bundesagentur für Außenwirtschaft (Office 

for Foreign Trade), the Nigerian Federal Executive Council had announced import restrictions 

for waste electrical and electronic equipment in 2008 [BFAI 2008]. Whether concrete measures 

followed this announcement is unclear. According to [Basel 2006-1], there are no official installation 

specialized specifically on the recycling of electrical and electronic equipment. There are 

(clinical) waste incineration plants as well as plastic and paper recycling facilities. 

According to [Oboro pers.com.], about 500 containers with electrical and electronic equipment 

reach Nigeria every month. He estimates that approximately 400,000 used computers are imported 

every month. Of these, only about 25 % to 75 % are functional [Osibanjo, Oboro 

pers.com, BAN 2005]. About 45 % of the equipment comes from Europe and the USA each and 

10 % from Asia. About 95 % of the computers imported into Nigeria are used [Osibanjo 2009]. 

There are two major trans-shipment centres for electrical and electronic equipment, the “Alaba 

market” and the “Computer village”, both in Lagos. All types of equipment are imported. Explicitly 

named were refrigerators, mobile phones, microwave ovens and computers. Reference was 

also made to the importance of equipment imported in used cars. 

As a rule, the equipment is directly delivered to the dealers. These have their own grading system 

according to which they evaluate the supplied equipment. Equipment that can be repaired 

is repaired immediately or sold to people who repair the equipment [Adesanya pers.com, Osibanjo 

pers.com]. Irreparable equipment is sold to scrap dealers, who are attributable to the informal 

sector [Adesanya pers.com]. Useful fractions are obtained using very simple means, 

such as breaking open the cases and burning off the cable sheathing [Osibanjo pers.com]. 

There are no laws of any kind in Nigeria prohibiting this approach. In order to change this situation, 

it would be necessary to raise awareness of the problem in Nigeria [Osibanjo pers.com]. 

69 See http://www.unep.org/padelia/publications/comp3Nigeria.pdf. 

70 This is still of no consequence since no equipment is imported as WEEE.




4.2.2 Pricing Situation for the Sale of Equipment and Components 

Research was conducted February and March 2009 on the prices of used equipment and components 

on the markets in Lagos, Nigeria. Since there is a relatively broad range of qualities 

available, a distinction was made between equipment in good quality and equipment of low 

quality. The results are summarized in Figure 20 and Figure 21 as price ranges per piece of 

equipment. It must be noted that the prices drift over the years, and are also influenced by 

global market prices or raw materials. Inasmuch, the situation presented here must be regarded 

as an isolated “snapshot” of the beginning of 2009. 

In the low-qualities group, the average price for PCs was € 30 and for CRT monitors was € 10. 

CRT televisions cost € 15 on average and refrigerators (medium size) € 35. 

€/appliance 

400 

350 

300 

250 

200 

150 

100 

50 

0 

(Data basis [Adesanya 2009 pers.com.]) 

Figure 20: Prices for different types of electrical and electronic equipment in Lagos (good quality) 

€/appliance 

160 

140 

120 

100 

80 

60 

40 

20 

0 

(Data basis [Adesanya 2009 pers.com.]) 

Figure 21: Prices for different types of electrical and electronic equipment in Lagos (low quality)




Imported non-functional equipment is also sold at the markets. The prices, however, vary more 

greatly between vendors and buyers than those for functional equipment. In one case, nonfunctional 

CRT monitors were reported to be priced between 1 €/piece and 3 €/piece. 

More research was conducted on the prices of components from electrical and electronic 

equipment on the Lagos market (see Figure 22). It was seen that relatively high prices were attained 

in some cases in comparison with the European market. RAM modules of 256 MB, for 

example, were sold for as much as € 10, motherboards (P IV) for up to € 25. 

30 

25 

20 

15 

10 

(Data basis: [Adesanya 2009 pers.com.]) 

5 

0 

Figure 22: Prices of used components from electrical and electronic equipment in Lagos 

4.3 Ghana 

According to [Basel 2006-2], there is no direct waste-related legislation in Ghana other than the 

Basel Convention, which has still not been effectively implemented yet [Anane, pers.com.]. According 

to [Basel 2006-2], there are no relevant final disposal or recycling facilities for electrical 

and electronic equipment apart from one plant for recycling lead from car batteries. 

The centre for handling electrical and electronic equipment in Ghana is the Agbogbloshie Market 

in the capital Accra, at which many little workshops for dismantling UEEE exist [Greenpeace 

2008]. More workshops are scattered throughout the entire country [Greenpeace 2008]. 

About 300 containers of UEEE/WEEE reach Ghana every month, according to [Anane 

pers.com.], and the trend is increasing. Primarily computers, televisions and monitors are imported 

into Ghana through the ports of Tema. These pieces of equipment often still bear stickers 

from the original owners. Most European equipment comes from Germany, the Netherlands 

and the United Kingdom. Some of the equipment from the Netherlands is purchased by civic 

amenity centres. About 75 % to 80 % of the imported UEEE/WEEE cannot be reused. The 

transport appears not to be the cause of the faultiness of the equipment, since the traces on the 

casing resemble signs of wear from normal use more than damage in transit [Anane pers.com.]. 

The Ghanaian must pay for the containers in the port upon arrival of the containers, and generally 

have no opportunity to test the goods. There are apparently also cases in which containers 

are directly taken for dumping. At markets such as that of Agbogbloshie, the valuable materials




such as aluminium and copper are manually separated from the worthless materials such as 

plastic. [Anane pers.com.] explains that this manual dismantling also involves breaking open the 

cases and burning off the plastic sheathing of copper cables. 

Side Note – Destination Inspection 

Some third countries such as Nigeria and Ghana employ Destination Inspection (DI) instead of Pre- 

Shipment Inspection (PSI). Taking Nigeria as an example, the following article by [Marfels 2006] explains 

this procedure: 

“With effect from 1 January 2006, the Nigerian government abolished the Pre-Shipment Inspection (PSI) 

system previously in operation and replaced it with a Destination Inspection regime for imports. According 

to the new regulations, goods imported into Nigeria are no longer inspected by inspection agencies of the 

country of origin, rather are subject to inspection only upon arrival in the ports of entry of the country of 

destination. Traditionally, PSI was supposed to prevent, by documents officially issued in the country of 

origin, goods declared below value or declared as inferior from reaching the country, thereby evading the 

actual corresponding duties and taxes. One significant reason for this changeover is the magnitude of corruption 

that had grown under the old regime in the customs clearance of the country of destination. 

The implementation of a Destination inspection regarded as advanced in developing countries generally 

involves setting up modern scanning methods and risk assessment systems by international inspection 

agencies. In the process of introducing such systems, import transactions are commonly divided into different 

risk groups. That way, customs authorities and inspection agencies can concentrate on deliveries 

evaluated as a higher risk, while at the same time, customs can be sped up by low-risk imports through socalled 

“green channels”. […] Alongside the national customs authorities, three international inspection 

agencies are also commissioned with introduction and performance […], namely Swiss agency Cotecna, 

SGS and Global Scan. It must be clarified with the importer in each case which company must perform the 

inspection on site.” 

4.4 South Africa 

There is no special legislation regarding WEEE in South Africa. The National Environmental 

Management: Waste Bill of 2007, however, does affect the handling of WEEE, since, in addition 

to establishing a national waste information system, it also prescribes concepts for producer responsibility 

and for acceptable pollution through the collection and recycling of waste. 

The Second-Hand Goods Bill of 2008 aims to regulate the business of dealers in second-hand 

goods and pawnbrokers, in order to limit trade in stolen goods, and to promote ethical standards 

in the second-hand goods trade [Finlay, Liechti 2008]. 

Computer reconditioners import between 20,000 and 100,000 computers per year to South Africa, 

and about 60,000 used mobile phones [Finlay, Liechti 2008]. More precise figures regarding 

UEEE/WEEE are not known, since the customs statistics do not distinguish between used 

and new equipment [Finlay, Liechti 2008, Ecroignard pers.com.] and the import statistics provided 

reveal only total values (see Chapter 3.6). There is said to be a good network between 

European exporters and South African importers and recyclers [Ecroignard pers.com.]. Donated 

computers pose one of the biggest problems, since they are usually too old (< Pentium 4) to be 

of further use [Ecroignard pers.com.]. 

Figure 23 shows the interplay between the formal and informal sector, taking the chain of parties 

involved for refrigerators, washing machines, microwaves, televisions, stationary computers, 

printers and mobile phones.




Importer 

Source 

Finlay, Liechti 2008, 

amended by Ökopol 

Use/Collection Recovery 

Staatliche Systeme 

Production 

(local) 

Retailer 

Privat/ formal sector 

Consumer 

Collection 

programms 

Informal sector 

2nd hand 

market 

Refinery 

Secondary 

market 

Mechanical treatment 

Manual 

dismantling 

Figure 23: WEEE flow chart for select product groups in South Africa 

Disposal/ 

Export 

Export 

Landfill 

Final disposal of 

hazardous waste 

Scrap 

dealer 

Landfilling 

It is estimated that there are roughly between 40,000 – 50,000 informal recyclers in South Africa 

who deal, among other things, with WEEE. This handling includes burning off cables to obtain 

the copper and dismantling CRT televisions. 

In the formal sector, plastics are, according to [Finlay, Liechti 2008], recycled in various fashions 

(e.g. in furniture or construction materials) [Ecroignard pers.com.]. Computer circuit boards are 

brought to smelters to extract precious metals. Computer circuit boards, nonferrous metals and 

plastic are also exported, according to [Ecroignard pers.com.]. Computer circuit boards are, for 

example, exported to Belgium to Umicore (thermal treatment) and to Singapore (wet chemical 

treatment). Parts are exported to China for further manual separation of plastic and copper. 

Finlay and Liechti deem it possible that the quantity of imported used computers and the quantity 

of exported fractions from computers (metals, circuit boards and plastics) are balanced so 

that the problem of domestic treatment is not so serious in the countries of destination, at least 

in relation to these fractions [Finlay und Liechti 2008]. 

Material fractions for which no market exists, such as batteries, plastic and cathode ray tubes, 

are stored or deposited [Finlay und Liechti 2008]. Where, only a minor percentage even of hazardous 

substances are disposed of at appropriately designed disposal sites. According to Ms. 

Ecroignard, the recycling of CRT and plasma televisions, mercury-containing light bulbs, and 

plastics that contain bromated flame retardants is not yet sufficiently clarified or controlled. Furthermore, 

there is still no depollution of refrigerators, and coolants leak uncontrolled on the 

scrap yards. 

4.5 India 

Between 50,000 t/a and 478,000 t/a of UEEE/WEEE/e-scrap is imported into India each year 

[Rochat et al. 2008, E-Scrap 2009]. The rate of increase of these imports is given at 10 % per




year [E-Scrap 2009]. The majority of this (approx. 80 %) originates from the USA and about 

20 % from Europe [Krishna pers.com.]. 

[Schreiber pers.com.] reports of cases in which pre-treatment is conducted in India, in order to 

export the material subsequently to another Asian country [Krishna, Schreiber pers.com.]. There 

is now a large, informal recycling sector in each of Delhi, Mumbai, Chennai and Bangalore [Rochat, 

Krishna, Schreiber pers.com.], which recycles about 95 % of the UEEE/WEEE or the fractions 

obtained from processing WEEE [Schreiber pers.com.]. 

Mixed scrap batches cost about 31 €/t. For older equipment that contains even more precious 

metals payment is done sometimes per appliance [Krishna pers.com.]. 

The contents of containers or their destination or purpose are often incorrectly declared. The 

container contents are declared as steel scrap, where they in fact contain UEEE/WEEE. Often, 

UEEE/WEEE has been declared as donations for schools, without this ever reaching any 

school. Mainly computers and printers are imported, and also monitors, mobile phones, audio 

systems, motherboards and circuit boards [Krishna, Schreiber pers.com.]. 

Corruption is said to be a major problem in this sector, in particular at ports and in customs 

[Krishna, Schreiber pers.com.]. Aside from sea routes, there is also said to be an important land 

trade route that runs from Dubai, via Pakistan, to Delhi [Krishna pers.com.]. The equipment was 

imported by import/export firms and then sold to wholesalers, who in turn the equipment into 

batches and then sell or auction these to the informal sector [Krishna, Schreiber, Venkatesh 

pers.com.]. A large number of jobs depend on the informal sector. 

Copper, silver and gold are extracted using wet-chemical processes and acid leaching [Krishna, 

Schreiber pers.com.]. The recovery rate for precious metals from circuit boards is around 20 %, 

but it is enough to be profitable in the informal sector [Krishna, Schreiber pers.com.]. Gold is 

mainly destined for the Indian jewellery market [Venkatesh pers.com.]. Details on the recycling 

techniques are given in Table 22. 

Table 22: Dismantling and recycling techniques in the informal sector 

Component Dismantling and recycling techniques 

Monitors Manually using screwdrivers and pliers; unusable monitors are pulverized with hammers 

Processors and other gold- Manually using screwdrivers, hammers and pliers. Gold extraction by chemical stripping at 

containing components river banks and open wastewater channels using hydrochloric and sulphuric acid 

Circuit boards Removal of functional components, copper recovery by open burning 

Printers Motors reused in toys 

PVC-insulated cables Burn-off or manual stripping of the insulation 

Hard disks Manual separation of individual components, melting of metals 

Capacitors Open burning for metal recovery 

Plastics Reduction to small pieces and low-temperature melting for re-use in low-quality products 

(downcycling) 

Toner cartridges Toner cartridges frequently cleaned with old toothbrushes without any breathing protection. 

Plastic casings are sold for filling or melting down 

[Subramanian 2007, E-Parisaraa 2007] 

Only primary products of the Indian market are actually repaired or re-used in appreciable quantities; 

non-functional imports serve only for recycling [Krishna pers.com.].




In recent years, partly due to an Indian-German-Swiss partnership 71 , two processing plants 

were opened in which UEEE/WEEE processing can be monitored and processed according to 

certain guidelines 72 . These plants are E-Parisaraa Ltd. in Bangalore and Trishyiarya Recycling 

India Private Ltd. in Chennai. A third plant with a capacity of 12,000 t per annum is currently being 

built in Hardiwar [Lalchandani 2008] near Delhi. 

These plants process equipment from the country’s local producers and from official collection 

points, but not equipment from imports. The informal sector is said to be very well organized, so 

that some manufacturers still sell their equipment to this sector in spite of these plants [Krishna 

pers.com]. Furthermore, it can happen that even the formal sector passes equipment down to 

the informal sector, or that the applicable methods are not followed entirely [Schreiber 

pers.com]. Reasons for this include “the fact that volumes are not coped with, that knowledge or 

sensitivity are not yet sufficiently developed, and that the development of downstream recyclers 

is taking a long time to get underway“ [Schreiber pers.com.]. 

Figure 24 below provides an overview of the collection and recycling infrastructure in India. 

Producer 

+ Importer 

Retailer 

Distribution/Use Collection Recovery 

Imports 

Source: 

Rochat 2008, 

amended by Ökopol 

Business 

consumer 

Privat 

consumer 

1 

2 

Scrap 

dealer 

Broker 

Scrap 

collector 

Repair + 

Refurbish 

Infor‐ 

mal 

Sector 

l 

1 

Landfill 

Informal 

landfill 

& incineration 

2 

Material recycling: Manual dismantling of hazardous components 

by acid leaching 

Informal final disposal : Emissions from incineration 

and from landfilled materials 

Figure 24: WEEE flow chart for select product groups in India 

Final 

disposal 

According to [Rochat pers.com], the situation in the big cities in India is essentially comparable 

with the contents of the chart. There are apparently certain differences, however, that need to 

be taken into account. Since Delhi is the “capital” of the informal recycling of UEEE/WEEE and 

of fractions from WEEE, many informal recyclers sell the dismantled equipment directly to Delhi 

71 See http://www.ewa.co.in/index.html. 

72 See http://www.cpcb.nic.in/e_Waste.php.




for further processing. Seeing as Chennai and Mumbai are port cities, the percentage of imported 

UEEE/WEEE is probably greater there than in other cities [Rochat pers.com]. 

Certified plants dismantle and recycle primarily used electrical and electronic equipment from information 

technology (76 %), telecommunications (12 %) and consumer electronics (7 %) 

[Seemann et al 2008]. Cases are pulverized, granulated and mixed with primary plastics in order 

to produce new cases or cable conduits. The quality loss this involves is said to be immaterial 

for the Indian market. Certain flows are put into storage, probably to be dumped or used as 

landfill later, e.g. coatings from cathode ray tubes, dust and residue from pulverization, coatings 

of fluorescent tubes and dry-cell batteries. Circuit boards are apparently transported to Umicore 

in Belgium. Prerequisites for this are a high percentage of recyclables in the circuit boards and a 

high market price for the metals [Schreiber pers.com]. 

For materials that originate from certified operations in India and are dumped, it would also be 

generally conceivable to organize return logistics, even if it would be necessary to pay for the 

recycling in Europe. This would only work, however, if the revenues from the recyclables cushion 

this appropriately. At current prices, this would not be possible [Schreiber pers.com]. 

4.6 Philippines 

In Philippine legislation, there have so far been no specific regulations on WEEE or any distinction 

between used electrical and electronic equipment and WEEE [UNCTAD 2006]. 

The Interim guidelines for the importation of recyclable materials 73 containing hazardous substances 

(DAO 94-28) 74 allow the import of electronic parts and scrap under the condition that 

written approval is obtained from the Department of Environment and Natural Resources 

(DENR) and under the condition that hazardous residues from recycling that cannot be re-used 

in the Philippines are sent back 75 . The handling of hazardous wastes is regulated in the Procedural 

Manual on the Guidelines on Hazardous Wastes Management 76 , and according to [Rativo 

2008] WEEE shall also be included in the waste catalogue of this manual in future. 

Mainly used computers and household appliances are imported and either repaired and resold 

or recycled in processing plants [Rativo 2008]. 

There are two processing plants for UEEE/WEEE, one that pulverizes or reconditions computers 

and one that extracts nonferrous metals and precious metals. Although the capacities of 

these firms would actually not be adequate to process the incident wastes from this sector, one 

of the firms was on the brink of giving up because considerable volumes are exported to other 

Asian countries, such as China, Taiwan or Thailand [Garcia 2006]. 

73 “Recyclable material” is defined as “any material which is re-used following its original use, for any purpose of commercial, industrial, agricultural 

or economic value”. 

74 See http://www.emb.gov.ph/laws/toxic%20substances%20and%20hazardous%20wastes/dao94-28.pdf. 

75 However, no hazardous wastes may be exported from the EU to the Philippines. 

76 See http://www.emb.gov.ph/hazardous/index.htm.




4.7 Vietnam 

All import of hazardous wastes, including UEEE/WEEE is legally prohibited in Vietnam 77 . Only 

temporary imports for re-export, including wastes, are allowed [Basel 2006-3, Yen pers.com.]. 

According to [Yen pers.com.], UEEE/WEEE also only enter the country as transit, and are then 

forwarded on to China, for example. This type of input is only possible with approval from the 

Vietnamese Ministry of Industry and Trade. 

There are about 20–30 approved plants that may recycle hazardous wastes. Other recycling is 

limited according to [Basel 20006-3] to paper, plastic, metals and glass, which may be performed 

by small recycling communes in the north of Vietnam. There is a series of disposal sites 

and (clinical) waste incineration plants in Vietnam. According to [Ahn 2007], there are no treatment 

plants for WEEE or processing guidelines for handling WEEE. A series of illegal imports of 

monitors, refrigerators and washing machines into Vietnam were discovered in 2007 [Ahn 

2007]. 

For the South East Asian region, the Asian Network for Prevention of Illegal Transboundary 

Movement of Wastes 78 exists, initiated by the Japanese government and is recognized by the 

Basel Convention, which documents the progress of the implementation of the Basel Convention, 

delivers background material and has a total of 11 South East Asian countries as members 

79 . 

4.8 Other Countries 

In addition to the abovementioned countries, telephone and written contact was made with Indonesia, 

Malaysia and Thailand 80 . The BCRC 81 of Indonesia only responded generally to the 

questionnaire and communicated that the import of hazardous wastes including UEEE/WEEE is 

legally prohibited and the nationally incidental WEEE is for the most part informally recycled. 

Furthermore, Indonesia exports WEEE and computer circuit boards in particular, mainly to Japan. 

There is no legal distinction made between UEEE and WEEE in Indonesia [Jinhui, Nana 

2008]. 

77 See Decree No 12/2006/ND CP ND-CP at http://www.dncustoms.gov.vn/web_Eglish/english/nghi_dinh/59_ND_CP_12_06_2006.htm and 

http://www.dncustoms.gov.vn/web_Eglish/english/btm/04_TT_BTM_06_04_2006.htm. 

78 See http://www.env.go.jp/en/recycle/asian_net/about.html. 

79 Cambodia, China, Hong Kong, Indonesia, Malaysia, Philippines, Republic of Korea, Singapore, Thailand, Vietnam and Japan. 

80 This contact was predominantly written, since the large time difference made telephone contact difficult, and the telephone connections were 

generally of very bad quality. Malaysia and Thailand did not respond. Details on the persons and institutions contacted are given in Appendix 

11.1. Furthermore, one Chinese-Malaysian company was contacted that apparently installs used cathode ray tubes into new television casings. 

The General Manager confirmed the written answers to some questions, but reacted no further than this. 

81 Basel Convention Regional Centre.




4.9 Summary 

Analysis of the treatment situation in the countries of destination showed that, in most cases, no 

infrastructure for treatment exists that is even remotely comparable with the infrastructure that 

the European Member States regard, for themselves, as the minimum standard of environmental 

and health protection 82 . 

In some countries of destination (e.g. South Africa or India), processing and recycling plants do 

exist for certain types of equipment and fractions from the processing of equipment. Nevertheless, 

there appear to be no management or control mechanisms effectively established that ensure 

the imported equipment actually makes it to these plants. 

The highly manual dismantling of equipment often achieves good separation of the materials in 

the first stage of the recovery chain. This, however, only applies to fractions that can generate 

sufficient returns on the respective regional market. This dismantling is essentially done by the 

informal sector. In African countries, especially, the degree of organization of the informal sector 

is low. As a result, the market access for selling fractions is very strongly dependent on local 

conditions. The prices that can be reached on the global market for fractions obtained from dismantling 

WEEE are therefore often difficult to carry over. The discussions and research showed 

that market access for such fractions is becoming an increasingly significant factor for the future 

development of waste management. 

As concerns resources, the most relevant problem is above all equipment that contains relatively 

large amounts of raw materials that cannot be recovered or cannot be marketed in the existing 

treatment infrastructures of the countries of destination, or for which the environmental 

consequences of recycling are most particularly problematic. This is above all equipment containing 

circuit boards and nonferrous metals that are present in low concentrations inside components 

(e.g. gold in circuit board components). 

The recovery rates for precious metals or rare earths are generally lower in the recycling methods 

employed in the most significant countries of destination than in the state-of-the-art methods 

according to European standard. The recovery of ferrous metals is classified as less problematic. 

82 Here we refer above all to the Waste Framework Directive (Directive 2008/98/EC of the European Parliament and of the Council of 19/11/2008 

on waste and repealing certain Directives, OJ L312 of 22/11/2008) and the WEEE Directive.




In light of the treatment infrastructures in the countries of destination, risks to human health and 

the environment can be posed in the four following areas: 

• Treatment steps in which a mechanical disassembling involves destruction of the material 

structures (e.g. the smashing of cathode ray tubes); 

• Hazardous substances which are contained in the products and which might be emitted 

e.g. by thermal processes. The quantity and number of these substances are reduced 

through the ecological optimisation of the products within the scope of manufacturers’ activities 

and the limitation through the RoHS-Directive from 2007. The use of such equipment 

as used equipment in the destination countries takes place, however, time-delayed 

(commensurate with the service life in Germany); 

• Auxiliary products from separation and/or recycling processes (e.g. liquids and sludge 

from leaching); 

• Substances which result from the handling or recycling (e.g. PCDD/F with thermal processes). 

With the last two points, a modification of the processes in the countries of destination is necessary 

if a level of protection comparable with Europe is to be achieved. 

The reduction of hazardous substances in newly produced electrical and electronic equipment 

taking place currently is an important step in reducing the environmental and health risks from 

treatment, also in the countries of destination. In addition, it is however, necessary also to incorporate 

in the overall consideration the risks from the use of auxiliary products from the handling 

(e. g. leaching agents, cyanide), as well as the emissions from handling and recycling 

processes (e. g. PCDD/F emissions from thermal processes, wastewater, secondary wastes 

such as, for example, sludge). 

Against the background of the treatment situation in the countries of destination, an extensive 

differentiation of equipment types, components and fractions with the estimation of the environmental 

and health risks appears to be sensible. For this, Appendix II of the WEEE Directive can 

be used. 

Environmental and health problems, which arise through a lack of or insufficient waste management 

structures, also from own stock equipment, are also significantly increased through 

imported equipment which, following import, has no utilitarian use (and is to be treated immediately 

as waste). But even equipment with curtailed service life 83 leads to treatment problems 

arising more quickly. Through the shortened usage period, there is often no acceptable balance 

between usefulness and environmental loading from treatment. 

Against the background of the presented relationships it appears to be sensible to undertake a 

differentiation of the exported equipment using their characteristic and/or usage profiles which 

covers seven groups (see Table 23). 

83 Compared with new equipment.




Table 23: Overview of property profiles of electrical and electronic equipment for export 

Equipmentcategory 

Property Condition according 

to Correspondents’ 

Guidelines 

No 1 paragraph… 

Type of use 

A New or as new, fully functional / 

B 

C 

Used, fully functional 

Used, limited function 

8a 

Use of equipment 

D1 Used, non-functional, non-waste-status 8b 

Equipment does not remain in 

the country, and is sent back 

D2 

E 

F 

Used, non-functional, no used equipment status 

Use as source of spare parts 

Use as source of raw materials (extraction of valuable 

fractions) 

9 

Use for parts 

Material use 

G Direct dumping / No use 

Equipment of Groups D2 to G is, with the following work steps, treated as problematic groups 

for export. Equipment of Group D1 primarily covers equipment which is shipped collectively for 

repair by the manufacturer or their repair centres within the scope of warranty. Groups A to D1 

are treated below as less problematic groups of exported equipment.




5 Parties involved in the export chain 

Preliminary remark: When the term “exporter” is used in the following, this describes exporters 

who export to countries outside of the European Union and in particular to those countries 

which are considered in depth in this study. 

5.1 Collection points 

Collection points are important centres of the export business between collection of equipment 

in Germany and export to countries of destination (see the examples in Figure 25 and Figure 

26). A distinction can be made between various types of collection points in the context of this 

project:




a) Collection points where 

equipment is traded (purchase 

and sale at the location) and 

where equipment suitable for export 

are packed either on location 

or at another location into sea containers 

and vehicles (the operator 

of the collection point and the exporter 

are not necessarily the 

same individual; it is also possible 

for example that the operator of 

the collection point acts as an 

agent from whom the exporters 

purchase). 

Billstraße in Hamburg for example 

is a well-known agglomeration of 

such points. Here around 20 companies 

trade in electrical equipment. 

Most are import and export 

companies whose covered warehouses 

contain often new and returned 

goods in their original 

packaging. Some of the companies 

trade exclusively in used 

equipment in a poor condition. 

Two site inspections took place 

and traders were interviewed. Basically, 

as expected, they did not 

want to talk openly about the issue. 

Nevertheless, it was possible 

to ascertain that most traders 

seemingly sell a mixture of used 

equipment and new and returned 

goods. In some cases, they specialised 

in particular types of 

equipment. One trader stated for 

example that he only exported 

electronic tools from traders. 

Figure 25a to d: Collection points (trade) 

There is also specialisation with 

regard to destination countries; 

this is due among other things to the operators of the collection points or the exporters having 

contacts in these countries. They often have contacts in the countries of destination because 

they come from there or have relatives there. As well as countries in Africa and Asia,




countries in Eastern Europe (Poland, Ukraine and Russia) were also stated as countries of 

destination. The exporters dynamically adapt their choice of countries of destination though 

to market conditions 84 . 

Some traders traded mainly in returns which originate from a particular technology market 

and German technology company. It was stressed in interviews that returns are not as 

popular as they once were as often only around 20 % of the appliances still work. 

In some cases, minor repairs are made at the sites. 

Of the equipment which appeared to be as good as new, in particular televisions, DVD 

players/records, compact music systems and occasionally white goods were seen. The appliances 

which had clearly already been used mainly involved ovens, refrigerators, televisions 

and monitors. 

b) Collection points where there are containers in which the equipment is consolidated for 

a longer period and then packed into sea containers which are located at the site for a 

limited period (e.g. collection in consolidated containers for several weeks or even 

months; the sea containers are packed in three days) (see the example in Figure 26). 

Figure 26a to b: Collection points (no trade) 

Large collection points of this kind hold around 50 consolidation containers, while 

smaller ones hold around 5 containers. When such collection points were visited at the 

end of 2008 and start of 2009, the contents of the consolidated containers and sea containers 

were inspected among other things. There were used televisions and televisions 

84 One trader stated that before Poland joined the EU a lot of goods were exported to Poland and then onto other countries in the former Soviet 

Union, and in particular to Russia, and that this trade has now shifted to West Africa.




which looked as good as new, compact systems, CD-radio decks and loudspeaker 

boxes, cookers and refrigerators in the sea containers which had just been filled 85 . 

c) Temporary stores in which normally larger batches of commercial equipment are stored 

before export: 

In view of the number of this type of temporary store, there is no basis upon which an 

assessment could be made. 

The authorities in the cities in which collection points were visited (among others Hamburg and 

Bremen) monitor them with regard to the requirements for compliance with environmental standards 

for commercial companies and the storage of such goods. There are no waste-related 

permit requirements. Occasionally (e.g. in Amsterdam) spot checks are carried out on the contents 

of containers with regard to export regulations (visual condition of the equipment for a first 

rough assessment of the waste characteristics, inspection of cooling equipment for CFCs, compliance 

with packaging regulations, loaded with materials with export restrictions). 

Based on expert estimates, the number of such collection points in Germany can be estimated 

at several hundred to over a thousand. 

Experience from export controls shows that at the collection points very often equipment of 

varying quality is mixed in containers. Often equipment which still works is mixed with faulty 

equipment and high-quality equipment. As a rough guide, it can be assumed that they are separated 

into three types of quality in the country of destination (“non-working and non-repairable” – 

“source of replacement parts” – “useable equipment”) (even if the exporter pre-selects the appliances 

in Germany). 

The research has shown that a few large and many smaller exporters are active. The exporters 

who only export a small number of appliances are often so-called “waste tourists” who come to 

Germany, buy and load material for one or more containers and then receive the container 

again in the country of destination (in particular in West Africa) and sell on the contents. 

5.2 Other parties involved 

As well as the operators of collection points (and the exporters in those cases where they are 

not the same), a range of other parties are involved in the export of equipment. The chain after 

the collection points (or the other points from which equipment is exported) includes agents, 

forwarding agents, other service providers for logistics and formalities and shipping lines. 

These other parties have hardly any influence on what is actually exported. Therefore, only a 

cursory description is provided here. 

Agents often form the link between exporters and shipping lines. If required the agents also organise 

the sea containers and the stowing of the equipment in the containers. The agents often 

have a very close relationship in terms of personnel or premises with the exporters. 

According to the Hamburg police, exports to West Africa are normally handled by forwarding 

agents. It was estimated that there are around 10 forwarding agents handing significant vol- 

85 There are also significant volumes of other products such as used tyres. Some containers were filled with only tyres.




umes. Exports to South East Asia on the other hand are normally handled directly by the shipping 

companies without the use of a forwarding agent [Hamburg police pers.com. March 2009]. 

There is in particular significant use of shipping lines to transport UEEE (as opposed to occasional 

transport). For the West Africa route, around 10 lines are significant. Exports to Asia are 

currently handled by primarily around 10 shipping lines. According to the exporters on both 

routes, mainly fully loaded containers are exported; the volume of containers where exporters 

stow their goods in containers of other exporters is less significant. As a result the containers 

are rarely stowed with equipment in the ports themselves (on the quayside) or at specialist container-loading 

companies, but in most cases at collection points. 

The shipping lines stop at many ports in Africa or 

Asia on their routes. By way of example, Figure 27 

shows a route which starts in Poland (Stettin) and 

then stops at Hamburg, Antwerp, Nigeria and the 

Ivory Coast. 

A close relationship in terms of organisation and 

personnel between exporters and shipping lines 

and specialisation in certain goods, for example 

the export of used cars (e.g. ships of the Grimaldi 

Lines) is not noticeable with the shipping of UEEE. 

In the container business, the shipping line has 

less contact with the goods (although the shipping 

line receives information on the load via the shipping 

documents). 

The shipping lines have more contact with the 

UEEE exported when the appliances are loaded 

into used cars. These cars are often welded shut 

to prevent theft during transport. Normally the 

owner of the appliances in the used cars is the 

owner of the car. 

Figure 27: Example of an Africa route




6 Origin of the equipment 

Hardly any information is available on the origin of the equipment. When exporters were questioned 

in the interviews and by the police, flea markets are most often stated as the origin. It is 

assumed, though, that this area of origin is only stated because here normally no receipts are 

issued with purchases and sales [pers.com. Bremen and Hamburg police, November 2008 and 

January 2009]. 

According to the police they could gather more detailed information on the areas of origin if, for 

example, after a transport is stopped the authority leading proceedings issued such a request to 

the police; this was hardly ever the case though. 

During the course of the investigation, it was revealed that exported equipment has many areas 

of origin. In this chapter the results of the research will be summarised and the export-related 

“profile” of the equipment from the areas of origin will be described in relation to 

• - quantity, 

• - quality, 

• - efforts of procuring the equipment for the exporter and 

• - price. 

As there is little sense due to the poor data and greatly fluctuating volumes in estimating the 

precise tonnage when looking at volumes, quantification is by volume category 86 . 

6.1 Collection of bulky waste 

The collection of bulky waste is used by commercial collectors or individual persons to sort out 

usable components before collection by the municipality. 

The collection of bulky waste is organised in various ways in Germany: 

• Collection at fixed, published times (times are published in the Bulky Waste Calendar or 

in the Official Journal) and collection on a rota basis, 

• Collection at individually determined times. Here the holder of the waste requests the 

collection of bulky waste (e.g. by “bulky waste ticket”, by telephone or online) and is 

given an individual time. These times are normally regionally pooled by the municipality 

for reasons of efficiency. 

The bulky waste is actually most often collected from the roadside and sometimes by personnel 

from homes or storage rooms (e.g. Hamburg). 

86 Volume category I: 50,000 t/a.




When the bulky waste is collected by the municipalities at individual times, the bulky waste provided 

may be stolen if the regions served were known to the commercial collectors or individual 

persons, which according to expert interviews often happened. With call-off collections, collection 

times are consolidated into regions. According to [VKS 2008] a vehicle stops at an average 

of 40 loading points per day. 

[VKS 2008] shows based on a survey of municipal waste treatment companies that ca. 80 % of 

the 161 companies surveyed collect bulky waste by call-off and ca. 12 % collect periodically; the 

remaining 8 % are hybrid forms or systems with central receiving points (see Figure 28). 

Delivery + call‐off 

59% 

only call‐off 

19% 

only delivery 

3% 

only periodical 

collection 

4% 

Delivery + 

periodical 

8% 

Call‐off + periodical 

4% 

Call‐off + periodical + 

delivery 

3% 

[VKS 2008] 

Figure 28: Type of bulky waste collection in Germany 2006 

Details on the number of residents associated with each type are not provided by VKS. Of the 

30 largest cities in Germany, 6 cities carried out periodical road collections in 2006 while 24 cities 

used a call-off system [VKS 2008]. 

Concerning the question of which system is used most, 22 % replied with “delivery to the recycling 

yard” (for more details see Figure 29 below) [VKS 2008]. 

Only delivery 

20% 

nur Abruf 

46% 

Delivery + periodical 

20% 

Call-off + 

periodical 

1% 

Only 

periodical 

collection 

13% 

[VKS 2008] 

Figure 29: Most used type of bulky waste collection in Germany 2006 

Concerning the question of what collection intervals are offered, 11 % stated “once a year” 

41 % stated “twice a year” and 48 % stated “several times a year” [VKS 2008]. 

With regard to the effectiveness of controls and regulatory measures against the theft, the following 

is found: “For some years the city’s police has been carrying out regular spot-checks. If 

they come across people stealing objects, fines are imposed and in some cases, vehicles are 

even confiscated. However, this has neither prevented nor reduced the cases of theft [Wuppertal 

waste balance 2006].” Other municipalities report similar experiences (e.g. the District Government 

of Düsseldorf).




Based on this experience theft is most likely prevented when the bulky waste is collected by the 

municipality from homes (as in Hamburg for example). There is no information available on how 

many municipalities are doing this. 

Quantification: The average number of collections per year per collection district is 2.8 87 . The 

number of collection districts is >1,000. In 10 % to 15 % of the collection districts (periodical collection) 

the risk of theft is according to the above information very high, in 50 % (call-off) a reduced 

risk is assumed. 

Based on the experience in several major cities in Germany, with periodical collections it is estimated 

that in periods of high metal prices, as in 2008, 75 % of white goods are stolen from. 

For collection by call-off, a reduced theft rate is estimated (50 %). This results in a volume in 

volume category II (10,000 t/a to 50,000 t/a) 88 which is mainly comprised of white goods, consumer 

equipment, small household appliances and IT 89 . 

What share of this is actually exported to countries outside of the EU is unclear. 

The number of points of origin can be roughly estimated at >1,000. 

Qualification: In contrast to equipment which is sold via barter exchange, free papers, flea 

markets, internet portals or internet auction sites, the equipment disposed of via bulky waste are 

considered by the user to no longer have a monetary value which would justify the cost of a 

sale. The quality of the equipment is normally poor to very poor. 

Price: By stealing from bulky waste the thief obtains the material at virtually “no cost”. 

87 This is a weighted average of the data from [VKS 2008]. 

88 It should be noted that these figures were greatly influenced by the situation in 2008 where very high raw materials prices resulted in a rise in 

thefts. In the rough estimate of volumes it was assumed that 700,000 t of EEE come from private collections. The share collected via collections 

is estimated at roughly 1/3. This results in a total theft volume of 26,500 t per year for periodical collections (15 % of collections) and a 

volume of 58,250 t per year for collections by call-off (50 % of collections). As the estimate was made based on the situation in major cities 

and at a time when metal prices were high, the estimated volume was conservatively classified in the category to 50,000 t/a. 

89 The volume of EEE stolen by waste collectors is estimated by [Janz et al 2009] using a different method at between 36,000 t and 122,000 t. 

As the volume estimation by [Janz et al 2009] was made against the background of material flows to Eastern Europe, it is assumed that these 

volumes were all exported. In our estimate of export volumes we assumed that only a part of the stolen volume is exported. Some is fed to the 

European scrap metal market. The relevant volumes in this study are therefore lower than the total volumes as only exports to the selected 

non-EU countries are considered.




Example of Wuppertal (switched to collection on a rota basis in 2000) 

“Similar to the development with bulky waste volumes, there was initially a dramatic rise in large electrical 

equipment with the introduction of road collections on a rota basis. While bulky waste volumes have since 

remained roughly the same, the number of white goods recorded has since fallen by two thirds.” (Note: 

See also Figure 30a and b).) “The reasons for this are that, due to the high scrap prices, the equipment is 

sometimes handed over by people to mobile scrap collectors, retailers also sell returned equipment to the 

scrap trade and “wild collections” are carried out before the bulky waste collection times. In addition, compressors 

were stolen from many of the refrigerators left with the bulky waste, (…).The huge rise of 30 % in 

the number of televisions and monitors disposed of is probably due to the increased switch to flat screens. 

The volume of small electrical equipment handed over continued to rise. This may be attributable to increased 

environmental awareness and a larger number of collection points” [Wuppertal 2006]. 

[Wuppertal waste balance 2006] 

Figure 30a and b: WEEE volumes recorded separately by the city of Wuppertal 

With regard to theft from refrigerators, it is estimated that in ca. 40 % of refrigerators left for collection, the 

compressors were removed and stolen.




6.2 Collection of scrap metal by commercial collectors 

Scrap metal is collected by commercial collectors of scrap from homes. In many cases, information 

is distributed to households stating that they can collect or buy metallic objects. “Scrap collectors” 

also collect equipment from traders. The higher the prices of raw materials, the greater 

the activity reported. 

Quantification: There is no information available on the number of scrap collectors and their 

turnover. [Janz et al 2009] roughly estimate that in areas close to the border in Eastern Germany 

between 0.4 kg and 1.5 kg per resident per year of in particular white goods were collected 

and exported by scrap dealers in 2008. If this value were extrapolated for the whole of 

Germany, according to this source volumes would be between 36,000 t/a and 122,000 t/a. For 

the investigated regions in Mecklenburg-Western Pomerania, Brandenburg, Saxony and Bavaria 

volumes between 2,000 t/a and 7,000 t/a were estimated. Also included in this are volumes 

stolen from bulky waste and volumes which are picked up by people outside recycling yards. 

As well as the number of commercial collectors and the volumes recorded per collector, it is 

also unclear what share of equipment collected is actually exported to Africa or Asia. It is assumed 

that equipment is only handed over to exporters if the purchase price paid by the exporters 

is above the material value of the equipment. 

Qualification: It tends to be equipment where the user no longer sees a value beyond the raw 

material value which is disposed of via scrap collectors. The quality of the equipment is normally 

poor to very poor. 

Price: The price of equipment collected is very low, often far below the metal market price for 

the Fe metal content of the equipment. 

6.3 Print media 

In Germany, ca. 1,300 free papers (titles) are published. Circulation was ca. 90 million copies in 

2008 [Federal Association of German free papers (BVDA)]. 

Free papers are normally financed by advertising revenue. The price of small ads is based on 

the number of columns and lines or the number of words and the circulation. A small ad for a 

used electrical equipment costs in most researched cases >10 € 90 . 

In particular equipment is offered when the owner is of the opinion that the equipment still has a 

value which justifies the cost of placing the advertisement. With the possibility of placing advertisements 

online, the cost has fallen here in recent years. A systematic evaluation of offer prices 

was not possible within the scope of this project. A survey conducted on behalf of eBay showed 

that comparatively few online advertisements were used for private sales 91 . 

Used electrical equipment is also offered in the advertising sections of newspapers (including 

regional editions > 1,000 titles), however obviously to a lesser extent than in free papers. Here 

too advertisements are increasingly being placed online. 

90 The range was between € 8 and € 22 (one column, 5 rows; or minimum number of words). 

91 Vgl. [http://www.ecc-handel.de/der_verkauf_ueber_online_-_auktionen_ist.php ].




The cost of procurement per appliance is considered by the potential exporter to be relatively 

high compared to the value of the product. While free papers and newspapers are obviously an 

important way for exporters to reach customers for used cars, this does not appear to be the 

case for electrical equipment. Online access to both newspapers and free papers is now possible 

almost everywhere. Sometimes an evaluation or filter function is provided for advertisements 

in the internet. This makes it much easier for the buyer to have access to the equipment. 

Quantification: The wide range of print media results even with a few advertisements per paper 

in a high total number of advertisements. With the weekly appearance of the advertisements 

and 10 advertisements per paper and edition, this produces a total number of 1.2 million advertisements 

per year. A success rate of 50 % for the advertisement would therefore result in 

600,000 sales per year. 

The total volume is estimated at around 10,000 t/a. 

Qualification: The quality of this equipment is considered better than that of the equipment 

which is collected by scrap collectors or via bulky waste. The lower quality limit is certainly also 

determined by the costs for an advertisement. 

Price: The range of prices for UEEE is very wide and at the upper end can reach those of new 

equipment. The lower end is certainly determined significantly by the price of the advertisement. 

If a factor of between 5 and 10 is assumed for the difference between the price of the equipment 

and the price of an advertisement, the lower end of the price scale is often between 

€ 50 and € 80. 

6.4 Flea markets 

Flea markets are stated by many exporters as a source for the exported equipment. 

There is no extensive information on the number of flea markets where electrical and electronic 

equipment is sold. 100 to 150 meetings per week are mentioned on relevant sites in the internet 

for Germany alone. It can be assumed that only the major flea markets are registered with such 

sites. 

Analyses on the relative importance of flea markets (compared to online trade, see below) show 

that online auctions are more popular than sales at traditional flea markets. In a survey conducted 

on behalf of eBay 70 % of the 1,004 people questioned stated that they had already sold 

something via an internet auction, while only 36.1 per cent used flea markets. 15.3 % had used 

an online advertisement 92 . 

At flea markets in particular small household appliances, consumer equipment and IT equipment 

are sold by private individuals. 

Quantification: As with the free papers, it can be assumed that there is a significant volume of 

sales of electrical and electronic equipment in flea markets due to their large number. The lower 

weight of the types of equipment sold compared to for example white goods results in a relatively 

lower mass (volume category I




With regard to the statement by exporters that they bought the goods at flea markets, it is assumed 

that they are mentioned as the source because there are no invoices or receipts at flea 

markets and therefore proof of purchase is not possible [pers.com. Bremen and Hamburg police]. 

Qualification: The quality of flea market equipment is also considered better than that of the 

equipment which is collected by scrap collectors or via bulky waste. However, the quality is often 

lower than the quality of equipment from print media. It is often equipment which is difficult 

to sell due to their age or condition. 

Price: The range of prices is probably much more limited than with online sales and it is assumed 

that equipment is also offered at a price of € 1. 

6.5 “Cascading values” 

In the event of “cascading values”, last users sell their equipment to second-hand retailers. 

These in turn sell such equipment which is otherwise unsalable to exporters. The number of 

small dealers is probably very high; however, precise numbers are not available. 

The quality of other equipment sold will cover the whole range of equipment for which there is 

no market in the region. 

As the other appliances sold are goods which cannot otherwise be sold in the region, very low 

prices are assumed. 

6.6 Recycling yards, first treatment operators 

The municipal collection points accept WEEE from private households. Traders can also deliver 

returns of WEEE by prior arrangement to the municipal receiving points. 

According to the official statistics [BMU 2008], in 2006 ca. 710,000 t of "business to consumer” 

(b2c) WEEE were collected via all collection routes (distributors, producers, municipal collection 

points). There is no data available on the volumes collected solely by the municipalities. 

Municipalities can treat or recycle waste themselves based on § 9 of the Electrical and Electronic 

Equipment Law (ElektroG). Figure 31(a-f) below reflect the changes in the number of municipalities 

which have opted for the respective collection group.




Collection group 1: Large household appliances 

Collection group 2: Cooling appliances




Collection group 3: IT equipment, consumer equipment 

Collection group 4: Gas discharge lamps 

Collection group 5: Small household appliances, lighting equipment, 

electrical and electronic tools, toys, leisure and sports equipment, 

medical devices, monitoring and control instruments 

[stiftung ear 2009] 

Figure 31 a to f: Number of municipalities which have opted for the respective collection group




It is not known what volumes are collected by the municipalities which have opted for the respective 

collection groups. This data is neither published by the “stiftung ear” nor centrally by 

the municipalities. 

Some producers of white goods 93 tend to get the contracted waste treatment company to recycle 

or dispose of the goods in collection group 1 and do not check the re-use in detail. It is also 

viewed as unlikely by some producers that significant volumes of white goods from the waste 

regime are exported outside of Europe for material recovery. The reason given is that the 

achievable prices for the raw materials (Fe fraction, NE fraction) result in domestic fractionation 

of the equipment. Collection group 2 is according to the producers primarily disposed of by the 

producers themselves as the costs of treatment are higher than the proceeds from the raw materials. 

For the volumes collected by this route according to some producers, the volumes disposed 

of and the treatment routes are monitored in detail [Welpotte 2009 pers.com]. For collection 

group 5, ca. 40 larger and several 100 smaller companies have found a joint treatment 

route. According to producers [Welpotte 2009 pers.com] economic drivers are making large 

waste treatment companies take the volumes relating to these contracts to their own treatment 

installations (use full capacity of the installations, long-term orientation of the business model of 

major waste treatment companies instead of short-term gains). 

The municipal collection points and first treatment operators also give equipment to re-use organisations. 

These may be specific re-use organisations (in the sense of chapter 6.7 below), 

other resellers for sale in Europe or exporters. The equipment has been handed over by the last 

users as waste to the waste regime. When the equipment is sold to exporters, they leave the 

waste regime. If they are given to resellers or exporters, a test has to have taken place, the result 

of which justifies their transfer from the waste regime to the product regime. 

We are aware of cases where cooling appliances and consumer equipment have been handed 

over by first treatment operators without a technical test to parties outside of the waste regime. 

While the suspicion has been expressed time and again that the volume here is significant, it 

was not possible to quantify or substantiate this in more detail. 

Electrical equipment is also sometimes collected by people outside of recycling yards; they ask 

those who are arriving for waste equipment. Here, too, information that is more detailed was not 

available. 

A more detailed investigation of the significance of the volume and the actual routes of the 

equipment was not possible within the scope of this research project. Information that is more 

detailed could be obtained with the help of the police (see also the recommendations in chapter 

9.2). 

6.7 Re-use organisations 

In contrast to professional re-marketing companies, the re-use organisations considered here 

often have both a socio-economic background (e.g. job-creation and training companies). End 

users hand over equipment which they still consider usable to these organisations. They also 

receive equipment from municipalities, businesses and authorities (replacement business) or 

93 This statement concerns ca. 60% of market participants.




actively collect equipment themselves (sometimes on behalf of the municipalities). The business 

models of these organisations vary greatly. 

Quantification: Within the scope of an expert survey and discussion in February 2009, estimates 

differed greatly. According to this, most re-use organisations do not export themselves 

and also do not knowingly hand over equipment to exporters who export equipment outside of 

the EU. The annual export volume of individual business to non-EU countries is very likely to be 

well below 5,000 t. 

Qualification: In most cases working equipment exported appear to go to destinations outside 

of the EU. However, an apparently small number of appliances are also exported which do not 

work, but can be repaired in the country of destination. 

Prices: The prices of the equipment sold range from “free” to prices which are offered by commercial 

re-marketing companies (see below). 

6.8 Waste transporters 

In expert interviews, it was pointed out that contracted transporters collect equipment from the 

municipal collection points and take them to the first treatment operator’s plant and that this 

treatment step is subject to inadequate monitoring. At the municipal collection points the container 

is collected as "full" (in accordance with the collection requirement) without the weight of 

the content being documented on an exit weighing machine (in most cases no weighing machine 

is available). On the way to the first treatment operator, where the containers are weighed 

on a weighing machine upon arrival, useable equipment would be separated. 

A more detailed investigation of the significance of the volume and the actual routes of the 

equipment was not possible within the scope of this research project. Information that is more 

detailed could be obtained with the help of the police (see also the recommendations in chapter 

9.2). 

6.9 Online auctions and trade – example of eBay 

In the internet, there are a large number of online trading platforms where used equipment has 

been offered and bought. The number of online auction platforms is estimated at between 150 

and 200. 

In the period between 1 January 2009 and 27 March 2009, the sales of used electrical and electronic 

equipment on eBay.de, by far the largest online auction platform, were followed and 

evaluated (see Table 24). In total approximately 100,000 sales 94 of the following types of products 

were evaluated: 

94 The exact number of appliances offered was 103,748.




• washing machines, 

• refrigerators, 

• televisions, 

• monitors, 

• personal computers, 

• printers. 

The sales rate 95 per equipment type without any further sub-categorisation was between 56 % 

and 77 % in the observation period. A much different picture is provided by the sub-categories 

“CRT monitors” and “CRT monitors faulty”, in which only 35 % and 6 % of the appliances respectively 

offered were actually sold (see also Table 24). 

Table 24: Selected used equipment traded on ebay.de between 01.01.2009 and 27.03.2009 

CRT 

and 

non- 

Television CLCP Monitor Printer 

of 

which 

Washing 

Only 

Only CRT 

machine Refrigerator CRT CRT All faulty CRT CRT faulty All Faulty 

Offered (number) 10,172 4,054 18,817 10,750 4,023 65 25,446 7,710 128 20,456 2,127 

Sales rate 71% 77% 70% 73% 64% 78% 56% 35% 6% 64% 61% 

The average price of the equipment per equipment types (without any sub-categorisation) was 

between € 44 and € 79 per item. 

CRT 

and 

non- 

95 The sales rate describes the relationship between the number of appliances sold and the number of appliances offered.




100% 

90% 

80% 

70% 

60% 

50% 

40% 

30% 

20% 

10% 

% 

Washing Washing machines machines 

Refrigerators 

Refrigerators 

Televisions Televisions general general 

CRT CRT TVs TVs 

Personal Personal computers computers general general 

Personal Personal computers computers faulty faulty 

Monitors Monitors general general 

Monitors Monitors CRT CRT 

Monitors Monitors CRT CRT faulty faulty 

Printers Printers general general 

Printers Printers faulty faulty 

Figure 32: Price distribution of selected used equipment traded on ebay.de (1. 1. 2009 and 27. 3. 2009) 

>50 (€) 

10.01 – 50.00 (€) 

5.01 – 10.00 (€) 

1.01 – 5.00 (€) 

0.01 – 1.00 (€) 

The analysis of the number of equipment sold per price category (see Figure 32) shows that 

most of the appliances were sold at prices between € 10 and € 50 and over € 50 (ca. 31,000 in 

each category). In the price categories € 0.01 to € 1 and € 1 to € 5 ca. 7,000 equipment was 

sold in each category. 

Shipping charges and the costs for self-collection have to be added to the prices. 

The observation period covers approximately a quarter of the year. The investigation of sales 

figures and average prices over a period of two years shows that, averaged over a year, in most 

cases there were relatively low fluctuations in sales figures and prices. 

Extrapolated for the whole year, 323,000 appliances of the selected product types were sold on 

ebay.de. The distribution of appliances sold is shown in the following Table 25.




Table 25: Price distribution of selected used equipment traded on ebay.de 96 

Price category 

0.01 – 1.00 (€) 

Number of appliances sold 

26,784 

1.01 – 5.00 (€) 28,952 

5.01 – 10.00 (€) 18,244 

10.01 – 50.00 (€) 124,644 

>50 (€) 124,276 

Quantification: Overall, online trading platforms such as e-bay sell a large number of appliances. 

While the volume potential with free papers is created by the large number of papers, 

most sales per “marketplace” are made with a relatively small number of large online trading 

platforms. The large number of smaller online trading platforms also has to be taken into account. 

The volume is therefore estimated to be in volume category II (10,000 t – 50,000 t). 

Qualification: The quality of the equipment ranges from new equipment with tiny visual defects 

to faulty waste equipment. Approximately 20 % of sales are made in the lower quality levels in 

the price range between € 0.01 and € 5. 

Faulty equipment is seemingly not easy to sell via the auctions, but they are still offered. It is not 

known how many appliances are still traded post-auction after they have not been sold on eBay. 

Price: The entire range of prices from (almost) new equipment to the symbolic price of € 1 is 

seen. Most of the prices are between € 10 and € 50. 

6.10 Re-marketing companies 

Re-marketing companies take equipment from various commercial sectors and authorities. The 

type and origin of the equipment varies, e.g. remaining stock of new products, returns (e.g. 

guarantee cases), batches which are not for domestic sale and used equipment from replacement 

business (deliver new equipment, take away used equipment). 

Many of these re-marketing companies sell not only to the commercial sector, they also have 

branches or sub-units which sell equipment to private customers. Many re-marketing companies 

also offer support for exports, e.g. with customs formalities or with packing of equipment into 

sea containers. 

The exporting of used equipment is often an important part of their business strategy. The 

goods are of varying quality levels, from as good as new to faulty. Sales for export are made by 

the pallet. These often contain a mixture of different qualities, including faulty or non-tested 

equipment. Re-marketing companies also prepare all of the export documents required and 

provide export advice. 

It is difficult to estimate the number of re-marketing companies. It is assumed that there are up 

to one hundred companies operating in the market. 

96 Extrapolated for one year based on the monitoring of one quarter.




Quantification: Due to the relatively large volumes per re-marketing company, 97 volumes in 

volume category III (>50,000 t) are expected. 

Qualification: The quality of the equipment ranges from new equipment with tiny visual defects 

to faulty old equipment. 

Price: The entire range of prices from (almost) new equipment to the (symbolic) price of € 1 is 

seen. 

6.11 Hand-over to retailers – private sector 

The Electrical and Electronic Equipment Law (ElektroG) requires retailers to take back equipment 

from end users free of charge. Unrelated to this, appliances are also handed over to traders 

outside of the waste regime. It is often difficult to differentiate between the two types of returns. 

It is assumed that lower volumes of information technology and consumer equipment (IT 

and CE) are handed over to retailers than volumes of white goods. With the category IT and CE 

the old equipment is often stored temporarily after the new equipment has been purchased before 

being disposed of. [Trend Büro 2008] estimates on the basis of a survey for example that 

“3.7 million old PCs and countless hard drives” and more than 12 million old mobile phones are 

not disposed of directly after their utilisation phase. The routes of treatment, when they are 

eventually disposed of, are more often municipal hand-over points or online sales. 

In the case of distance trading (e.g. via the internet) it is normally assumed that the share of returns 

is lower than is the case with delivery by local traders. Distance trading has been continually 

gaining in market share for years. While the overall share of distance trading in total purchases 

per household was only 11.4 % in 2002, it rose in 2006 to 12.4 % [GFK Universal panel 

Non-Food 2007]. There were distinct differences between the product groups. In the segment 

Computer/CE/Photo/Telecommunications the share of distance trading in the total expenditure 

of a German household rose from 14 % in 2004 to 17.6 % in 2006 [GFK Universal panel Non- 

Food 2007. With large and small electrical appliances the share fell from 17.6 % to 17 % [GFK 

Universal panel Non-Food 2007]. However, only 5.7 % of flat screen televisions were bought via 

distance trading [GFK Panel service 2007]. 

It is not known how high the volume of returns is for distance traders. 

Quantification: The equipment taken back by traders or handed over to traders is not normally 

re-sold directly, but are instead passed or sold on to professional resellers. The volumes passing 

through this route have already been taken into account in the respective chapters above. 

Qualification: In terms of quality the equipment taken back probably cover a very wide range. 

Compared to areas where the last user tries to sell the equipment (internet, newspapers, etc.), 

in the case of goods being taken back free of charge this involves more often non-working appliances. 

97 One company stated an average of up to half a million units per year, another stated that it exported over 100,000 units per year from the IT 

sector alone.




Price: The equipment is taken back free of charge and the retailer normally does not pay for the 

equipment. The owner of the old equipment is often charged for the cost of transport. The resale 

price covers the whole range of quality levels taken back. 

6.12 Economic aspects 

An extensive economic analysis was not possible within the scope of this study. A few relevant 

economic aspects which have become clear during the research are described here however. 

An important basic condition for continued exports is that as a minimum the transport costs 

have to be covered. In 2008 the price offered for the full logistics for a container to West Africa 

(e.g. delivery of the sea container to a collection point, collection of the container after three 

days and transport to the shipping location, loading, shipping, unloading) approximately 

€ 1,500 per 40 foot sea container. 

The costs in the country of destination for the stand or shack in the market and for the sale of 

the appliances in the market were not communicated. There is also no detailed information on 

the import costs in the country of destination (customs, where applicable destination inspection, 

etc.) and the personnel costs of the exporters. 

The inspections of the contents of containers as part of export controls showed that in most 

cases there was a mixture of appliances of all characteristic profiles A to G (see chapter 4.9). 

As a result, this means that a wide range of prices is possible for all appliances due to the 

mixed calculation. With the estimation of transport costs it is assumed here for reasons of simplification 

that only one type of appliance is transported in the container 98 . On average with 

space-efficient stowage approximately 900 CRT monitors, 2,000 PCs, 100 refrigerators or 2,800 

CD/DVD players can be packed into a container. 

Table 26 below shows the market prices in Nigeria for selected appliances of a low or very low 

quality (utilisation profiles D2 to G) against the calculated logistics costs. 

With a range of appliances such as CRT it also has to be considered when looking at economic 

factors that the treatment of a CRT monitor in Germany costs between € 3 and € 4 and these 

costs are saved by exporting them. This represents an additional economic driver for low-quality 

appliances. As the demand for CRT monitors has fallen dramatically in Germany and there are 

a lot of CRTs waiting for treatment after being replaced by flat screens, the price for used appliances 

is currently very low (including used appliances which still work). With other appliances, 

fluctuating raw materials prices mean that sometimes profits can be achieved from treatment in 

Germany, and sometimes not. 

98 This is though actually only the case in a few containers which are relevant in the context of this project.




Table 26: Price structure for the acquisition of appliances in Germany (estimate) 

Ø market price 

in Nigeria 

Utilisation profiles 

D2 to G 

(see chapter 

4.9) 

CRT 

monitor 

Scenario A (low prices) Scenario B (high prices) 

PC CRT TV Refrigerator 

VCD 

player 

CRT 

monitor 

PC CRT TV Refrigerator 

VCD 

player 

€ 11.30 € 30.12 € 15.06 € 35.14 € 4.52 € 22.59 € 67.77 € 28.87 € 47.69 € 12.55 

Logistics € 1.60 € 0.66 € 2.25 € 12.92 € 0.53 € 1.60 € 0.66 € 2.25 € 12.92 € 0.53 

On average a CRT monitor contains approximately 700 g of copper [UNU 2007]. Although 

wholesale prices occasionally reached well above € 5/kg in 2008 and an average price level of 

€ 2/kg to € 2.50/kg can be assumed over several years, much lower prices are achieved with 

small volumes in the informal sector in West Africa (ca. € 0.50/CRT). Profits from the informal 

sector for other components (e.g. steel, platinum, etc.) can roughly be estimated at € 0.20/CRT. 

There are no costs for the final disposal of the non-recyclable material. 

With some types of appliances profits from the sale of fractions play a greater role (e.g. white 

goods, PCs), and with others profits from the sale of components (e.g. IT appliances). 

For the cost situation in Germany research has shown that a distinction can be made between 

two different situations: 

• For appliances with treatment costs, such as CRT monitors, exporting saves treatment 

costs. This saving is made if the appliance was once in the German system for the 

treatment of waste electrical equipment and as a result treatment costs have been incurred 

by those who are financially responsible for the waste treatment (the producers 

in terms of the Electrical and Electronic Equipment Law (ElektroG), unless the material 

comes from the area of an opting municipality) 99 . 

• Appliances with treatment profits (such as washing machines) are primarily collected 

by traders or exporters before they reach the German system for the treatment of waste 

electrical equipment or before they are handed over to first treatment operators. Potential 

profits from the raw materials can therefore not be achieved by those responsible for 

the product in accordance with the ElektroG. 

If, for example, half of the treatment costs saved with CRT monitors are passed on to the exporters, 

after transport costs have been deducted this would leave a profit of € 0.50 to € 1 per 

non-working appliance. 

6.13 Summary 

Table 27 below summarises the results of the investigation concerning the quantification, qualification, 

prices and costs for procuring appliances by exporters. 

99 We do not assume though that the waste treatment costs saved are passed on 1:1 to the exporters.




With regard to developing recommendations to improve the control of the flow of materials, the 

number of possible intervention points is also relevant. This is shown by a breakdown into the 

following categories: 

• Category I: 1 to 10 intervention points, 

• Category II: 11 to 100 intervention points, 

• Category III: 101 to 1000 intervention points, 

• Category IV: >1000 intervention points. 

Table 27: Export relevance of different areas of origin 

Area of origin Main equipment 

groups 

Pilferage of bulky 

waste collection 

White goods, brown 

goods, small domestic 

appliances, Information 

Technology 

(IT), consumer electronics 

(CE) 

Scrap collection White goods, brown 

goods 

Quantifying 

quantity class1 II (highly erratic, depending 

on the level of 

the metal prices) 

II to III (highly erratic, 

depending on the level 

of the metal prices) 

Qualification 2 Price 3 Outlay for 

acquisition 4 

Number of intervention 

points 5 

3 3 2 IV 

II (Information for the 

public) 

3 3 2 IV 

II (Information to 

public) 

Classified ads in print All I 2 2 1 II (Information to 

media 

public) 

Flea markets Small domestic ap- I 2-3 2-3 1 IV 

pliances, IT, tele- 

II (Information to 

communication (TC), 

CE 

public) 

Value cascades Small domestic appliances, 

IT, TC, CE 

I to II 2 - 3 3 3 III 

Recycling centres, White goods, brown No details 2 - 3 3 2 IV 

First treatment com- goods, small domespanytic 

appliances, IT, CE 

Re-use- 

White goods, brown I 2 

organisations 

goods, small domestic 

appliances, IT, CE 

6 3 3 II 

Waste transporter No details No details No details No 

details 

2 IV 

Online advertisements/ All II 2 – 3 

auction houses 

7 1 - 3 3 II (Information to 

public) 

Re-marketing-firms9 White goods, brown 

goods, IT, CE 

III 2 – 38 2-3 3 III 

Handing over to trade Primarily white III (already taken into 2 – 3 2 – 3 3 II 

– private area 

goods, less CE and account with re- 

IT 

marketing firms) 

1 3-stage scaling; quantity classes I: 50,000 t/a to 100,000 t/a; the estimate of quantity relates to the 

total quantity from the respective area of origin. The actual amounts exported into countries in Africa and Asia are a subset there from. 

2 3-stage scaling; 1 = high value product profiles A and B, 2 = medium quality product profiles C and D1, 3 = low quality product profiles D2 to G 

3 3-stage scaling; 1 = high price, 2 = medium price, 3 = low price to free of charge 

4 3-stage scaling; 1 = high, 2 = medium outlay, 3 = low 

5 4-stage scaling; I = 1 to 10 intervention points, II = 11 to 100 intervention points, III = 101 to 1000 intervention points, IV = >1000 intervention 

points. 

6 Although non-functioning equipment is exported from re-use organisations, the quantities are, however, smaller than the quantities of equipment 

which are processed or repaired by the re-use organisations. 

7 This takes into account that non-functioning equipment is also offered (often as equipment “for hobbyists”). 

8 The commercial resellers take over a large part of the equipment from take back of used equipment from private customers through retailer, for 

example when the retailer supplies new equipment.




The financing of exports is determined through a series of factors. In the countries of destination, 

functional equipment and components are traded at higher prices than would be the case 

in Germany. The transport itself is relatively inexpensive. Often a mixed financing takes place 

via functional equipment, equipment which is used as source of spare parts and via equipment 

which will no longer be employed and used either for production of raw materials or treated immediately. 

A financing of exports exclusively on the basis for raw material appears improbable. 

For a CRT monitor, in countries such as Nigeria, less than € 1 is realised, the transport, however, 

costs significantly more than € 1. Equipment with a high recyclable fraction (e.g. washing 

machines and also PCs) with an exclusively resource-based financing of the export, the difference 

from the revenues in Germany and in the country of destination must act as economic 

driver of the export. This, however, is probably not the case. Continuing to be effective are costs 

saved for the treatment of non-recyclable fractions and the lower costs of the separation of the 

fractions in the countries of destination. 

Furthermore, it is to be noted that a cross-financing with some types of equipment via treatment 

costs saved probably takes place (e.g. CRT screens). The costs are saved if the equipment was 

to be collected in accordance with the ElektroG and the waste management company does not 

pass lower costs to the (financially responsible) producer who already paid for treatment. Herein 

the types of equipment with treatment costs (e.g. CRT screens) differentiate themselves from 

the equipment types with revenues from treatment (e.g. washing machines). The latter do 

probably not arrive frequently in the collection system in accordance with the ElektroG but 

rather are captured for export.




7 Export monitoring 

Both the sources of UEEE and the collection points where sea containers are loaded for shipping 

are found in various federal states in Germany. The states therefore have in practice a 

monitoring and control function, which in the cases of Hamburg and Bremen, because they are 

export ports, is extended by a (central) control function in the ports. 

This chapter describes the essential points of the situation in some federal states. 

7.1 Hamburg 

7.1.1 Office for Urban Development and Environment 

Hamburg’s Office for Urban Development and Environment (BSU) employs 4 full-time people in 

the area of waste shipment who, among other things, process ca. 200 notification procedures a 

year. As well as processing notification procedures, the BSU is also responsible for controlling 

waste shipments and coordinating suspected cases of illegal waste shipments which are reported 

by the inspection authorities. 

In Hamburg a total of 102 suspected cases of illegal waste shipments detected during inspections 

were reported to the BSU by the police and customs in 2008. 45 suspected cases relate to 

electrical and electronic equipment (29 inspections of cooling appliances, 15 of monitors or 

used televisions). In 22 cases the appliances came from Hamburg, in the remaining cases the 

appliances came from other federal states or European countries such as Finland and Norway. 

Nigeria, the Ivory Coast, Malaysia, Egypt, Hong Kong and Togo were stated as countries of 

destination for used electrical and electronic equipment. Due to data protection reasons no further 

details on exporters were given. 

In order to bundle information better, the BSU and the police are in agreement that the BSU initiates 

and controls the communication with the appropriate state authorities. 

Under the direction of the BSU information and experience has been exchanged since the start 

of 2007 between the inspection authorities (customs and police) and the BSU on a regular (halfyearly) 

basis in order to continually optimise and adapt enforcement to the actual circumstances. 

The BSU does not have access to the ZAPP system of Dakosy AG or the ATLAS system of 

customs.




The BSU considers the following open questions for enforcement to be important for its control 

activities: 

• How can it be proved in a legally watertight manner that the appliances are nonrepairable? 

• What packaging/packaging method actually maintains the value of the shipment and how 

can it be proven that it does not maintain the value? 

• How should the appliance-specific information, which the Correspondents' Guidelines 

recommend, be checked and what cost is reasonable here? 

The BSU has prepared a matrix which provides an overview of the indications of the product 

and waste characteristics of appliances for export which are easy to detect. After an evaluation 

phase the matrix was revised and is now being used in the revised version. 

7.1.2 Police 

Hamburg’s police is responsible for inspecting cross-border waste shipments in Hamburg and 

carries out appropriate inspections with regard to the export of suspected waste electrical 

equipment. 

The police has access to the ZAPP system and can identify with the use of police records containers 

which appear to be suspicious with regard to the export of used electrical equipment. 

According to the Correspondents' Guidelines, the exporter has to have performed a function test 

on the appliances and also be able to document this. In spite of this, non-working appliances 

are found time and again during spot checks. The exporters then normally state that the appliances 

will be repaired in the countries of destination and that these repairs will be done with 

new parts. They state that they do not cannibalise the appliances (cannibalisation would establish 

the waste characteristic of the appliances). It is difficult to disprove this within the scope of 

the waste transport inspection. In the opinion of the authority responsible in Hamburg, the BSU, 

the question of whether the appliances can be repaired at an economically viable cost is to be 

assessed in accordance with the prevailing standards in the countries of destination. 

A peculiarity for the instigation of criminal proceedings is that the legally relevant assessment of 

whether the appliances are waste electrical and electronic equipment in terms of the Electrical 

and Electronic Equipment Law (ElektroG) or are used electrical and electronic equipment is the 

responsibility of the administrative authority and in this respect this decision has a direct influence 

on whether the matter will be prosecuted as a criminal offence or not. Criminal proceedings 

are regularly not pursued when the administrative authority, after establishing the facts under 

administrative law, refuses to recognise the term waste. 

In this context, there have in the opinion of the interview partner been different views of the export 

situation in the past. In the view of the police a clear framework for distinguishing between 

waste and product, e.g. the Correspondents' Guidelines being legally binding, would be helpful 

for dealing with this situation in future. 

In the meantime, cooperation between the police and the BSU has further intensified and improved.




7.1.3 Customs 

Exports via the Port of Hamburg are recorded electronically either in the ZAPP or ATLAS-HH 

system. 

This data is only available to customs for the last three months. Data which is one year old can 

only be obtained from the computer centre of the Federal Finance Administration (ZIVIT 100 ) at a 

cost. Customs only has very limited access to the resources of ZIVIT through a framework 

agreement. 

The data in the ATLAS system is subject to tax secrecy and the customs administration is 

bound by this; other authorities are therefore not allowed to have general access to customs 

data [BMF 2009]. 

The data in the ZAPP system is only available for 6 months and is archived for 12 months, it is 

therefore possible to search over 18 months. 

The amended Correspondents' Guidelines No. 1 are available to all customs office via the Intranet 

[pers. com. Federal Finance Office South East]. 

7.2 Bremen 

7.2.1 Bremen Environment Office 

At the Bremen Environment Office around 120 notification procedures were processed by one 

full-time person 101 in 2007. To date there have been three suspected cases concerning refrigerators. 

The Environment Office stated that they are getting on well with the amended Correspondents' 

Guidelines No. 1. The Environment Office experiences difficulties in that it bears the burden of 

proof before the courts, that the reverse processing of a shipment is not clearly regulated and 

the Office can potentially incur costs. 

7.2.2 Bremen Police 

According to the Bremen Police it is not known that UEEE/WEEE is exported by parties with a 

high degree of organisation. Instead, they are normally individual persons or small groups. 

Mainly televisions, hi-fi systems, car radios and CD players were collected and exported. It was 

estimated that around 60-100 containers are shipped per year from Bremen via Hamburg 

mostly to Nigeria, Ghana, Benin and the Ivory Coast. The respective hirers of the consolidated 

containers state that they have acquired the appliances from flea markets, from collecting bulky 

waste and from electrical repair businesses. 

The police in Bremen has no access to the databases which comprise goods codes, unlike the 

Hamburg Police. It inspects the collection and packing points in Bremen for potentially illegal activities. 

100 Centre for Information Processing and Information Technology, see http://www.zoll.de/dienststverz/dvz_sonst_zivit/index.html. 

101 Zusätzlich gibt es noch eine halbe Stelle, die sich hauptsächlich um die Datenerfassung kümmert.




The police’s lack of decision-making authority in suspected cases was stated as a difficulty. It is 

also very difficult for a state authority to decide as an administrative authority in cases which are 

not clear. There was a risk that the state authority would have to bear costs if a shipment were 

prevented, only for it to be decided later that it is allowed to be exported. There was also one 

case where the costs of treatment and storage had to be borne by the authority because the 

exporter was no longer within reach. 

In the view of the Bremen Police the consistent application of the amended Correspondents' 

Guidelines No. 1 would be an effective tool which would greatly reduce the export flows of lowquality 

appliances. 

The activities of the IMPEL 102 -Seaport TFS 103 project, which intends to standardise practices in 

ports, was considered very helpful and sensible and should be continued in order to have a 

European-wide standard guideline concerning the export of UEEE/WEEE to non-EU countries. 

It was also stated that networking in Germany would also make sense as there are considerable 

differences in decision-making practice in the federal states. 

7.3 North Rhine-Westphalia - District Government of Düsseldorf 

The District Government of Düsseldorf had 8 suspected cases of illegal waste shipment in 2008 

which were reported by the customs offices in Antwerp and Rotterdam. It is estimated though 

that the number of unreported cases is a lot higher. Exports travel mainly via Rotterdam and 

Antwerp. 

In one case the District Government ordered the recall of a container from Rotterdam. The content 

of the container had been stated as used televisions, the actual contents though were ironing 

boards, computers and other objects. There was no outer packaging. The amended Correspondents' 

Guidelines were consulted when making the decision. An appeal was made against 

the recall order. However, the District Government won in the first instance and also considers 

its chances to be good before the Upper Administrative Court (OVG) in Münster. It has already 

won another case. However, it was noted that the cost in terms of time of such recall orders and 

the potential legal consequences were considerable. 

Suspected cases are always reported by the customs offices in Antwerp or Rotterdam. The appliances 

which are exported come according to the District Government of Düsseldorf from 

points which are established before municipal collection points and used car sites, as well as 

from flea markets and stealing from bulky waste. The District Government is not aware of any 

cases in which appliances are exported after being handed over to municipal collection points. 

It was noted that the inspection activities which were carried out together with the IMPEL-TFS 

network were helpful and that they should be continued. The national cooperation between the 

Federal Office for the Transport of Goods, customs and the police should be further intensified. 

102 Implementation and Enforcement of Environmental Law. 

103 Transfrontier Shipment of waste; one of the goals of the project is to harmonise activities in ports.




7.4 Federal Office for the Transport of Goods 

The Federal Office for the Transport of Goods (BAG) is an independent federal authority in the 

Federal Ministry of Transport, Building and Urban Affairs. It watches over among others the 

transportation of waste by vehicles for road freight 104 . The BAG’s inspections are carried out on 

motorways, federal and state roads in part undertaken in cooperation with the police and other 

supervisory authorities 105 . 

It is difficult for the BAG to gain an overall picture on this topic as the individual state authorities 

have different views on what is waste and what is not. More uniform decision-making by the authorities 

involved would according to the BAG make sense as it essentially always decides on a 

case-by-case basis whether it temporarily prevents a stopped shipment of electrical equipment 

which is suspected of being waste from continuing its journey in order to inform the responsible 

authorities. The amended Correspondents' Guidelines No. 1 are used by the BAG. Statistics are 

not recorded on non-compliant transport relating to electrical equipment, however UEEE/WEEE 

have in the past been the subject of waste inspections by the BAG’s road inspection service 

time and again [BAG pers. com. 2009]. 

7.5 Criminal Police Offices 

The Federal Criminal Police Office (BKA) has replied in writing to a questionnaire. 

According to the BKA in the period between 2004 and 2008 a total of 27 suspected cases relating 

to the export of UEEE/WEEE were registered in which the state police instigated preliminary 

proceedings in accordance with § 326 para. 2 of the Penal Code (StGB) (illegal handling of 

hazardous waste). The majority of the preliminary proceedings were instigated by the police 

(Water Protection Police) in Hamburg and Bremen. The actual number of preliminary proceedings 

may be higher though as the BKA is not informed in every case. 

Police waste transport inspections to gather evidence were identified as crucial for enabling 

proceedings. 

The probing and carrying out of targeted inspections is in the opinion of the BKA helped by cooperation 

between police and customs authorities. 

The current legal uncertainty in administrative enforcement relating to the difference between 

UEEE and WEEE has proven to be a hindrance to instigating criminal proceedings 106 . 

There would be more legal certainty if existing legal regulations (e.g. the Electrical and Electronic 

Equipment Act) were amended with certain content (here in particular the criteria for differentiating 

between used electrical and electronic equipment and waste electrical and electronic 

equipment) of the Correspondents' Guidelines No.1. This would also strengthen enforcement 

and the fight against illegal practices. 

The BKA stresses the need for sufficient and available government resources as a requirement 

for enforcement and the fight against illegal practices. 

104 Road Haulage Act (Güterkraftverkehrsgesetz) § 11 para. 2 letter j. 

105 Kropp, O., “Zuständigkeiten und Vorgehensweise bei der Kontrolle grenzüberschreitender Abfalltransporte” (Responsibilities and procedures 

for controlling cross-border waste transport) Mainz. UPR 6/2008. 

106 Apart from cooling appliances containing CFCs.




It was stated that the ATLAS and ZAPP systems would enable improved detection and inspection 

of loads possibly containing WEEE as they enable access to certain export data. 

In a range of detailed questions the state police forces were referred to. 

According to the BKA’s public relations department its goals for 2009 involved focusing on 

“shipments of waste electrical equipment” and it has been actively participating in Interpol’s current 

"e-waste" project since the end of 2008. 

8 Recovery of raw materials 

8.1 Exported raw materials volumes 

Due to the current uncertainty of the data, different variants of exported material flows have 

been calculated. Data uncertainty was considered at two levels: 

• Total exported volumes: a minimum volume of 93,000 t, a maximum volume of 

216,000 t and a weighted average volume of 155,000 t were included in the calculations. 

• Exported appliance mix: the share of exported small appliances tends to be underestimated. 

Therefore, in addition to the appliance mix in accordance with customs registrations, 

an appliance mix with an increased share of small appliances was considered in 

the calculations. 

Table 28 summarises the variants. 

Table 28: Variants of material flow calculations 

Variant Sub-variant Total exported volume 

CRT share 

Appliance mix 

Share of small appliances and PCs 

1 

1 

2 

High 

High 

Slightly less 

Low 

Increased 

2 

1 

2 

Low 

High 

Slightly less 

Low 

Increased 

3 1 Average Average Average 

Based on these variants, this results in (see Figure 33) an export volume (weighted average) of 

37,000 t for steel (range between 18,000 t and 61,000 t), 65,000 t for CRT glass (range between 

35,000 t and 81,000 t) and 23,000 t for plastic (range between 13,000 t and 33,000 t).




90000 

80000 

70000 

60000 

50000 

40000 

30000 

20000 

10000 

0 

Steel Copper Aluminium Plastic Glass (CRT) Printed 

circuit 

boards 

Figure 33: Range diagram of exported materials (figures in t for 2008) 

Due to the limited availability of data on precious metal contents in the various appliance types, 

the representation of gold, silver and palladium is limited (see Figure 34). The exported precious 

metal volumes were calculated at ca. 1.6 t for silver (range between 0.5 t and 3.3 t), 300 kg for 

gold (range between 0.1 t and 0.6 t) and 120 kg for palladium (range between 0.05 t and 0.2 t). 

4 

3 

2 

1 

0 

Ag Au Pd 

Figure 34: Range diagram of exported precious metals (figures in t for 2008) 

Based on precious metal prices in the first quarter of 2008 the value of exported precious metal 

is ca. € 9 million (range between € 3 million and € 17 million). 

For materials with particular environmental relevance (apart from the above-mentioned CRT 

glass), the volumes were 22 kg for batteries (range between 7 kg and 47 kg) and 90 kg for mercury 

(range between 20 kg and 190 kg) (data base [UNU 2007]). 

Others




8.2 Recovery of raw materials 

Under ideal market conditions, i.e. with the effects of market forces in the areas in which the 

electrical/electronic equipment is handled in the countries of destination, it can be assumed that 

mass-relevant raw materials with relatively good purity can be reclaimed for recycling. This applies, 

for example, for steel and copper and, to a limited extent, aluminium (the recycling of the 

latter is dependent on whether it is identified and whether sufficient quantities are yielded in order 

to carry out separation). 

For ca. three quarters of the exported quantities it can be assumed that the lacking waste management 

infrastructure leads to the final disposal of materials (often on unsuitable areas). The 

inadequate possibilities for final disposal, primarily with batteries and accumulators, mercury 

switches, capacitors and oils, lead to direct environmental effects. 

No analysis is available regarding the reclamation rates for precious metals and rare earths in 

the countries of destination. Based on analysis in Bangalore and treatment processes applied in 

Asia it can be assumed according to [Hagelüken 2009] that reclamation rates for gold of 25 % 

are achieved when printed circuit boards are treated in simple processes. Palladium, rare metals, 

lead and nickel will be lost. According to this basis it can be estimated that ca. 240 kg gold 

(ranges from 90 kg to 458 kg) and 120 kg palladium (ranges from 50 kg to 230 kg) are lost in 

the countries of destination. If similar reclamation rates are applied for silver as done for gold it 

can be estimated that 1.2 t of silver would be lost (ranges from 353 kg to 2,445 kg). 

It has to be noted that this calculation model assumes that the equipment is actually collected in 

the countries of destination and that market forces in the regions ensure that (limited) reclamation 

possibilities are applied. To what extent this is actually the case is not known exactly and 

would require investigations in those countries.




9 Measures/options 

In discussions with the parties involved, measures were developed which can contribute towards 

optimising the control and inspection of transboundary shipment of electrical equipment. 

The measures are influenced or determined among other things by there being no treatment facilities 

available in the countries of destination considered with a protection level which the 

European member states consider to be minimum standards for themselves. The analysis of 

the situation in the countries of destination reveals the necessity to effectively ensure in practice 

that only appliance qualities which are according to the definition of the Waste Framework Directive 

107 (article 3) re-usable without further preparation and meet the requirements of the Correspondents' 

Guidelines for products are exported under the product regime (appliance categories 

A to D1 in accordance with chapter 4.9). 

The measures are described in chapters 9.1 to 9.4 and summarised in Table 29 108 . 

9.1 Statistics and data 

The evaluation of statistics and databases has shown that meaningful information on the export 

of used electrical and electronic equipment of the characteristic profiles D2 to G (see chapter 

4.9) can only be prepared with a lot of time and effort, if at all. 

In order to improve information from the further monitoring of the development of exports of 

such appliances, evaluation routines for the export databases should be developed and 

implemented in order to simplify/enable the monitoring (Measure 1a) 109 . The waste monitoring 

authorities (where applicable also those of other federal states other than Hamburg) 

should have easier access to export data in order to allow volume developments to 

be monitored (Measure 1b). In this context it should be ensured on a permanent basis that 

the police has access to the export databases (Measure 1c). 

The Federal Ministry of Finance (BMF) should initiate appropriate data retention requirements 

and evaluation routines. 

The time horizon for the initiation of the measure should be in the short term. 

In relation to this, a differentiation in the statistics between new and used appliances is important. 

This differentiation is currently achieved using criteria of limited reliability (exporter’s state- 

107 Directive 2008/98/EC of the European Parliament and Council of the 19.11.2008 on waste and repealing certain directives, Official Journal L 

312 of the 22.11.2008, p. 3. 

108 The numbers of the measures stated in the text are in accordance with Table 30. 

109 The exports should without exception be classified in the specified value categories (see also chapter 2) in order to include the indicator “value 

of exported goods” in the monitoring. 

A full account of the volumes in the DESTATIS data including below certain value limits would provide important information on the exporting 

of goods in the grey area between waste and product.




ment on price per registration 110 ). European statistics should differentiate for relevant exported 

appliance types such as monitors, televisions, refrigerators between new and 

used appliances by introducing appropriate codes in the combined nomenclature (Measure 

1d). The agreement of all countries participating in the Harmonised System (HS) (see chapter 

3) would take a lot of time (if an agreement could be achieved at all), as there is also a goal 

to reduce the total number of goods codes. Differentiation at the level of the combined nomenclature 

of the EU appears to be enough to address the problem of exports from Europe. 

Worldwide harmonisation is recommended as a longer-term prospect. 

The possibility of seizing the initiative to implement this measure is considered most likely with 

the UBA or BMU in cooperation with the BMF. Implementation of this measure should be 

started in the short term. It has to be assumed though that it will take several years until it is 

really applied. 

9.2 Sources of exported equipment 

Overall, it was seen that the exported appliances of the profiles D2 to G (see chapter 4.9) come 

from a large number of sources. There is not one major source which, if regulated, would result 

in most of the exported appliances of the profiles D2 to G being covered. 

It appears that theft from bulky waste and the collection of electrical and electronic equipment 

by scrap collectors can only be controlled to a limited extent by local inspections by regulatory 

authorities. Such inspections are also associated with relatively high cost. It therefore appears 

to make sense to as far as possible change the collection of appliances from the roadside 

and in a manner which provides protection against theft (collection, hand-over by last 

owner) (Measure 2a). In relation to the collection of bulky waste but also with regard to the collection 

of appliances by scrap collectors, the public should be given more information (also 

by media) on the risks relating to inappropriate treatment and to their own role in relation 

to the export of waste electrical and electronic equipment and the negative consequences 

of this (Measure 2b). 

Here the UBA should seek to cooperate with the municipalities or the VKS in the VKU and initiate 

public campaigns and changes in collection. The UBA can also initiate public relations activities 

with institutions which perform public relations within the scope of implementing the Electrical 

and Electronic Equipment Law (ElektroG). 

The measures can be initiated in the short term. 

It also appears with regard to appliances which are traded via print media and at flea markets 

that the most likely way to reduce the number of appliances with the profiles D2 to G being sold 

to export-relevant routes is by providing the public with targeted information. However, it will be 

very important here to provide the last users with a specific alternative in the public relations 

message. Awareness that the appliances can still have a use plays an important role in particular 

with sales at flea markets. The communication of contacts at qualified re-use organisations 

110 There are a couple of uncertainties involved when evaluating the database based on prices. First of all the stating of prices of exported goods 

has repercussions under customs law, and secondly the prices refer to individual registrations. It is not possible to clearly deduce the unit 

prices of the appliances exported from this.




may make sense here. A list of such re-use organisations should be developed by the offices 

responsible for public relations. 

Providing the public with information and the link to the situation in the countries of destination is 

also considered an important measure with regard to online trading. Particularly with the major 

trading platforms such as eBay, this should be done in cooperation with the operators. 

The UBA should also initiate public relations activities here with institutions which perform public 

relations within the scope of implementing the Electrical and Electronic Equipment Law (ElektroG). 

Many producers of electrical and electronic equipment have not developed and established 

their own specific corporate philosophy/policy in relation to the exporting of new and used appliances. 

At many companies the specific responsibilities or scope for action have not been specifically 

implemented. Producers should therefore develop and implement specific corporate 

policies in relation to the exporting of waste electrical and electronic equipment 

(Measure 2c). Particularly so far as re-marketing companies are concerned, the development 

opportunities appear to exist (e.g. the choice of re-marketing companies which have established 

a qualified specific corporate policy in relation to the exporting of non-working 

appliances (see Measure 2d below)). However, the monitoring of the contracted treatment 

companies for WEEE can also be developed in those cases where the producers do not monitor 

real mass flow rates in practice. 

It should be worked out with producers and producer organisations (where applicable at European 

level) how such a corporate policy and its compliance could be realised. 

While the initiation of the process by for example the BMU is conceivable, the overall process 

should though be organised by the producers themselves. 

For re-marketing companies the export of appliances is an important part of their corporate 

strategy. Their selection function is also based with regard to exported appliances on their own 

interpretations of legislation. Therefore quality labels and a voluntary commitment for remarketing 

companies should be developed and implemented (goal: non-export of nonworking 

appliances to non-EU countries) (Measure 2d). Here the instrument of selfcommitment 

and transparent proof of compliance with this appears to make sense in order to 

ensure a common understanding. 

The BMU can initiate a discussion on such a self-commitment. A workshop could be held on 

this issue, to which the most important re-marketing companies would be invited. 

The number of appliances of the profiles D2 to G actually exported by re-use organisations 

(e.g. job-creation and training companies) appears to be rather low 111 . It is therefore considered 

to be sensible that specific corporate policies for exports are developed for such companies and 

where applicable ensured by a quality label. On the way, these organisations can also set quality 

standards for other institutions which re-market appliances. 

Particularly in the context of the work of re-use organisations, the development of a quality 

label should be integrated into the “Second Life” project promoted by the UBA (Measure 

111 Pers. com. Bröhl-Kerner Werkstatt Frankfurt 2009




2d). In the process, as for re-marketing companies, specific requirements on the export of nonworking 

appliances should be considered. 

A self-commitment of producers and exporters relating to the non-export of non-working 

old appliances should be introduced at the CeBIT trade fair in 2011 (Measure 2e). 

The consideration of export-related corporate policies when companies are evaluated by 

ranking organisations appears to make sense (Measure 2f). The UBA should inform specific 

appropriate companies about this. 

The discussions with waste management companies (and producers) have shown that producers 

monitor the management of waste appliances which they are responsible for to varying 

levels of detail. Some producers make precise specifications to the waste management companies 

relating to treatment routes and also monitor these. Other producers merely require that 

the contracted waste management company must meet the minimum legal requirements for 

treatment, but monitor the mass balances themselves. A third group of producers hand the 

waste over to the contracted waste management companies without making any specifications 

beyond the minimum legal requirements and without doing any monitoring themselves. Waste 

management companies which have built their own treatment and recycling plants stressed 

their interest in fully utilising these plants and that it is normally more economical to dispose of 

the waste in their own plant than to export the appliances. In particular major waste treatment 

companies emphasised that a positive image and customer loyalty (in this case of producers) 

are essential for the longer-term success of the business and that it was therefore in their own 

interests to prevent exports to grey zones, which was ensured by internal monitoring. 

It would need to be clarified whether a negative “black list” of companies is legally tenable. 

The publication of a positive list of certified companies does though appear to be possible. Past 

cases though show that certification as a waste management company does not seem to provide 

sufficient certainty. Instead improved control mechanisms appear to be necessary to cover 

the export problem. 

Measures which are applied at the level of producers (as well as re-marketing companies and 

waste treatment companies) as voluntary and self-committed measures also appear to make 

sense because there are limits to a purely legal strategy due to the international constellation. 

Specific product responsibility concepts, where the producer or retailer remains the owner of 

the product during its utilisation phase (e.g. leasing) are currently being used for some types of 

appliances and user constellations (in particular among industrial, high-price users). Such concepts, 

which could be extended to other appliance types and user groups, do not provide a sufficient 

instrument per se to improve controls for the exporting of appliances. It has been revealed 

that re-marketing organisations, which take back used appliances from leasing activities 

when producers deliver new appliances, export appliances of the profiles D2 to G. In cases 

where the producers do not recondition or resell the appliances themselves, specific product responsibility 

concepts would only make sense in conjunction with a self-commitment as described 

above.




9.3 Legal regulations and controls 

Important legal regulatory areas which concern the exporting of appliances of the profiles C to G 

are the differentiation between waste and non-waste and the regulations concerning the export 

restriction of appliances which do not meet certain minimum requirements. 

The discussions with the parties controlling exports have shown that a simple legal basis for distinguishing 

between appliances which may be exported in the product regime and those which 

should be exported in the better-monitored waste regime, is considered to be essentially important. 

Appendix I to the draft of the amendment of the WEEE directive was considered by these parties 

to be an important step and a suitable instrument which can solve a range of difficulties in 

preventing unwanted exports. 

The analyses and discussions have shown that this instrument achieves the best effect when it 

is kept simple. With simple requirements it can happen though that some exports are prevented 

which would not result in unwanted consequences in the countries of destination or in loss of 

resources. In view of the scale of the problem in countries of destination such as Nigeria and 

Ghana, it does appear to be justifiable, however, to accept unwanted side-effects to a limited 

degree in order to considerably ease the overall problem. Here a social responsibility to improve 

the situation in the countries of destination is also seen, which have to be placed possibly before 

those of individual interests. Where necessary it should be reviewed at regular intervals 

whether the application of the detailed monitoring regime of waste legislation results in unreasonable 

difficulties for exports. 

It is therefore recommended that the distinction between waste and non-waste for 

UEEE/WEEE should be made via the amendment to the WEEE. The existing approach in 

this draft amendment should be further developed in detail for this purpose (Measure 3a). 

In any case a specification in the text of Appendix I to the effect that only exports outside of the 

EU are to be affected by the regulation appears to make sense. It should also be reviewed 

whether it has been included in Appendix I of the amendment of the WEEE directive in accordance 

with the requirement of 8b (last clause) of the Correspondents' Guidelines 112 that nonworking 

appliances which are under guarantee and sent for repair by the producer are not subject 

to the waste regime. 

It appears to make sense, based among other things on further discussions with various re-use 

organisations, re-marketing companies and parties controlling exports, to relate the requirements 

which Appendix I makes on permissible exports to fundamental functions of the appliance. 

Appendix I para. 1 a) therefore specifies a copy of the invoice and the contract (…) which 

confirms that the appliance is suitable for direct re-use and in full working order.” Appendix I 

paragraph 2 a) defines the test requirements in more specific terms: “For most used electrical 

and electrical equipment a test of the key functions is sufficient” [proposal for a directive of the 

European Parliament and Council concerning waste electrical and electronic equipment (new 

version) Brussels, 2008]). For the cases of doubt which have become known within the scope of 

112 Electrical and electronic equipment is normally not considered to be waste if 

b) the criteria specified in paragraph 7 letters c and d are complied with and the appliances are returned as a faulty collective consignment for 

maintenance to the producer or to maintenance centres (e.g. as part of the guarantee) with the intention of re-use. For clarification it is recommended 

that the text is specified more precisely to the effect that this applies to appliances sent for “maintenance to the producer or to its 

maintenance centres”.




this study a test of these key functions would have been sufficient to prevent export under the 

product regime. It is necessary to define the tests for the key functions mentioned in more specific 

terms. This can be done though in subordinate regulations. It appears in any case to be 

necessary to link breaches of the requirements of Appendix I with fines or penalties. 

The proposals can be made by the BMU in the discussion on the amendment of the WEEE directive 

in a European context. 

By way of support, a simple matrix should be developed for the information of exporters, as 

well as for use with export controls and by the authorities responsible for exports in the federal 

states which adopt the differentiation between appliances in categories A to G (see chapter 4.9) 

proposed in this study. The matrix presented in a project workshop by the Hamburg Environment 

Office can be used here as a starting point. 

The timetable for the revision of the WEEE directive suggests that it may take another 3 to 5 

years before it is implemented in national law and actually comes into force. For some types of 

equipment, this period is too long as for example CRT monitors and televisions are now being 

exported in great volumes as they are being replaced by flat screens. With other used appliances 

the requirements of for example the RoHS directive (on the restriction of the use of certain 

hazardous substances in electrical and electronic equipment) will not show any real effects 

with used appliances for a couple of years, whereby the need for action is greater now. It is not 

possible to make an appropriate change to the Electrical and Electronic Equipment Law (ElektroG) 

while the WEEE directive is being revised (block on changes). The legal obligation to ensure 

the requirements of the Correspondents' Guidelines at national level in the short term also 

carries the risk that exports will be redirected to ports in other member states. 

The analysis on the origin of exported appliances (see chapter 5) showed that a range of 

sources is relevant and therefore also that a range of intervention points should be processed. 

Based on experience and the fact that the personnel resources for enforcement are instead being 

reduced, monitoring of these points appears to be difficult. As a result, export controls at the 

points where the appliances are stowed into sea containers or where the containers are shipped 

become particularly important. 

While the city of Hamburg has managed to employ two additional people in the area of waste 

shipment, in view of the large number of containers this cannot though sufficiently replace personnel 

resources in other federal states. The analysis of the areas of origin has shown that the 

monitoring of export hubs will remain of great importance for improving export processes and 

that relevant volumes of appliances are not export via the Port of Hamburg, but via ports in 

other member states (e.g. Antwerp). 

The knowledge and awareness of collection points for electrical and electronic equipment for 

export (see section 5.1) is still very limited in the federal states. It is recommended that first of 

all a systematic survey on the number, facilities, approval type and status and turnover 

of the collection points in the federal states takes place. Criteria for the identification and 

control of collection points should be developed for this purpose (Measure 3b). As the 

goods collected and traded here often fall in the grey area between waste and non-waste, the 

situation at the collection points can for example be assessed against the background of the requirements 

of the Electrical and Electronic Equipment Law (ElektroG) and Appendix I of the 

amendment of the WEEE directive. 

Appropriate initiatives could be proposed by the BMU to the LAGA.




In some federal states and in Europe collection points are already being monitored in relation to 

exports of electrical and electronic equipment. It was emphasised that it is not possible to monitor 

every container which is packed for export. The goal is rather to control by way of example 

and to talk with exporters and gather their information on the requirements concerning the export 

electrical and electronic equipment under the product regime. An extension of such controls 

and discussions to more collection points should be initiated by the responsible monitoring authorities 

in cooperation with the responsible police forces. Where applicable this is also possible 

in the form of more concerted actions in which the experiences of the various federal states can 

be included. 

It became clear that the effective cooperation between the police, customs and the responsible 

waste authorities is an essential requirement for successful waste export controls and a harmonised 

and high standard of control. The legal responsibility of the police for the area of waste 

transport controls is at least considered to be sensible in the inland and sea port cities. An important 

element for effective controls is also that the police obtain access to databases for export 

registrations. This access, which has been established in Hamburg but is not ensured for 

future database systems, is considered an important requirement for identifying suspected 

cases using the police and being able to carry out targeted inspections. For this purpose the 

risk profiles of such exports should be further developed and there should be more intensive 

exchange between the responsible authorities (Measure 3c). 

Based on the IT information on export registrations, container check routines can be applied 

which also differentiate between the environmental risk potential of the appliances. 

• With refrigerators, the statistical comparisons suggest that a significant share of the appliances 

contain CFCs. Here a high frequency of controls and monitoring of the appliancespecific 

information, as recommended by the Correspondents' Guidelines, makes sense. 

• CRT monitors are currently the most significant type of appliance in terms of volume being 

exported to the countries of destination investigated. The environmental risk potential and 

the currently very strong drivers for non-working appliances to also be exported (domestic 

treatment costs, lack of recycling opportunities for the highest-volume fractions) also make 

a high inspection frequency appear sensible. 

This practice, which already takes place in some federal states, should be harmonised in its application. 

In addition, the on-the-ground work of the environment offices with container inspections should 

be foreseen. 

The exchange between the federal states and between German, Dutch and Belgian sea ports 

on the investigative profiles of exports where the risk of exporting waste as products is particularly 

high should be intensified. 

According to the police they could gather more detailed information on the areas of origin if, for 

example, after a transport is stopped the responsible authority issued such a request to the police. 

The gaps in information on the origin of exported appliances (see chapter 6 and in particular 

sections 6.6 and 6.8) show the importance of such a procedure. Investigations using the 

police in certain potential areas of origin for exported UEEE/WEEE (appliances which 

were already in the waste regime and are exported as used appliances) should be initiated 

(Measure 3d).




The exchange of information between the federal states is considered a sensible way of collating 

and using experience in all states. This can be done by developing a network of regional authorities 

and by exchanging employees. In the process, the experiences from the IMPEL-TFS 

projects concerning exchanging experience can be built upon. This could be initiated in the 

short term by Germany’s coordinating centre for the Basel Convention. 

9.4 Waste treatment structures in the countries of destination 

The above recommended measures have shown that a mixture of measures at different levels 

and with different time horizons is necessary in order to optimise the management and control 

of cross-border material flows of waste electrical and electronic equipment. 

First, it will be a matter of significantly reducing unwanted exports with source-related measures 

and improved export controls. Measures for this can be initiated in the short and medium term. 

In addition, further-reaching measures are considered sensible, with their implementation period 

considered to be in the medium to long term. 

The waste treatment structures in the countries of destination are below (sometimes by far) the 

protection level which the Europeans have set themselves. As the export of appliances (in working 

order) will continue in future, and this certainly also makes social and environmental sense, 

and new appliances will be marketed which will at some point be ready for treatment, the support 

of the countries of destination in the further development of their waste treatment structures 

and the tying of the industrial countries to waste treatment structures makes sense. 

With regard to environmental and health risks and also with regard to the relevant volumes of 

raw materials which are exported and not recovered, it should be expressly emphasised at this 

point that such medium and long-term measures can be no replacement for the export restriction 

measures in Germany. 

The countries of destination should also establish import restrictions which prohibit the import of 

non-working appliances and control imports more effectively. 

It should also be verified whether, for the waste caused by the appliances exported from 

Europe, equivalent waste volumes from the countries of destination should be disposed of in industrial 

countries in accordance with the requirements of the WEEE directive if no adequate 

waste treatment structures have been created there. 

The question of how these waste shipments from the country of destination to the industrial 

country could be financed is still to be answered 113 . It appears that a duty on all appliances 

which are exported from Germany or the EU would be difficult to achieve due to legal reasons. 

In discussions with experts concerning such a method of financing it was emphasised though 

that such a duty and the increased export costs might make the exporting of poor quality appliances 

less profitable. 

The findings concerning the waste treatment situation in the investigated countries of destination 

make the following dividing lines for the current situation between domestic treatment and 

export appear sensible: 

113 They could be partly financed by the choice of material (e.g. material containing precious metals).




• domestic manual or basic mechanical dismantling, 

• export of fractions which contain a high degree of materials with an environmental risk potential 

and fractions which have to be treated in technically complex thermal or chemical 

processes. 

It also appears possible based on current knowledge (and certainly also productive) that the 

parties in the countries of destination share in the value created from the waste treatment. 

In order to be able to export the fractions, domestic collection structures would also have to be 

established though. This can be problematic particularly in countries with a low degree of organisation 

in the informal sector (e.g. Nigeria and Ghana). It was also pointed out by some experts 

that the procurement of the necessary papers for the export of hazardous waste in compliance 

with the Basel requirements problematic and very costly in some countries. 

Concerns were also expressed in discussions with experts to the effect that the re-export of 

waste could be used as a justification for the export of poor quality appliances to such countries 

and even produce an unwanted pull effect. A sensible adjustment of the economic conditions of 

the re-export would certainly be necessary so that this does not hinder or prevent the development 

of domestic waste treatment structures. 

Therefore, further in-depth investigations are recommended into how fractions from the 

manual and mechanical dismantling of WEEE can be re-exported from the countries of 

destination to industrial countries (Measure 4a). 

The re-export of waste must not be restricted in this proposal to waste relating to the treatment 

of waste electrical equipment. In particular where valuable raw materials are contained in other 

waste (e.g. in catalytic converters from cars 114 ) and a high recovery rate cannot be ensured in 

the respective country, the pooling of waste provides an opportunity to increase the efficiency of 

transport and simplify the financing. 

In parallel to this European countries and producers should provide support in the development 

of suitable waste treatment facilities and infrastructure in countries of destination 

(Measure 4b). 

Producers in the countries of destination which implement broad product responsibility in this 

context might also implement the measures. Where applicable cooperation with companies in 

the recycling industry may take place 115 . 

9.5 Summary of the proposed measures 

Table 29 below summarised the measures recommended in chapter 9.1 to 9.4. 

114 Specific cases of this were reported in Nigeria. 

115 As is the case with Hewlett Packard’s involvement in measures to improve the waste management situation in Asia and South Africa. In this 

context discussion with forwarding agents was also proposed.




Table 29: Overview of the proposed measures 

Measure 

Statistics 

Addressee Implementation 

level 

1a Evaluation routines for the export databases should be developed 

and implemented in order to simplify or enable monitoring. 

1b A simple access to the export data should be provided for the 

waste surveillance authorities (if necessary also of those German 

Federal States other than Hamburg), in order to enable a 

monitoring of the development of quantities. 

1c It should be permanently ensured that the police forces have 

access to the exports databases. 

1d European statistics for important exported types of equipment 

such as, for example, monitors, television sets, refrigerators 

should be differentiated between new/used equipment in that 

appropriate codes are introduced into the combined nomenclature 

(a worldwide harmonisation is recommended as long-term 

perspective). 

Sources of exported equipment 

2a The collection of bulky waste should take place in such a form 

that protection against pilferage of waste electrical and electronic 

equipment is provided. 

2b The public should be more intensely informed about its own 

role in relationship to the export of waste electrical and electronic 

equipment and its negative effects. 

2c Manufacturers should elaborate and implement explicit corporate 

policies for the export of used electrical/electronic equipment 

and waste electrical/electronic equipment. 

2d Quality label and voluntary self-binding agreement for resellers 

should be elaborated and implemented (Objective: non-export 

of non-functional equipment in non-EU States). The integration 

of the label development in the UBA promoted project “Second 

Life” is recommended. 

2e A voluntary self-binding agreement of manufacturers and exporters 

for the non-export of non-functional used equipment 

should be presented at the CeBIT Trade Fair in 2011. 

2f Corporate policies for the export of non-functional equipment 

should be taken up by company ranking. 

BMF (German Federal Short-term 

Ministry of Finance) 

supporting work by 

enforcement authorities 

BMF Short-term 

BMF Short-term 

BMF Medium-term 

Federal states / 

municipalities 

Short-term 

UBA (German Federal Short-term 

Environment Agency)/ 

VKS/VKU (German 

Association of Municipal 

Waste Management 

and City Cleaning 

in VKU), all protagonists 

Manufacturers / BMU Short-term 

(German Ministry for 

the Environment, Nature 

Conservation and 

Nuclear Safety) 

BMU / UBA Short-term 

BMU / UBA Short-term 

Ranking 

organisations 

Medium-term




Table 29: Overview of proposed measures (continued) 

Measure 

Legal regulations and controls 

Addressee Implementation 

level 

3a The distinction between waste and non-waste for EEE/WEEE 

should take place via the amendment of the WEEE Directive. 

The existing draft should be refined in detail on this point. 

3b A systematic survey of the collection points for equipment for 

export in the German Federal States should take place and criteria 

for the identification and checking of such points should 

be elaborated. 

3c Risk profiles for the export of WEEE and UEEE should be developed 

further and exchange between the responsible authorities 

should be intensified. 

3d Investigations using police means in certain potential areas of 

origin for exported WEEE/UEEE should be initiated (equipment 

which has already been in the waste regime and is to be 

exported as used equipment). 

Cooperation with countries of destination 

4a Investigations should take place into how a re-export of fractions 

from the manual and mechanical disassembly of WEEE 

from the countries of destination into industrial states can take 

place. 

4b European countries and manufacturers should provide support 

with the build up of suitable waste treatment facilities and infrastructure 

in countries of destination. 

BMU/UBA Short- to mediumterm 

Federal states, 

municipalities 

BMF/UBA, Environmentalauthorities 

in NL and BE; 

focal points for the 

Basel Convention 

Environmental authorities,department 

of public 

prosecution 

EU, 

BMZ (German 

Ministry for Economic 

Cooperation 

and Development) 

Manufacturers, 

EU, BMZ 

Short-term 

Short-term 

Short-term 

Short-term 

Medium-term 

The analysis and the discussions with experts clearly showed that the improvement of the situation 

cannot be achieved via a singular measure. The proposed measures combine mid- and 

long-term activities and target numerous protagonists/players. An intensive monitoring of potential 

sources of equipment destined for export everywhere will not be possible due to restricted 

human resources and a desired high controlling efficiency. Control measures should therefore 

be focused on those spots which concentrate equipment destined for export (collection and 

loading points, ports). 

Due to the transnational character of this problem with exports pure legislative approaches cannot 

solve the accompanying difficulties completely. Therefore voluntary measures on the level 

of manufacturers (but also of the re-marketing and waste treatment companies) have been developed. 

It can be expected that the combination of these measures will mitigate the problem for Germany. 

In order to improve the situation in the countries of destination structurally, further activities 

on an international level are necessary. 

The inclusion of further export rules into the recast of the WEEE-Directive is being welcomed in 

particular by the controlling authorities. Nevertheless with regard to the current export wave of 

CRT-monitors the implementation of the Directive within the Member States will come too late.




With regard to the current large scale exports of old CRT-Monitors and -TV short term solutions 

should be found. 

Overall, it can be expected that the combination of these measures can ease the problem for 

Germany. For a fundamental improvement of the situation in the countries of destination, however, 

further measures at an international level are necessary. 

The inclusion of provisions for the waste export problem in the amendment of the WEEE directive 

is considered sensible and very helpful by the inspection authorities. With regard to the current 

wave of exported CRT monitors, the effects of the directive would not unfold until after the 

directive has been implemented in the member states, i.e. too late. In view of the large scale of 

old CRT monitors and televisions being exported, a solution which would have a short-term impact 

should be found.




10 Sources 

1. [Wuppertal waste balance 2006] Waste balance of the city of Wuppertal 2006, http://www.wuppertal.de/rathausbuergerservice/umweltschutz/abfall/102370100000146444.php 

2. [Adesanya pers.com.] Adesanya, Olayemi, freelance researcher, Lagos, Nigeria, e-mails February/March 2009 

3. [Ahn 007] Nguyen Hoang Anh, Vietnam Environment Protection Agency, E-Waste Management in Vietnam, Regional 

Workshop on Prevention of Illegal Transboundary Movement for Hazardous Waste, Beijing, China ,28-29 March 2007, 

http://www.env.go.jp/en/recycle/asian_net/reports/fourthyearwork/Presentations/S4.05_070322-Vietnam-E-waste- 

Anh.pdf 

4. [Anane pers.com.] Anane, Mike, journalist, Accra, Ghana, telephone conversation December 2008 

5. [BAN 2005] Puckett, J., Westervelt, S.,Gutierrez, R., Takamiya, Y., The Basel Action Network. The Digital Dump- 

Exporting Re-use and Abuse to Africa, 24.10.20056 

6. [Basel 2006-1] Basel Convention, Country Fact Sheet 2006, Nigeria, www.basel.int/natreporting/2006/cfs/nigeria.doc 

7. [Basel 2006-2] Basel Convention, Country Fact Sheet 2006, Ghana, www.basel.int/natreporting/2006/cfs/GHANA.doc 

8. [Basel 2006-3] Basel Convention, Country Fact Sheet 2006, Vietnam, www.basel.int/natreporting/2006/cfs/vietnam.doc 

9. [Becker RAL pers.com.], expert discussion May 2009 

10. [BFAI 2008] Bundesagentur für Außenwirtschaft (German Office for Foreign Trade), bfai-Zollnews 03/2008, 

http://www.gtai.de/de/content/__shareddocs/anlagen/pdf/anlagen-newsletter-zoll/2008-03-bfaizollnews,property=publicationfile.pdf?show=true 

11. [BFD 2009] Communication in writing from the Bundesfinanzdirektion Südost (Federal Finance Office South East) 

dated 13.05.2009 

12. [BMU 2008] Daten über Elektro(nik)geräte in Deutschland im Jahr 2006 - BMU-Erläuterungen zu der Berichterstattung 

an die EU-Kommission (Data on electrical and electronic equipment in Germany in 2006 – BMU explanations on reporting 

to the EU Commission), Berlin, 2008 

13. [Braun 2009] Braun, J., Bremen Police/WV 12, Wirksame Kontrollen grenzüberschreitender Abfalltransporte – Eine internationale 

Herausforderung (Effective controls of cross-border waste transport - An international challenge), Deutsche 

Polizei (German Police) 1-2009, pages 22-25 

14. [Bundesfinanzdirektion Südost pers com.] Bundesfinanzdirektion Südost (Federal Finance Office South East): Verbote 

und Beschränkungen für den Warenverkehr über die Grenze (Prohibitions and limitations for cross-border trade, Nuremberg), 

e-mail dated 20.02.2009 

15. [BVDA 2009] Bundesverband Deutscher Anzeigenblätter (Federal Association of German Free Papers, BVDA): 

http://www.bvda.de/ 

16. [Chancerel 2009] Chancerel, P., Rotter, V. S.: Edelmetallrückgewinnung aus Elektro- und Elektronikaltgeräten durch 

Aufbereitung (Recovery of precious metals from electrical and electronic equipment through treatment), in: Müll und 

Abfall Heft 2.09 (Rubbish and Waste Issue 2.09), Berlin 2009 

17. [Dakosy pers.com.] E-mail dated 30 April 2009 

18. [DESTATIS 2008] Statistisches Bundesamt (Federal Statistical Office) – Export statistics; Wiesbaden 2008 

19. [DESTATIS 2009], E-mail from the Statistisches Bundesamt (Federal Statistical Office) 08.01.2009 

20. [Deutscher Bundestag 2006] Antwort der Bundesregierung vom 13.11.2006 Gefährliche Müllexporte in Entwicklungsländer 

– Folgen und Lösungsansätze (Reply from the German government dated 13.11.2006 Hazardous waste exports 

to developing countries – consequences and solutions), – Official Paper 16/3203 – , 

http://dip21.bundestag.de/dip21/btd/16/034/1603422.pdf




21. [Ecroignard pers.com.] Ecroignard, L., Project Coordinator, e-Waste Association of South Africa, Randjiesfontein, 

South Africa, telephone conversation and e-mails in December 2008 

22. [EITO 2007] European Information Technology Observatory EITO 2007, Frankfurt, 2007 

23. [E-Parisaraa 07] E-Parisara, R&D Department, internal study, Bangalore, 2007, www.ewasteindia.com 

24. [E-Scrap 2009] E-Scrap News Electronic Newlsetter, Slumdogs face tide of e-scrap, 05.03.2009 

25. [EU 2009] http://europa.eu/legislation_summaries/environment/waste_management/l21210_de.htm 

26. [Finlay, Liechti 2008] Finlay, A., Liechti, D., e-Waste Assessment South Africa, e-Waste Association of South Africa 

(eWASA), November 2008 

27. [Garcia 2006] Garcia, D., Promoting 3r Initiatives in the Philippines - Asia-Pacific Roundtable for Sustainable Consumption 

and Production, 

http://www.3rkh.net/3rkh/files/Advanced%20Waste%20Management%20Project%20Final%20Report%20- 

%20Philippines.pdf 

28. [GFK 2007] Adlwarth, W.: Trends in mail order – how do customers think?, GfK 2007 

29. [Greenpeace 2008] Kuper,J., Hojsik, M., Greenpeace: Poisoning the poor –Electronic waste in Ghana, August 2008 

[Hagelüken 2009]: Bilitewski, B., Werner, P., Janz, A. (publisher): Brennpunkt ElektroG; Edelmetallverluste bei Export 

und Aufbereitung von Elektroschrott in Drittländern (Focus on ElektroG; loss of precious metals in exports and treatment 

of electrical waste in third countries), series: Beiträge zu Abfallwirtschaft / Altlasten Band 62 (Contributions on 

Waste Management / Contaminated Sites Volume 62), Dresden, 2009 

30. [Hoeppner 2005] Hoeppner, D. Änderungen in Internationalen Warenverzeichnis für den Außenhandel (SITC) 

(Changes in international goods index for foreign trade (SITC)), Statistisches Bundesamt (Federal Statistical Office) - 

Economy and Statistics 12/2005, http://www.destatis.de/ 

31. [ICAI 2003] Chartered Accountants in India, Customs Valuation Rules in WTO 

www.icai.org.in/resource_file/8855CustomsValuationRulesinWTO.ppt 

32. [ICT 2008] Stichting Witgoed, Stichting Bruingoed, Stichting ICT Milieu, Stichting Metalektro Recycling, Stichting 

LightRec, Stichting Verwerking Centrale Ventilatoren, Stichting Verwijdering Elektrische Gereedschappen: Onderzoek 

naar complementaire afvalstromen voor e-waste in Nederland, Breda, 2008 

33. [Janz 2009] Janz, A. e. a.: Grenzüberschreitende Ströme von Elektroaltgeräten (Cross-border flows of waste electrical 

equipment); in: Müll und Abfall (Rubbish and Waste), 3/09, P. 126-132 

34. [Jinhui Nana 2008] Prof. Li Jinhui, Ms. Zhao Nana, Basel Convention Coordinating Center for Asia and the Pacific, 

PROJECTS PROGRESS The Import/Export Management of E-Waste and used EEE, presentation 

35. [Krishna pers. com] S. T. Radha Krishna, Managing Director, E-waste Agency, Bangalore, India, telephone conversation 

December 2008 

36. [Kropp 2008] Kropp, O., Zuständigkeiten und Vorgehensweise bei der Kontrolle grenzüberschreitender Abfalltransporte 

(Responsibilities and procedures for controlling cross-border waste transport), Umwelt- und Planungsrecht (Environmental 

and Planning Law, UPR) 6/2008, pages 213-218 

37. [Lalchandani 2008] Lalchandani, N., TNN, The Times of India, Delhi's e-waste to be recycled in Haridwar, 6 Jun 2008, 

http://timesofindia.indiatimes.com/articleshow/msid-3105218,prtpage-1.cms 

38. [Marfels 2006] Marfels, N., 2006, No.2 http://www.afrikawirtschaft.de/de/index.php?node_id=87 . April 2009 

39. [Oboro pers.com.] Oboro, John, Assistant General Secretary, Computer and Allied Products Dealers Association of Nigeria 

(CAPDAN), Lagos, Nigeria, telephone conversation December 2008 

40. [OFD-HH 2002] Oberfinanzdirektion Hamburg Hauptzollamt Hamburg-Hafen -Zollamt Waltershof---Abfertigung Ericus-- 

Hamburg, in: Verbindliche Regeln für die Eingabe zollrelevanter Daten des Hafendatensatzes (HDS)/ der Gestellungsmitteilung 

(GM01) (Binding rules for entering customs-relevant data for the Port Data Record (HDS) / the customs 

presentation notification (GM01)) in ZAPP in three parts:, November 2002 

41. [Osibanjo 2009] Osibanjo, O., Draft information document on electronic waste, 17.02.2009 

42. [Osibanjo pers.com.] Osibanjo, O., Professor of Chemistry and Director of the Basel Convention Regional Coordinating 

Centre, University of Ibadan, Centre for Africa for Training and Technology, Ibadan, Nigeria, telephone conversation 

December 2008




43. [Rativo 2008] Rativo, S.C., Republic of the Philippines - Environmental Management Bureau, Regional Workshop on E- 

Waste Identification toward the Prevention of Illegal Transboundary Movement for Hazardous Waste and Other Wastes 

in Asia, 03-07 November 2008, Beijing, China, presentation 

44. [Rochat 2008] Rochat, D., India: Including the Existing Informal Sector in a Clean e-Waste Channel, presentation at 

WasteCon, Durban, South Africa, October 2008 

45. [Rochat et al 2008] Rochat, D., Rodrigues, W., Gantenbein, A.: Including the existing informal Sector in a clean Ewaste 

channel. Proceedings of the 19th Waste Management Conference of the IWMSA (Waste Con 2008), 6th-8th October 

2008, Durban, South Africa 

46. [Rochat pers. Com.] Rochat, D., e-Waste Project Coordinator, Swiss Institute for Materials Science and Technology, 

Global Swiss e-Waste Programme (EMPA), St. Gallen, Schweiz, e-mail, January 2009 

47. [Salhofer 2009] Salhofer, S., Spitzbart, M., Schöps, D., Meskers, C.E.M.. Kriegl, M., Panowitz, G., Verfahrensvergleich 

zur Gewinnung von Wertstoffen aus Elektroaltgeräten (Comparison of methods for recovering recyclable material from 

waste electrical equipment), in: Bilitewski, B., Werner, P., Janz, A. (Hrsg): Brennpunkt ElektroG; Reihe: Beiträge zu Abfallwirtschaft 

/ Altlasten Band 62 (Focus on ElektroG; series, Contributions on Waste Management / Contaminated Sites 

Volume 62), Dresden, 2009 

48. [Schreiber pers. com.] Schreiber, H., Expert for Waste Management & Recycling, E-Parisaraa Pvt. Ltd., Bangalore, India, 

telephone conversation December 2008 

49. [Seemann et al 2008] Seemann, A., Schreiber, S., Radha Krishna, S.T., E-waste Recycling in India, in Müll und Abfall 

(Rubbish and Waste) 06/2008, page 4 

50. [Soenke 2007] Zehle, S., Arndt, L., Bormann, S.: Unsichtbare Kosten Ungleiche Verteilung Ökologischer Risiken In Der 

Globalen Computerindustrie (Invisible costs unequal distribution of environmental risks in the global computer industry); 

publisher: Weltwirtschaft Ökologie & Entwicklung e.V. (WEED e.V.); Bonn, 2007 

51. [stiftung ear 2009] http://www.stiftung-ear.de/ , at: 02.01.2009 

52. [Subramanian 2007] Subramanian, S., E-Waste Management – A formidable challenge in: Waste Management World, 

July/August 2007 in Müll und Abfall (Rubbish and Waste) 06/2008, page 4 

53. [Trend Büro 2008] Angerer, M., Auktionskultur: Leben im Jetzt, Besitzen auf Zeit (Auction culture: living in the now, borrowed 

ownership); Dreilinden, 2008 

54. [UBA pers.com.] expert discussion May 2009 

55. [UNCTAD 2006] United Nations Conference on Trade and Development, Trade And Environment Review, Chapter 2: 

Environmental requirements and market access for developing countries: the case of electrical and electronic equipment, 

United Nations Geneva 

56. [UNSTATS 2005] United Nations Department of Economic and Social Affairs, Statistics Division, Workshop on compilation 

of international merchandise trade statistics, Abuja, Nigeria, 30 août - 2 septembre 2005, Country Presentation, 

Customs – Ghana, The Ghana Customs Excise and Preventive Service CEPS, 

http://unstats.un.org/UNSD/trade/ws%20abuja/Ghana%20-%20Customs%20-%20Presentation.pdf 

57. [UNU 2007] Kühr, R., Review of Directive 2002/96/EC on Waste Electric And Electronic Equipment, United Nation University, 

Bonn, 200756. 

58. [Ventkatesh pers.com] Venkatesh, Karnataka State Pollution Control Board, Bangalore, India, telephone conversation 

December 2008 

59. [VKS 2008] Betriebsdatenauswertung 2006 (Evaluation of operational data 2006), published by the VKS in the VKU, 

Cologne 2008 

60. [WDI 2006] World Development Indicators – The Information Age; World Bank, 2006 

61. [Weigelt pers.com.] Expert discussion May 2009 

62. [Wuttke Baehr 2008] Wuttke, J., Baehr, T., Praxishandbuch zur grenzüberschreitenden Abfallverbringung (Practical 

handbook for cross-border waste shipments), 2nd edition, publisher. Umweltbundesamt (Federal Environment 

Agency), Erich Schmidt Verlag, 2008 

63. [Yen pers com.] Yen, Nguyen Thanh, Hazardous Waste Management Division, Waste Management and Environment 

Promotion Agency, Vietnam Environment Administration, Hanoi, Vietnam, e-mail dated 14.04.2009




11 Appendix 

11.1 ZAPP/ATLAS criteria 

Table 30: Goods codes used in an evaluation of the database 

Goods code Text 

84181020 Combined refrigerator-freezers, capacity > 340 l 

84181080 Combined refrigerator-freezers, capacity 340 l 

84182151 Household refrigerators, table model





84433299 Other machines for connection to EDP machines 

84433910 Machines for copying and printing 

84433931 Machines with copy function with optical system 

84433939 Other copying machines 

84433990 Other machines for copying and printing 

84729070 Other office machines 

85437010 Electrical machines with translation or dictionary functions, without a calculator 

84713000 Portable computers (central unit with display and keyboard) 

84714100 Digital automatic data-processing machines 

84714900 Digital automatic data-processing machines, provided as a system 

84715000 Digital processing units 

84716060 Keyboards for input or output units 

84717020 Central storage units for automatic data-processing machines 

84717030 Disk storage units for automatic data-processing machines 

84717050 Hard disk storage drives for automatic data-processing machines 

84717070 Disk storage units for automatic data-processing machines, not mentioned elsewhere 

84717080 Magnetic tape storage units for automatic data-processing machines 

84717098 Storage units for automatic data-processing machines, not mentioned elsewhere 

84718000 Peripheral units for data-processing machines 

84719000 Magnetic or optical readers, machines 

84733080 Parts and accessories, data-processing machines 

84690010 Word-processing machines 

85195000 Telephone answering machines 

85198151 Dictating machines with external source of power 

85198915 Dictating machines 

85198115 Pocket-size cassette players 

85198121 Cassette players with analogue or digital system 

85198125 Other cassette players 

85198155 Cassette recorders for recording or reproducing sound 




85198181 Magnetic tape recorders for recording sound 



85198911 Record players 

85198919 Other sound reproducing apparatus without sound recording device 

85198990 Other sound reproducing apparatus 

85211020 Magnetic tape recorders for recording video and sound 

85211095 Magnetic tape recorders for recording video and sound, not mentioned elsewhere 

85221000 Pick-up cartridges 

85271210 Pocket-size radiocassette players 

85271290 Pocket-size radiocassette players 

85271310 Radio-broadcast receivers 

85271391 Radio-broadcast receivers/cassette players 

85271399 Radio-broadcast receivers with laser reading system 

85271900 Other radio broadcast receivers 

85272120 Radio-broadcast receivers used in motor vehicles 

85272152 Radio-broadcast receivers/cassette players for motor vehicles 

85272159 Radio-broadcast receivers for motor vehicles 


85272192 Radio-broadcast receivers/cassette players for motor vehicles 


85272900 Radio-broadcast receivers used in motor vehicles 

85279111 Radio-broadcast receivers with cassette player 

85279119 Radio-broadcast receivers with speakers 

85279135 Radio-broadcast receivers with laser reading system 

85279191 Radio-broadcast receivers/cassette players 


85279210 Alarm clock radios 

85279290 Radio-broadcast receivers with clock 


85192091 Sound reproducing apparatus with laser reading system operated by coins, banknotes, bank cards, tokens or





85192099 

by other means of payment 

Sound reproducing apparatus without sound recording device operated by coins, banknotes, bank cards, tokens 

or by other means of payment (excl. those under codes 85192010 and 85192091) 

85193000 Turntables, sound reproducing apparatus 

85198131 Sound reproducing apparatus with laser reading system 

85198135 Sound reproducing apparatus with laser reading system 

85198145 Other sound reproducing apparatus without sound recording device 

85192010 Coin-operated or disc-operated record-players 

85258091 Video camera recorders 

85258099 Video camera recorders 

85219000 Video recording or reproducing apparatus 

85258030 Digital cameras 

85287220 Reception apparatus for television with built-in video recording or reproducing apparatus 

85287190 Reception apparatus for television, colour 










85287300 Reception apparatus for television, black and white or other monochrome 

85287210 Television projection equipment, colour 

85286910 Video projectors, operating by means of flat panel display 

85286991 Video projectors, black and white or other monochrome 

85286999 Video projectors, colour 

85286100 Projectors for data-processing machines 

85285990 Video monitors, colour 




85284100 Monitors for data-processing machines 

85284910 Monitors, black and white or colour 

85285100 Monitors for data-processing machines 

85285910 Monitors, black and white or colour 

85171100 Line telephone sets with cordless handsets 

85171200 Telephones for cellular networks mobile telephones or for other wireless networks 

85183020 Line telephone handsets 

85171800 Telephone sets (excl. line telephone sets with cordless handsets and telephones for cellular networks or for 

other wireless networks) 

85176100 Base stations of apparatus for the transmission or reception of voice, images or other data incl. apparatus for 

communication in a wired or wireless network [such as a local or wide area network] 

87032190 Motor vehicles with spark-ignition engine, to 1000cm3, used 

87032290 Motor vehicles with spark-ignition engine, 1000-1500cm3, used 

87032490 Motor vehicles, campers, with spark-ignition engine, over 3000cm3, used 

87032390 Motor vehicles, campers, with spark-ignition engine, 1500cm3-3000cm3, used 

87033190 Motor vehicles with diesel engine, to 1500cm3, used 

87033390 Motor vehicles, campers, with diesel engine, >2500cm3, used 

87033290 Motor vehicles, campers, with diesel engine,1500-2500cm3, used




11.2 Selected countries of destination 

Egypt 

Algeria 

Angola 

Ethiopia 

Belgium 

Benin 

Burkina Faso 

Ivory Coast 

Democratic Republic of Congo 

Democratic People’s Republic of Laos 

France 

Gabon 

Gambia 

Ghana 

Guinea 

India 

Indonesia 

Yemen 

Jordan 

Cambodia 

Cameroon 

Kenya 

Lebanon 

Liberia 

Malawi 

Malaysia 

Morocco 

Mauritania 

Mozambique 

Myanmar 

Nepal 

Netherlands 

Niger 

Nigeria 

Pakistan 

Philippines 

Republic of Congo 

Republic of Korea 

Saudi-Arabia 

Senegal 

Zimbabwe 

Spain 

Sri Lanka 

South Africa 


Togo 

Tunisia 

Turkmenistan 

United Arab Emirates 

United Republic of Tanzania 

Vietnam 

People’s Republic of China




11.3 Elements of the variant calculations 

Table 31: Variants of the exported appliance mix 

Type of appliance 

Variants of the volume distribution 

High CRT share High share of small appliances and PCs Average shares 

Refrigerators and freezers 10% 10% 10% 

Monitors 35% 30% 33% 

Televisions 43% 33% 38% 

Brown goods 5% 5% 5% 

Small appliances 3% 10% 7% 

Computers 4% 12% 8% 

Total 100% 100% 100% 

Table 32: Material flows from the export of electrical and electronic equipment and WEEE 

Fraction Max. Min. 

t 

Steel 61,064.26 17,952.48 

Copper 11,585.64 4,818.85 

Aluminium 4,170.97 1,790.87 

Plastic 33,094.63 13,143.65 

Wood 514.07 124.82 

Glass 329.49 127.93 

Glass (CRT) 80,873.96 34,858.26 

LCD screens 1.72 0.24 

Batteries 47.37 6.65 

Capacitors 44.76 9.91 

Circuit boards 14,589.87 6,288.52 

Oil 190.23 68.98 

PCB 0.17 0.07 

Mercury 0.19 0.02 

kg 

Ag 3.26 0.47 

Au 0.61 0.12 

Pd 0.23 0.05 

Sn 34.70 6.86 

Zn 32.46 5.78

Transboundary shipment of waste electrical and ... - Basel Convention

Create successful ePaper yourself

Delete template?

Save as template?