Introduction

Internal auditors, as well as environmental auditors, who specialise in end-of-life treatment and disposal of e-waste, face a number of unique challenges that emphasize the need for continued professional development, adaptability, and collaboration with experts in technology and sustainability. For instance, technologies such as AI, IoT, and automation are critical for environmental management and data collection and require continuous learning and adaptation. The term e-waste refers to discarded electronic devices and equipment, including computers, smartphones, tablets, and other electronic equipment. In the absence of adequate management, e-waste poses significant environmental challenges due to the toxic materials it contains, such as lead, mercury, and cadmium. The improper disposal and recycling of e-waste can lead to soil and water pollution and contribute to various health problems.

For instance, young children, adolescents, and women work in the growing e-waste dumps of Africa, Asia, and Latin America, as well as in some developed economies of Europe and elsewhere, extracting precious metals such as gold from computer chips and copper from cables by burning or using toxic chemicals. In the process, they are exposed to dangerous chemicals such as mercury, lead, dioxins, and flame retardants, and breathe air polluted with toxic particles. E-waste often contains toxic substances like lead, mercury, cadmium, and brominated flame retardants. When e-waste is improperly disposed of in landfills or incinerated, these hazardous materials can leach into the soil and eventually contaminate groundwater and surface water, including rivers, lakes, and aquifers. Contaminated water can lead to soil pollution, affecting the quality and safety of crops grown in the contaminated soil. Plants can absorb heavy metals and other contaminants from the soil, which can then be ingested by animals or humans.

To audit the recording, tracking, or management of e-waste, an internationally recognised standard in environmental management is recommended. The ISO 14001 environmental management framework and the International Standards of Supreme Audit Institutions (ISSAI) are both recognised frameworks for establishing an audit program for e-waste management. 

The Problem

The e-waste produced annually is worth over $62.5 billion, more than the GDP of most countries. There is 100 times more gold in a tonne of e-waste than in a tonne of gold ore. Less than 20% of e-waste is formally recycled, with 80% either ending up in landfills or being informally recycled. A record 53.6 million metric tonnes (Mt) of e-waste was generated around the world in 2019, and this number is on the rise. Interestingly, only 17.4% of this e-waste is officially documented and disposed of in compliance with national and international legislation. An astounding 82.6% of e-waste is undocumented globally with evidence of transboundary movement of e-waste.

Undocumented e-waste disposal or illegal disposal practices can be considered a crime in Europe and other jurisdictions. A recent study highlights the issue of illegal e-waste quantifying the extent to which e-waste moves from the Global North and Global South. France, the UK, and Sweden emerge as central exporters of illegal e-waste, and Nigeria as a main importer. Another recent study identified France, the United Kingdom, Germany, Sweden, and Belgium as the main global illegal waste exporters, and China, Poland, Nigeria, and Ghana as the main importers of illegal waste. Other destination countries for illegal shipments at the global level were Benin, Cameroon, Guinea, Senegal, Congo, Cote d’Ivoire, and Gambia in West Africa and India, Pakistan, Malaysia, and Thailand in South and Southeast Asia. 

Do national or regional environmental audits or inspections shed any light on the issue?

In 2022, a compliance and performance audit conducted by the UK National Audit Office, regarding the government's efforts to combat waste crime including e-waste in England, verified that the Environmental Agency intercepts between 200 and 450 containers annually. These containers generally hold waste that does not conform to waste export regulations, encompassing untreated and hazardous materials, rendering them ineligible for lawful export for disposal. The report confirms that the scale of illegal e-waste exported from the UK is unknown. The outcome of the audit confirmed that the environmental agency did not have the data or evidence to identify and assess the full extent of illegal e-waste in England.

In 2015, the Swedish National Audit Office conducted a performance audit into whether the Swedish government effectively supervises cross-border and national transport of hazardous waste. The auditing findings concluded that there were deficiencies in the system of supervision of hazardous waste transport. 

In 2011, a national financial, compliance, and performance audit was conducted in France that focused on the local authorities and waste management. The audit findings included poor management of waste locally and nationally with a lack of transparency.

Within the EU, the Shipment of Waste Enforcement Actions Project, (SWEAP) acts as an enforcement regulator within the EU. The inspectors, auditors, and law enforcement agencies act to disrupt illegal waste shipments. From 2018 to March 2020, a total of 11,843 waste inspections were carried out in 28 European countries, resulting in 2,586 violations being recorded. The violations encompass administrative issues, such as missing or incomplete forms (18%), breaches of national regulations (34%), and shipments that are subject to export bans (22%).

How do we re-think the national environmental audit of end-of-life treatment and final disposal of transboundary e-waste in the UK?

Artificial Intelligence (AI) techniques can play a crucial role in the auditing and monitoring of transboundary e-waste, ensuring proper handling, disposal, and tracking of transboundary e-waste is essential for environmental protection and compliance with international regulations. AI can be used to assess geospatial data, including satellite imagery and GPS data, to track the movement of e-waste shipments. Geospatial analysis can help identify unauthorized dumping sites and track the routes taken by e-waste shipments. For example, the Basel Action Network (BAN) conducted a two-year study between 2016 to 2018, across 10 European countries, where they used GPS to track the movement of illegal WEEE across the EU. The results showed the UK was clearly the worst violator, with most of the illegal shipments bound for Africa.

By utilizing blockchain technology, international e-waste transactions can be transparent and immutable. In order to ensure that e-waste movements are consistent with the recorded transactions, AI can analyse blockchain data and identify any discrepancies. Images and videos from surveillance cameras at border crossings, ports, and recycling facilities can be analysed by AI-powered computer vision systems. E-waste shipments can be identified this way and their condition, quantity, and documentation requirements can be assessed.

Investment in end-of-life treatment and final disposal of transboundary e-waste in the UK is critical to disrupting illegal e-waste shipments to developing countries and deterring further violations of national and international legislation.

Fadeke Ayoola FCCA - CEO, NET Africa