The amendment to transboundary e-waste regulations, UK International Waste Shipments (Amendment) Regulations 2024, which came into force on 1 January 2025, introduces stricter controls on the import and export of waste electrical and electronic equipment (WEEE). 

The escalating issue of WEEE, a form of environmental pollution with dire consequences, has emerged as a pressing global concern. 

The term refers to discarded electronic devices and equipment, including computers, smartphones, tablets and other electronic equipment. The heavy metals used in the manufacturing of these devices develop an issue once they convert to waste due to their toxicity, mobility and non-biodegradability in environmental media such as soil, water, and air.  

The annual generation of e-waste exceeds 50 million metric tons. This vast and rapidly accumulating waste stream poses a significant threat to environmental sustainability and human health, particularly in developing nations that often bear the brunt of improper transboundary e-waste management practices. 

The UK has historically been one of the world's largest exporters of e-waste, with numerous documented cases of illegal transboundary shipments to developing countries, particularly in West Africa and South Asia. Investigations by Interpol, Greenpeace, and the Basel Action Network (BAN) have exposed the UK's role in violating international e-waste trade laws, often misclassifying used electronics as 'second-hand goods' to bypass regulations. 

For example, the 2018 Basel Action Network Report found that UK e-waste was illegally exported to Ghana, Nigeria and Pakistan, violating Basel Convention rules. The 2020 Environmental Audit Committee (EAC) Investigation revealed that the UK was shipping over 200,000 tonnes of e-waste annually 'under dubious circumstances'. In 2021, UK Environment Agency crackdowns resulted in several UK companies facing penalties for violating WEEE export laws, particularly for failing to secure Prior Informed Consent.

PIC procedure

The Prior Informed Consent (PIC) process requires the exporting country’s regulatory authority (such as the UK Environment Agency) to notify the importing country's authorities about the intended shipment of e-waste. It needs to obtain formal consent from the importing country before the shipment can proceed. This will ensure proper documentation accompanies the shipment, including waste classification, quantity, handling procedures and final disposal methods.                         

The procedure aims to prevent illegal waste dumping, ensure environmentally sound management (ESM), and promote accountability among waste exporters and recyclers.

Key amendments

The new rules introduce stricter controls on WEEE shipments by expanding PIC requirements. Previously, only hazardous e-waste required prior approval from exporting/importing authorities. Now, non-hazardous WEEE also falls under PIC procedures, meaning businesses must obtain official consent before transboundary movement. 

UK businesses must now track, document and report their e-waste shipments with greater scrutiny. Companies handling e-waste must secure prior approvals before shipping electronic waste across borders, leading to longer processing times and potential administrative costs. 

Stricter controls may restrict exports to certain countries, particularly in the Global South where informal recycling often takes place. With limited export options, companies may need to invest in domestic recycling infrastructure or partner with certified e-waste processors.

Actions

UK businesses should take a number of actions:

• Establish a strong compliance framework that ensures internal teams understand PIC rules and maintain accurate waste classification records. 
• Develop alternative waste management strategies that explore domestic recycling and circular economy solutions to reduce reliance on e-waste exports. 
• Strengthen supply chain due diligence by conducting thorough audits of recycling partners to ensure they meet environmental compliance standards.
• Engage with regulators such as the UK Environment Agency.

Implications for internal audit 

These changes necessitate enhanced governance, risk management and compliance (GRC) measures. Internal auditors must evaluate how well an organisation aligns with the International Waste Shipments (Amendment) Regulations 2024, the expanded Basel Convention and OECD controls. 

This should include assessing regulatory awareness within the organisation; reviewing existing e-waste management policies to ensure compliance with the PIC procedure for hazardous and non-hazardous WEEE exports/imports; and identifying non-compliance risks that could lead to fines, shipment rejections or reputational damage.

Organisations also need robust internal controls to meet new e-waste regulations. Internal Audit should assess the documentation processes to ensure all e-waste shipments include proper notification, permits and country consents; ensure that supply chain due diligence of suppliers and recycling partners adhere to the amended regulations; and assess data accuracy to validate waste classification (hazardous vs non-hazardous), as misclassification could result in regulatory breaches.

Stricter regulations raise the risk of illegal exports, waste dumping and fraudulent waste reporting. Internal auditors should monitor for red flags, such as incomplete documentation, mis-declared waste or export routes involving high-risk jurisdictions; audit vendor contracts to ensure compliance with environmental laws and assess their track record in responsible e-waste disposal; and assess financial risk exposure due to increased export restrictions, higher disposal costs, and potential liability for non-compliance.

Many businesses integrate e-waste management into their environmental, social and governance (ESG) frameworks. Internal auditors should review sustainability reporting to ensure compliance with UK's new sustainability assurance requirements under the Corporate Sustainability Reporting Directive (CSRD); assess if the organisation meets circular economy principles, such as responsible recycling, extended producer responsibility (EPR), and resource recovery; and ensure third-party waste processors are audited for environmental compliance and ethical disposal methods.

Internal auditors also need to assess information technology and data security implications, as WEEE disposal often involves data security risks. This means reviewing data destruction policies to prevent data breaches from improperly disposed electronic devices; and ensuring that secure e-waste disposal contracts include clauses on certified data wiping and asset tracking.

Finally, the key recommendations for internal auditors are to develop an e-waste compliance framework aligned with UK regulations. They should conduct periodic compliance audits on e-waste shipments and disposal practices; engage with sustainability and procurement teams to assess supply chain risks; and implement continuous monitoring through data analytics to track e-waste movements and identify anomalies.

Fadeke Ayoola FCCA - CEO, NET Africa