Dhaka’s scrap dealers and the collectors behind them

Dhaka’s scrap dealers sit on a stream the government has tried to formalise once and had blocked once, and the collectors behind them carry on regardless, because nothing about the blockage changes the price of metal. The interesting detail is the reason: Bangladesh’s rules contain reduced standards for lead and are blocked on trade grounds by the World Trade Organization, which means the country’s e-waste policy is currently paralysed by an instrument written for a different purpose. The collectors are the system that works while that is sorted out, and the country’s tonnage is the one nobody is counting.

The Bangladeshi numbers are the region’s third largest, and the description of what happens to them is blunt. The Global E-waste Monitor 2024 records Bangladesh generating over 350 million kilograms of e-waste annually at 2.2 kilograms per person, one of the largest totals in its sub-region, and its assessment is that the country has few licensed dismantlers, that they use basic resource recovery practices that are polluting and unsafe, and that in the absence of formal infrastructure or enforcement the material is mainly handled by the informal sector. That is the measured profile of a collection system that exists and a formal sector that mostly does not.

The rules the government wrote were serious. The Ministry of Environment, Forest and Climate Change issued the E-waste Management Rules in 2021 after nearly ten years of discussions, introducing an extended producer responsibility framework that requires producers of almost all electrical and electronic equipment to register with the Department of Environment, hold an approved e-waste management plan and reach collection targets starting at 10 per cent in 2022 and rising by ten percentage points annually to 50 per cent in 2026. The restrictions on hazardous substances were aligned with those of the European Union. Had implementation followed, the 2026 target would have made Bangladesh one of the more ambitious collectors in the region, and instead the rules have not been implemented at all, blocked over their reduced lead standards, and the collectors continued collecting.

The sub-regional arithmetic says what the blockage costs. Southern Asia generated about 6.1 billion kilograms of e-waste in 2022 with documented formal collection of 60 million kilograms, roughly 1 per cent, against a world figure of 22.3 per cent, and the Monitor estimates that 18 billion kilograms of global e-waste is handled in low- and lower-middle-income countries with no developed infrastructure, mostly informally. Bangladesh’s collectors’ share is the difference between its generation and its formal output, which the international dataset cannot isolate, because the formal output is not being recorded while the policy sits in the blocked state.

Why now is the 2026 target’s arrival, because the year the rules were supposed to have reached 50 per cent is arriving without the rules in force, which is a finding rather than a deadline. The Monitor notes the pressure behind them came from civil society and from international development partners, and the blocking instrument comes from trade policy, which leaves the resolution sitting somewhere between the Ministry of Environment and the trade negotiation that the lead standards belong in. Meanwhile the world’s documented collection rate is projected to fall to 20 per cent by 2030, and the country’s collectors are the only part of its system whose behaviour tracks the actual stream.

The contradiction in the Bangladeshi position is that the collectors solve the problem the rules were written for. Their work is the collection the registration scheme was supposed to create, and the dismantling practices that pollute are the consequence of no authorised facility receiving what they gather, not of any deficit in the gathering itself. A collector delivering into authorised dismantlers against a payment and a record resolves both problems at once, and the WTO block on the lead standards has no bearing on that arrangement. The ministries involved have an unusually clean separation available to them: the trade side can fight the lead-standards battle at whatever pace it likes while the environment side proceeds with a collection framework that does not need the disputed clause to operate.

What should happen in Bangladesh is the separation of the trade question from the collection question, because they are different problems that the current rule set has bundled into one. The lead-standards dispute belongs to the trade negotiations, and the collection framework should proceed independently with a standard that satisfies whichever forum is asking. The collectors should be licensed as the delivery layer the Department of Environment’s registration scheme was supposed to fund, and the dismantling practices the Monitor describes as polluting are the specific thing a licensed collector delivering into authorised facilities would replace first, because basic resource recovery happens where no better facility is being supplied and the supply is the missing piece.

For traders, the Bangladeshi stream is a volume market with an absent paper trail, and its collectors are the supply of a foundry and re-rolling industry that buys by weight and price. The Monitor’s global arithmetic, 91 billion US dollars of metal value in 2022’s e-waste with documented management realising 28 billion, describes what the unrecorded share is worth, and the country’s own formal sector output, if the rules ever move from blocked to operating, is the number that would change its measured share from nothing to something. The Global E-waste Monitor 2024 holds the figures above, and the Basel Convention governs the movements of what the country ships, while scrap.trade handles documented trade between counterparties as the formal share emerges.

Dhaka’s dealers and collectors are carrying a national stream while the country’s policy sits on a WTO hold, and the material has not waited for the rules. The collection network is a fact, and the legal instrument that will eventually licence it does not need to resolve the trade dispute to begin work; it needs to stop being bundled with it.