The European Union is recognised for its strong environmental policies, yet much of its waste is dumped abroad. Aliyu Umar Sadiq explores what happens when used electronics are exported from the EU to Nigeria.
Aliyu Umar Sadiq is a Visiting Researcher at the European Environmental Bureau (EEB), and a Co-Founder of Ecocykle Development Foundation, a Nigerian NGO.
The export of second-hand products from the EU to Africa can benefit receiving countries, providing wider access to affordable goods. But when the fees that producers pay to finance waste treatment – the so-called Extended Producer Responsibility (EPR) fees – remain in Europe, African countries are left to handle the waste management of imported products without the necessary support.
This places an unfair, heavy burden on emerging African economies, as shown by a study on the implications of second-hand electronics and vehicles exports from Europe to Ghana and Nigeria, published by the EEB.
Environmental NGOs have long called for an update of the EU law on electronic waste – the Waste Electrical and Electronic Equipment (WEEE) Directive – to take on Europe’s mounting e-waste crisis and close the gaps in producers’ responsibility.
As the EU revises the Directive and prepares a circular economy act, expected in 2026, this is a crucial time to rethink the EPR system, and ensure it extends beyond EU borders, covering products wherever they reach.
How does EPR work?
Extended Producer Responsibility (EPR) is an environmental policy approach that holds producers accountable not only for making products, but also for managing them once they become waste. In the EU, it is rooted in the ‘Polluter Pays Principle’, the idea that those who cause environmental harm should cover the costs.
EPR schemes have already been introduced in many sectors, including batteries, packaging, electronics, and textiles. But how do they work?
In the EU, producers mostly pay EPR fees to Producer Responsibility Organization (PRO), with the expectation that these funds will ensure the safe management of their products when they become waste. Yet, a shortcoming of the EU EPR system is that the fees do not transfer outside EU borders. This means that, when used electronics are exported outside the EU, the money collected to fund their treatment stays in Europe, leaving receiving countries to foot the waste management bill.
Ibukun Faluyi, Executive Secretary of Extended Producers Responsibility Organization of Nigeria (EPRON), linked this issue to policy gaps:
The WEEE Directive does not make provision for products that are shipped out of EU countries; without the enabling law, it is difficult to achieve the EPR fee transfer between countries for the waste management of imported electronics in receiving countries like Nigeria.
Used electronics exports and policy gaps
The number of electronic devices placed on the EU market almost doubled, soaring by over 98% between 2013 and 2022. This sharp increase also drives the generation of e-waste, which contains a mix of harmful additives and dangerous substances posing risks to human health and the environment.
The EU WEEE Directive, adopted in 2002 and later revised in 2012, has so far failed to address the issue of illegal exports. In fact, the recently published Evaluation report shows that illegal export have increased.
In 2020, an estimated 0.5 million tonnes of WEEE (4.8%) were illegally exported from the EU, alongside 0.6 million tonnes (5.7%) of used electrical and electronic equipment exported for re-use. A further 1.5 million tonnes (14.4%) of WEEE were unaccounted for, much of it likely exported under the label of second-hand electronics.
In fact, the EEB report revealed that many products exported as ‘second-hand’ are in fact non-functional or outright waste, making them unsuitable for reuse. Besides, even the functional goods eventually reach the end of their life within a few years, adding to the waste burden.
Altogether, around 2.6 million tonnes of WEEE – about a quarter of the total generated in the EU – may have been shipped abroad, contributing to serious environmental and health problems in receiving countries.
Ibrahim Musa, Assistant Director at the National Environmental and Standards Regulatory Enforcement Agency of Nigeria (NESREA), emphasised that while national legislation outlines clear EPR guidelines and procedures for importing used electronics, enforcement has been weakened by several gaps, allowing the continued illegal shipment of e-waste:
Key challenges include porous borders, corruption, poor coordination among relevant stakeholders, and shortcomings in the enforcement of the legal framework.
As Ibrahim noted, while authorities often intercept vessels carrying electronic waste, prosecutions are rare, and most vessels are simply sent back without further consequences.
This failure has cost African economies an estimated €340–€380 million each year in lost EPR fees, based on the volume of used electronics traded. Closing these gaps is crucial, not only to mitigate the environmental and health risks from used electronics, but also to promote sustainable development in both the EU and its trading partners.
The case for direct fee transfers
When asked about the most viable way to transfer EPR fees to support the waste management of used electronics in Nigeria, stakeholders unanimously recommended a direct transfer from exporting-country PROs to Nigeria’s designated PRO.
Nigeria operates an industry-led PRO system, with EPRON as the body responsible for overseeing the end-of-life management of electronics. Stakeholders suggest that EPR fees should be calculated and remitted on the basis of the reported volume of used electronics exported.
Prof. Nnorom Innocent, Senior Research Associate to the Basel Convention Coordinating Centre for the African Region, said:
To ensure environmentally sound management of EU-origin e-waste in Nigeria, the fees collected under EPR schemes should be transferred alongside shipments of used electronics into the country.
Improving e-waste traceability
Addressing illegal exports and improving tracking of used electronics at both EU and Nigerian borders remains a key challenge. For Ibrahim Abdullahi, this could be handled by stationing Pre-Shipment Enforcement Officers at ports. These officers would verify labels, assess product conditions, and ensure that they meet the requirements of usable products before passing through the borders.
On the European end, these efforts could be supported by dedicating sufficient financial resources to the agencies responsible for such border checks, establishing a robust system to collect data on the exported and imported used electronics, and setting concrete and harmonised criteria to distinguish reusable electronics from e-waste within the revised WEEE directive.
Prof. Nnorom Innocent, reinforced this recommendation by citing lessons from the Person in the Port Project, which for the first time quantified and qualitatively assessed used electronic equipment imports through Lagos ports in 2015–2016.
Notably, he highlighted that physical verification at ports in exporting countries could help estimate the quantity of used electronics shipped, and the equivalent EPR fees due:
If you place someone in ports, both at the point of export and at the receiving end, for two to three months, you can collect data and extrapolate the appropriate fees to be transferred.
On the other hand, Ibukun Faluyi, while acknowledging the viability of physical verification, recommended the Digital Product Passport (DPP) as a more effective and long-term solution for tracing used electronics across borders. However, Ibukun also emphasised that the DPP will take more time to be adopted for all electronics. In her opinion, the physical verification option could be associated with increased administrative costs. Ultimately, she recommended a hybrid approach that combines both physical verification and DPP for strengthening the traceability of used electronics and preventing the export of waste.
In addition, Ibukun stressed the importance of capacity building for local technicians. Despite a strong repair culture in Nigeria, poor repair services and high repair cost are additional factors that turns used electronics into e-waste. Therefore, Ibukun called for technical training repair programs to be included in EPR schemes, to help improve the durability of used electronics.
Ensuring EPR fees reach the right place
The movement of used electronics through multiple borders before arriving at their final country of destination, especially for landlocked countries, is a potential challenge to the direct transfer of EPR fees.
To guarantee that EPR fees reach the right destination, Prof. Nnorom Innocent proposed tracking used electronics shipments using either the destination country indicated on the shipping register, or the recipient’s address, where available. This approach would help ensure that funds are distributed to the countries where the products will ultimately become waste, reducing misallocation and aligning financial responsibility with the actual point of environmental impact. Regular verification and checks on site could also be envisaged.
Closing the loop, globally
With the ongoing revision of the WEEE Directive, and a potential reform of EPR rules in the Waste Framework Directive as part of a new EU Circular Economy Act, Europe must take responsibility for the used electronics it exports, and for its own e-waste.
These Nigerian insights can help build a more robust and global approach to the waste management of used electronics produced in the EU.
By considering these perspectives and integrating them into policy measures, the EU can hold producers accountable for their products across their entire lifecycle, and build a more inclusive and sustainable circular economy that works for people and planet – within and beyond EU borders.