Right To Repair

To U.S. Trade Representative: We must reduce, reuse, repair and recycle critical minerals

In response to the Office of the United States Trade Representative (USTR) request for comments on U.S. supply chain resilience, on behalf of PIRG, I submitted the following letter urging policy to focus on reducing, reusing, repairing and recycling electronics that require critical minerals before engaging in more damaging extraction.

First page of submitted comments, letter text continues below.Photo by Staff | TPIN

April 22, 2024

Promoting Supply Chain Resilience

Comments concerning critical minerals and electronic waste

Docket Number USTR-2024-0002

This May 28, 2024 pre-hearing submission is focused on the issue of critical minerals.

Critical minerals are needed for life saving medical devices, our country’s green transition and many other essential products. Their importance makes it all the more absurd that Americans are throwing away these valuable finite resources in the form of electronic waste at the rate of 8 million tons each year.

Electronic waste is the fastest growing waste stream in the world and the U.S. generates more than nearly every other country in the world. PIRG advocates to reduce harmful or needless manufacturing, reuse what we already have produced and recycle the rest—until we achieve zero waste. In the electronics space, we campaign for the Right to Repair, which removes barriers to repair and reuse. We also work to ensure all the products we use are designed to last, and not part of an endless treadmill of disposable devices. 

We’ve been campaigning more and more around electronics, because of the unique ways that electronics manufacturing, e-waste, and the extraction of critical minerals powering these devices threaten our health, climate and environment. To address concerns around finite, valuable, and necessary critical minerals our first step should be to stop wasting materials by manufacturing them into unfixable or disposable products.

The United Nations’ 2024 Global E-Waste Monitor found that rare earth elements are critical for future green technologies but less than 1% of our supplies come from recycling.

Rare earth elements are critical minerals used in magnets, memory storage, electric cars and buses, e-scooters, and other necessities for a future without the air pollution that causes climate change. Ninety-nine percent of the elements we use to meet demand comes from extraction, while less than one percent are from recycled materials. Our current recycling system is not capable of creating a circular economy for these elements.

Instead of opening new destructive mining operations, we should stop wasting the critical minerals we use in products that are destined for the dump. Too many consumer electronics have glued-in batteries that act as timers counting down their lifespan. No device should have consumable batteries that can’t be replaced when they die. These products, including Apple Airpods, aren’t designed to last, taking rare earth elements such as neodymium and dysprosium with them to the landfill. After disposal neodymium can cause adverse health effects and dysprosium can present an explosion hazard.

The Global E-Waste Monitor announced that vape waste is a ‘major e-waste contributor’ and is getting worse.

Disposable e-cigarettes, better known as vapes, have become a pervasive part of our society. The vape market is expected to grow by 31% annually until 2030 and vape waste could grow at an equally dangerous rate. Nothing used for a day or two should pollute our environment for hundreds of years. According to CDC Foundation sales estimates, lining-up the disposable vapes sold in a year would stretch for 7,000 miles—long enough to span the continental U.S. twice. Because of their nicotine residue and glued-in batteries, there’s no standard legal way to recycle these products—meaning many users just toss them and the critical minerals they contain. U.S. PIRG Education Fund’s Vape Waste report found that Americans throw out 4.5 disposable vapes per second.

The United Nations found the vape batteries produced in 2022 contained 286,000 pounds of lithium. Mining for and disposing of this element can have negative environmental repercussions. The report points out that although lithium recycling is technically feasible, it’s not economically viable under current conditions. In 2022, only 13,000 pounds of lithium were recovered from all e-waste. That’s less than 5% of the lithium needed to power disposable vapes just that year.

Dozens of countries around the world have banned disposable vapes. In the U.S., lawmakers across the country have introduced some 48 bills that ban, partially ban, or implement recycling programs for vapes. We need to ban disposable vapes wasting our finite resources. Retailers and franchisees such as 7-Eleven, Mobil, Citgo and others that have received warnings from the U.S. Food and Drug Administration should also stop selling these products.

Start with reduce, reuse, repair, recycle.

The UN E-Waste Monitor found that electronics manufacturing is growing five times faster than recycling. Even though global recycling is growing at a rate of 30 billion pounds per year, it can’t keep up with our insatiable manufacturing of electronics. The only way recycling can work is if we manufacture much less, starting with the stuff that shouldn’t exist at all. Right now, only 22% of global electronic waste is recycled. Our social norms of buying, using, and tossing phones, laptops, and other electronics can’t continue at this rate.

The first step to resilient supply chains is to stop throwing out the valuable and necessary critical minerals used to manufacture short-lived products with glued-in batteries and limited lifespans. Consumers and the environment deserve better than a world where nothing is designed to last.

Our supply chain resilience policy should focus on reducing, reusing and recycling the electronics that require critical minerals before engaging in more damaging extraction. By slowing the flow of e-waste and extending the lifespan of a wide variety of products, we can reduce pressure for new forms of mineral extraction and lay the foundation for a sustainable circular economy in critical minerals for decades to come.


Lucas Rockett Gutterman
Designed to Last Campaign Director

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