
From Mohamed El-Fatatry
As a Finnish citizen and a member of the electronic waste recycling industry in Malaysia, I feel compelled to respond to Michael Soh’s letter titled “Hypocritical to label Malaysia a dumping ground for e-waste” (March 5, 2025).
While I appreciate Mr Soh’s interest in highlighting success stories from other countries that are net importers of e-waste, several claims in his letter require factual correction, particularly when comparing Malaysia’s e-waste management system with that of my country, Finland.
But before we start, let’s get some facts straight:
- Finland is not a huge net importer of e-waste as the author claims.
- The mentioned company, Boliden Rönnskär is not even in Finland.
The Finnish recycling infrastructure and green technology development were meant to address local e-waste first, and only after they reached high levels of productivity almost 15 years ago did large scale imports start.
Imagine if we solve the domestic collection problem and harness more than 300,000 tonnes of domestic e-waste in Malaysia. That would be 1.5 times more than the total amount of e-waste Germany imported in 2022.
Believe it or not, such infrastructure already exists in Malaysia but it needs to be scaled up rapidly. Lack of awareness and market fragmentation are slowing us down.
European recovery facilities pay a lot less for, and even slap penalties on e-waste that does not contain a high concentration of valuable metals.
This means they cherry-pick e-waste, taking only that which has a high concentration of valuable metals and low in plastic and resin. They can therefore offer high prices for such material.
This means that pre-processing needs to happen at “filter” countries where all the low-value and polluting materials are filtered out first, before the containers of high-grade materials is economically viable to be processed in Europe.
Malaysia should not fall into this trap of becoming one of those “filter” countries. It is a question of national sovereignty and the government’s decision should be respected.
My company would easily gain millions of dollars per year if Malaysia allows the import of e-waste. However, I do not believe that creating shareholder value should come at the expense of clean water and soil for future generations.
Economic growth should not come at the expense of permanent damage to irreplaceable things.
Collection infrastructure and accessibility
Finland’s collection system demonstrates how effective e-waste management should function. Finnish residents benefit from an extensive network of collection points with at least one such point per municipality.
There is no charge for leaving e-waste at these collection points, which are accessible across the country, making it is an effortless process.
Finnish retailers also have a legal obligation to accept e-waste when consumers purchase new equipment, with larger stores required to accept small e-waste items without any purchase.
But more importantly, citizens are happy to put in the effort to recycle their e-waste material and do not expect any rewards for it.
In Malaysia, the situation differs dramatically. Facilities and infrastructure designated by the government for waste disposal primarily serve industry-generated waste, not household e-waste.
Malaysian households rely largely on informal channels such as general waste collection, charities, door-to-door collectors, and individual waste-for-recycling buyers.
This lack of formal infrastructure results in significant amounts of e-waste being improperly disposed of or handled by the informal sector, which mostly processes them without regard for human health and pollution concerns.
Given that these practices have been in place over many decades, Malaysian consumers now expect someone else to do the heavy lifting. Worse than that, they also expect to get cash compensation for their recyclables.
This means that ready access to imported e-waste will most certainly cause licensed recovery facilities to neglect the local e-waste problem.
Even if the imported e-waste is processed in “green facilities”, the nation will be swamped with domestic household e-waste which will certainly pollute the environment for generations to come.
Finland already achieved 88% domestic e-waste collection rate in 2010, whereas Malaysia is barely at one third of that level 15 years later.
Even if it makes sense for Finland to import the e-waste, we still have a lot more homework to do in terms of domestic e-waste collection and recycling in Malaysia, before we shock the system with hundreds of thousands of tonnes of imported e-waste.
Producer responsibility and funding mechanisms
The Finnish system operates on a comprehensive producer responsibility principle.
Manufacturers or importers of electrical equipment in Finland bear full responsibility for the cost and logistics of their products’ end-of-life management.
This operation is funded through recycling fees included in product sales prices, creating a sustainable financing mechanism.
Malaysia’s producer responsibility framework for e-waste remains underdeveloped. The current system places minimal financial or logistical responsibility on producers, resulting in inadequate infrastructure and public awareness campaigns.
Mr Soh’s claims overlooked this critical difference between the two countries’ approaches.
Collection rates and processing
Finland has not only implemented but exceeded the European Union’s collection requirements in a relatively short time.
The total rate of electrical and electronic waste recovery in Finland is over 88%, far above the global average.
Finnish e-waste is processed primarily within Finland at regulated treatment facilities, minimising environmental impact through proper handling.
Global data shows stark disparities in e-waste handling, with Europe achieving a 42.8% collection and recycling rate, while regions with less developed systems struggle with rates below 10%.
Malaysia falls into this latter category, with insufficient formal collection infrastructure for household e-waste, leading to lower recovery rates and more informal processing.
Legislative framework and implementation
Finland has implemented a comprehensive e-waste management system based on three primary laws: the Waste Act 646/2011, the Government Decree on Waste Electrical and Electronic Equipment 519/2014, and the EU Directive 2012/19/EU.
This robust legal framework specifically addresses e-waste collection, treatment, and recovery.
In contrast, Malaysia regulates e-waste under the Environmental Quality (Scheduled Wastes) Regulations 2005, categorising it as scheduled waste under code SW 110.
Unlike Finland, Malaysia still lacks specific regulations dedicated to e-waste management. While guidelines exist for classification, they do not constitute enforceable legislation with clear targets and requirements.
Before opening the flood gates to international e-waste, we need to ensure that Malaysia’s legislative framework is comprehensive and up-to-date.
Conclusion
Acknowledging Malaysia as a recipient of improper e-waste shipments is not hypocritical but necessary for addressing this global environmental challenge.
Rather than denying existing problems, we should focus on implementing proven solutions, such as Finland’s comprehensive producer responsibility system, accessible collection infrastructure, and strong regulatory framework.
Let’s focus on our domestic problem first, and only after we reach high e-waste collection and recycling levels domestically, can we consider helping other countries deal with their e-waste.
Malaysia has made progress in drafting regulations for household e-waste, but significant gaps remain between our current system and best practices exemplified by Finland.
By acknowledging these differences and learning from successful models, Malaysia can better protect its environment and citizens from the hazards of improper e-waste management.
Meanwhile restricting the flow of international e-waste until the domestic problems are solved is the only reasonable path forward.
Expecting e-waste imports to be a magic wand that can solve all domestic problems is a fairy tale. - FMT
Mohamed El-Fatatry is an FMT reader as well as founder and managing hero at Khazanah-backed Electronic Recycling Through Heroes (ERTH).
The views expressed are those of the writer and do not necessarily reflect those of MMKtT.