What to Do with 500 Billion “Things” of the Internet

This article is by guest contributor Joe Kakesh

Much attention has been paid to the “Internet” part of the Internet of Things (IoT).  Concerns about privacy and cybersecurity have been paramount because of increased opportunities for surveillance and data gathering.  Less focus has been paid to the “things” that make up the IoT, which Cisco predicts will reach 500 billion by 2030. These “things” are primarily electronic devices that are manufactured, marketed, used, and often thrown away.  The electronics industry should keep in mind that, while many are looking at security related to IoT device “end of life,” regulators may see IoT as an environmental challenge as well.

As electronic devices have proliferated, electronic waste or e-waste has become a growing concern.  Many states have passed e-waste product stewardship laws that place the burden on manufacturers of electronic devices and others to ensure that the devices are properly managed at their end of life and, where feasible, diverted from the waste stream for recycling, reclamation, or reuse.  We should not expect IoT to be any different, and IoT manufacturers, distributors, and retailers should consider how to approach likely state and federal interest in expanding current end-of-life e-waste product stewardship laws to encompass a wider range of IoT products. 

What are product stewardship laws? E-waste product stewardship laws exist in 25 states and the District of Columbia, and they govern a wide range of electronic devices, including many devices that have network connectivity.  The principle behind them is that manufacturers and others involved in the supply, distribution, and use of their products should to some degree be held responsible for ensuring that the products are managed responsibly at the end of their useful life, rather than be allowed to shift that responsibility to local and state waste management authorities.  The concerns driving state e-waste product stewardship laws are threefold:  (1) potential environmental harms caused by release of electronic device materials into the environment; (2) landfill capacity issues created by electronic devices that are too bulky or difficult to handle through ordinary municipal solid waste facilities without great expense; and (3) the potential commercial value of e-waste upon recovery, recycling, and reuse of valuable commodities. 

How will they affect IoT? Once the things of the Internet reach the end of their useful life, they will likely be considered e-waste, if they are not already.  Each concern identified for e-waste generally is potentially applicable to IoT devices.  First, IoT products are manufactured from the same potentially hazardous materials or rare commodities as many non-networked electronic devices, so the  environmental concerns behind existing e-waste legislation will probably lead some to call for expanding the coverage of their e-waste laws to include more IoT products. 

Second, landfill and solid waste processing and capacity concerns may drive states to aggressive regulation of IoT devices as the devices proliferate among consumers and businesses alike.  Such concerns, along with human health and safety concerns, drove states to implement product stewardship laws for bulky cathode-ray tube (CRT) televisions and monitors beginning in the 2000s.  Those laws have since expanded to cover other products.  Because the size of IoT products can vary widely, from tiny microchips to data centers “wired for the Internet,” the capacity and handling concerns for these products at the end of their useful life could be especially acute as volumes rise.  In addition, as a wider variety of material components enter the e-waste stream, the complexity of sorting processes necessary to deal with them will likely increase, which will in turn increase costs and burdens on state and local governments to manage them, further encouraging them to try to impose the burdens on industry.

Finally, as with many other electronic devices, IoT devices likely contain commodities that have commercial value.  Such commodities may be difficult to recover, but as the number of volume of IoT devices proliferates, the demand for such commodities may increase to a degree that supports innovation and improvement in recycling and recovery technology.

In sum, not all of the interesting regulatory concerns related to IoT are “in the cloud.”  Manufacturers, distributors, and retailers of IoT technology should keep an eye on how the proliferation of IoT technology affects regulators’ concerns about what happens when the products that support IoT connectivity are no longer being used.      


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