Guidance is also provided on selecting certified disposal services and e-waste recyclers. If using a third party, the Bureau recommends using a company that provides complete asset management solutions, from removal to destruction, including transportation and chain of custody tracking to avoid the potential for misplaced or lost equipment containing sensitive information. Providers may utilize one company for the entire disposal and recycling process, or different companies for different aspects of the disposal and recycling process based upon the categories of covered communications equipment outlined above.22 Because the Commission in the 2020 Supply Chain Order prohibited the transfer of operable covered communications equipment or service to non-U.S. providers, we recommend providers use U.S disposal companies that conduct the disposal process on U.S. soil.23. Equipment is still considered operable until it is properly disposed.
In particular, we recommend providers use a U.S. disposal company registered with the U.S. Department of State’s Directorate of Defense Trade Controls pursuant to the International Traffic in Arms Regulations (ITAR).24 We agree with Advanced Technology Recycling that “utilizing ITAR processing guidelines is an ideal mechanism to ensure sensitive electronics as outlined in the [Secure Networks Act] are properly disposed of in a manner that protects national security.”25 While the covered communications equipment may not fall within the scope of ITAR,26 we find that an ITAR-registered disposal company will likely have the procedures in place and the facilities necessary to effectively handle the safe and secure destruction of covered communications equipment, including the most sensitive equipment.
We find that, based on the record, ITAR–registered companies likely can provide complete asset management services, including tracking equipment, maintaining records, and documentation and certifying destruction. According to Advanced Technology Recycling, “ITAR registered service providers must follow strict disposal guidelines to ensure scrap materials generated throughout the disposal process remain on U.S. soil and be processed exclusively by U.S. persons.” ITAR–registered companies are required to maintain records concerning manufacture, acquisition, and disposition of defense articles, including technical data, subject to ITAR, and are subject to civil and criminal penalties for violations.
According to Advanced Technology Recycling and Gannon & Scott, ITAR–registered companies may also hold e–waste recycling or other certifications and provide media sanitization services, allowing for a one–stop disposal facility to handle the disposal of different categories of equipment according to the best practices outlined in Appendix A. We agree with Teltech Group that through the disposal process we should “consider environmental issues” so that the covered communications equipment “do not create environmental problems.”33 Accordingly, the Bureau recommends for providers to recycle covered communications equipment to ensure the secure and environmentally responsible disposal of equipment as recommended by the Environmental Protection Agency (EPA).34 Consistent with EPA guidelines, the Bureau recommends utilizing electronic waste (e–waste) recyclers that are certified by either the Responsible Recycling (R2) Standard for Electronics Recyclers or the e–Stewards Standard for Responsible Recycling and Reuse of Electronic Equipment (e–Stewards).35 As noted above, ITAR–registered companies may also hold R2 and e–Stewards certifications. For example, according to Advanced Technology Recycling, as an ITAR–registered disposal company, disposal processes are “carried out … at R2 certified and ITAR registered facilities.
Advanced Technology Recycling (ATR) is R2 Certified and registered with the U.S. State Department, and authorized to provide secure disposal solutions under the rip-and-replace telecom act. Additionally ATR offers a secure chain of custody that meets and/or exceeds all Federal logistics guidelines for all types of Huawei and ZTE equipment that requires U.S. based disposal solutions under the rip and replace act.
ATR has established Secure Destruction Services (SDS) comprised of compliance, legal, logistics and operational professionals with additional capabilities and security clearances to manage ITAR controlled material streams. ATR can customize a program that meets or exceeds all requirements outlined in the rip and replace act.
Additionally, ATR owns a fleet of portable destruction devices that can be brought directly to our customers’ facilities when transportation to our secured facilities isn’t feasible.
Assets are individually tracked by serial number, weight, origin, dates and product type. Material reports are available through our FIPS 140-A compliance web portal. Customers can also use our online tools to create shipping manifests, define PPE gear required for each project and track load progress. Global reporting is readily available to the sustainability managers that monitor enterprise sized businesses.
To protect our customers’ branding we have implemented a zero landfill policy on ITAR controlled materials and qualify each downstream vendor to ensure all recoverable commodities remain on US soil. ATR is authorized by the US State Department and Homeland Security to provide SDS (Secure Destruction Services) to highly volatile waste streams for Aerospace, Defense and all federal agencies including the FBI, FAA and the US Border Patrol just to list a few.
“Rip and replace” telecom equipment manufactured by Huawei and ZTE fall under the ITAR (International Traffic and Arms Regulations). If you are a U.S. based telecom provider with 10M or less customers and required to rip and replace Huawei and ZTE equipment let us customize a program for you today.
For more information on ATR rip and “replace disposal services” for +Huawei and +ZTE branded telecom equipment emails us at Support@ATReCycle.com or call toll free 1-877-781-7779.
