Compliance
Retired IT crosses three regulatory regimes at once: data protection, waste classification, and destination-market import rules. A programme that satisfies one and ignores the others is not compliant — it is just uneventful, for now.
Sanitisation you can evidence
Data protection law rarely prescribes a technical method. It requires that you can demonstrate appropriate measures were taken. In practice, that means a recognised standard and a record that names the device.
We scope sanitisation with reference to NIST SP 800-88 Rev. 2, the US National Institute of Standards and Technology guideline on media sanitisation. It is widely used outside the US precisely because it separates the decision (Clear, Purge, Destroy) from the technique, which makes it defensible across different legal environments.
- The decision is recorded. Why a given drive was cleared rather than purged or destroyed, based on media type, classification and intended reuse.
- The verification is recorded. A sanitisation that cannot be verified is treated as a destruction case, not an erasure case.
- The device is named. Serial number, not just a job reference.
- Residual risk is disclosed. Where a device cannot be processed as intended, it is reported as an exception rather than quietly reclassified.
Waste or non-waste: the distinction that decides everything
A used laptop and a hazardous waste shipment can be the same object. What separates them is not the device — it is whether it has been tested, whether it works, and whether anyone in the importing country will actually buy it.
The 2025 change
Amendments to the Basel Convention covering e-waste entered into force on 1 January 2025, adding a comprehensive hazardous e-waste entry (A1181) that reaches whole equipment, components and processing residues — not just loose parts. Equipment that was previously argued to sit outside the controls now generally falls inside them, unless a specific exclusion applies.
The reuse exclusion
Equipment and components that have been tested, shown to work as originally intended for their primary functions, and that have a demonstrated reuse market in the importing country, are not considered waste under the Convention and are therefore outside its trade controls.
The exclusion is conditional on evidence. In practice that means a declaration accompanying the shipment, and test records that can support it.
Tested & working
Functionality verified, declaration issued, reuse market established. Moves as non-waste.
Repairable
Repaired and re-tested before export, or processed domestically. Never shipped as a promise to fix later.
End of life
Managed as waste through licensed downstream facilities, with the receiving party named in the record.
Import rules are tightening, not loosening
The direction of travel across emerging reuse markets is consistent: raise the quality bar, require testing before shipment, and push the cost of failure onto the importer. Two examples show what this looks like in practice.
Kenya
Kenya imports roughly 70% of its electronics, a large share of it second-hand. NEMA has published draft regulations — the Environmental Management and Co-ordination (Electrical and Electronic Waste Management) Regulations 2025 — that would materially change what can enter the country.
- Import of equipment manufactured more than 12 years before shipment would be prohibited, other than for approved museums or certified refurbishment centres.
- Equipment performing below 85% of original specification would be declared waste at the port of entry.
- Importers would file a detailed manifest at least 30 days before shipping, including brand, model, serial number, manufacture date and a functionality certificate from an accredited laboratory.
- Clearance withheld until a compliance certificate is issued, with penalties reaching KSh 10 million or 10% of goods value, whichever is higher.
Standards & conformity
Separately from environmental rules, most destination markets operate a conformity assessment regime at import. Kenya's is administered by KEBS through pre-export verification of conformity, and electrical products face additional requirements — including plug format, where Kenya follows the British BS 546 standard.
- Conformity scope varies by product category and is revised periodically. It is confirmed per shipment, not assumed from a previous engagement.
- Test reports must come from laboratories recognised by the destination authority; a supplier's internal report is not a substitute.
- Labelling and language requirements apply to the product, not only to the shipping documents.
- Non-conforming consignments can be refused clearance, fined, returned or destroyed — the commercial loss sits with the importer.
What lands in your audit file
Deliverables are agreed during scoping, so nothing here is a surprise at closeout. Formats can be adapted to your internal controls.
| Record | What it evidences |
|---|---|
| Intake manifest | That every unit leaving your site was counted and identified at handover. |
| Chain-of-custody record | Who held the equipment at each stage, from pickup to processing. |
| Sanitisation records | Method applied per device, standard referenced, operator and date. |
| Certificates of destruction | That specific serial numbers were rendered unrecoverable, where destruction was the method. |
| Reuse & recycling outcome | Where the material went, and the identity of the receiving facility. |
| Value statement | Final settlement reconciled against the agreed commercial model and the intake manifest. |
What clients ask before signing
Can you destroy data on site, under our supervision?
On-site destruction can be scoped where the asset classification or internal policy requires it, and witnessed sessions can be arranged. It is confirmed during scoping, because it changes logistics and cost. For most fleets, off-site processing with serial-level records is sufficient and materially cheaper.
What happens if a device cannot be wiped?
It is destroyed physically and recorded as a destruction case rather than an erasure case. The distinction matters: presenting an unverifiable wipe as a successful erasure is exactly the failure mode that turns into a reportable incident later.
Do you handle equipment that is already broken?
Yes, but it is processed differently. Non-functional equipment is not reuse material under the Basel framework, so it is either repaired and re-tested before any cross-border movement, or managed as waste through a licensed facility. It is never shipped on the assumption it can be fixed at the other end.
Who pays for collection?
It depends on the lot. Where residual value covers logistics, collection is absorbed into the commercial terms. Where it does not — low-value, bulky or hazardous fractions — collection and handling are quoted as a cost. The answer is given at valuation, not after the truck has been dispatched.
How do you handle batteries and UPS units?
Separately from the general hardware stream. Batteries are classified as a distinct waste stream in most jurisdictions and require different handling and different downstream partners. They are quoted as their own line item and never consolidated into a general load.
Which certifications do you hold?
Certification status is confirmed in writing during scoping, together with the identity of downstream processing facilities and their licences. We do not publish credential claims on this page that cannot be verified against a certificate number — if a specific accreditation is a requirement in your procurement process, tell us and we will confirm whether it can be met before you commit.
Need this mapped to your procurement requirements?
Send us the compliance clause you have to satisfy. We will tell you plainly whether we can meet it.