Assessment of the Impact of the Revised National E-Waste Framework on the Informal E-Waste Sector of Nigeria

Abstract

E-Waste management in Nigeria remains predominantly informal, with unlicensed collectors focusing on extracting valuable materials, primarily for export. Despite policy interventions, including the revised 2022 E-Waste framework and the Global Environment Facility (GEF) project, which introduced collection centers in Lagos and bolstered Extended Producer Responsibility (EPR), progress has been uneven. This comparative longitudinal study examined informal E-Waste processing practices over a six-year period (2017–2023) to evaluate the impact of these initiatives. Using a mixed-methods approach, including content analysis and field interviews with informal collectors, government officials, and NGOs, our findings reveal that profit is the primary motivator for informal collectors, while E-Waste fractions that are not considered profitable are often discarded in environmentally harmful ways. The findings indicate persistent noncompliance with regulations and stagnant or declining income levels for informal collectors. The revised 2022 regulation resulted in a significant increase in registrations, with EPRON recording its highest number of producers, with 39 in total, including 25.6% renewals and 74.4% new registrations. Although the revised framework and EPR efforts have achieved limited success, critical gaps in implementation and outreach remain, with minimal improvements in collectors’ awareness of health and environmental risks. This study underscores the need for targeted training and financial incentives to redirect E-Waste flows toward formal channels, thereby more effectively safeguarding the environment and wellbeing.

1. Introduction

Nigeria, just like some other developing countries, is presently facing challenges with electronic waste (E-Waste) management. Considering that E-Waste, which is unwanted, surplus, non-working, or obsolete electronic appliances with grid power or battery supply [1], contains hazardous (e.g., lead), non-hazardous materials (e.g., steel), and precious metals (e.g., gold), it is important that appropriate management routes are adopted. Globally, E-Waste management is a significant source of environmental pollution, particularly in developing countries, where regulation is either absent or poorly enforced [2]. This issue also poses serious health risks, including respiratory problems from toxic fumes, heavy metal poisoning (e.g., lead, cadmium), and neurological disorders caused by exposure to hazardous materials. These risks have been well documented in the literature [3], highlighting the severe impacts on both workers and surrounding communities. Additionally, developing countries face major challenges, such as inadequate funding for E-Waste management and a lack of dedicated E-Waste collection and treatment infrastructure [4]. As a result, informal operators often resort to inappropriate methods for retrieving valuable components, exacerbating the environmental and health impacts.

E-Waste management activities in Nigeria are unregulated and dominated by informal operators, whose main goal is to recover valuable materials in small workshops and open sites using rudimentary crude material recovery techniques like cherry picking of metals from TV and cathode ray tube (CRT) monitors. The workforce in Nigeria’s informal E-Waste sector is primarily composed of men and young boys. The 2024 Global E-Waste Monitor highlighted that women, often restricted to roles such as collectors (and in some cases sorting and record keeping), face not only limited negotiating power but also exclusion from decision-making processes, a reality that reflects broader socio-economic and cultural marginalization [5]. Women in this vocation, which is perceived as dirty, are generally relegated to low-wage and high-risk activities, positioning them at the periphery of the sector that profits from their labor. Importantly, these gendered power imbalances are further compounded by the informal nature of the sector, where workers, regardless of gender, are often excluded from social safety nets, making it particularly difficult for women to challenge exploitative conditions [6].

E-Waste mismanagement is a critical issue in developing countries, and various nations have attempted to address it through Extended Producer Responsibility (EPR) initiatives, with varying degrees of success. In Ghana, the introduction of EPR laws aimed at improving the formal recycling of E-Waste has had limited success. While the formal sector has seen some progress, informal operators remain dominant, and the lack of effective enforcement continues to contribute to widespread environmental contamination and health risks [7]. Similarly, in Kenya and South Africa, EPR laws have been enacted to reduce the environmental impact of E-Waste, but challenges persist in enforcement, and informal recycling practices continue to exacerbate public health and environmental concerns [8]. India, another key example, has a comprehensive EPR framework; however, despite legislative efforts, informal E-Waste processing remains pervasive, with significant adverse impacts on both human health and the environment, particularly in cities like Delhi [9]. The Nigerian context shares many of these challenges [2].

The common approach adopted for management includes cracking copper wire and burning cables to recover copper wires, which often results in environmental pollution [2]. Non-valuables components such as CRT glass and plastics are dumped and burned [10,11]. Studies have shown that these activities cause harm to human health (via ingestion, inhalation, and dermal contact), especially to informal workers and persons residing within the neighborhood, as well as the contamination of air, soil, water, and sediments [12,13,14,15]. Most informal E-Waste operators work without personal protective equipment (PPE), and this exposes them to a cocktail of toxins, with various negative health effects. Though E-Waste collection and treatment infrastructure are insufficient in the country, citizens are not patronizing existing facilities and prefer to channel E-Waste to the informal sector due to the financial incentives they offer. Usually, informal operators use a house-to-house collection approach and often pay a token for certain obsolete devices from households and businesses. There have been some improvements in policy and guidance in the E-Waste sector in Nigeria in recent times, including (i) completion of the GEF project, which among other measures supported a revision of the 2011 Electrical Electronic EE sector regulation in 2022 to provide for funding mechanisms and provided collection centers/receptacles in Lagos, and (ii) the introduction of a manual by national E-Waste producer responsibility organization (the E-Waste Producer Responsibility Organization, EPRON) in 2023.

This study is a follow-up on the Person in Port (PiP) project [16], which was carried out within the overall framework of the United Nations University (UNU) in collaboration with the U.S. Environmental Protection Agency (USEPA), the Basel Convention Coordinating Centre for the Africa Region (BCCC-A) in Nigeria, and Deutsche Gesellschaft fur Internationale Zusammenarbeit (GIZ). The PiP study focused on Nigeria, and it assessed the quantities, types, sources, conditions, and functional status of used electrical electronic equipment (UEEE) imported into Nigeria through Lagos ports between 2015 and 2016 [17]. The study observed that about 11% of the imported UEEE were non-functional with many of them ending up at a refurbishment outlet or in the informal sector. The PiP approach was adopted by McMahon et al. [18], and their report standardized the PiP approach for E-Waste flows studies.

The Global Environment Facility in conjunction with the UN Environment implemented a USD 15-million initiative to promote a circular system for EEE in Nigeria between 2019 and 2023. The aim of the project was to reform the E-Waste sector of Nigeria and put an end to the toxic toll improper management of electronic waste is taking on Nigeria, considering that more than 100,000 people work in the informal electronic waste sector in Nigeria. The USD 15 million initiative titled Circular Economy Approaches for the Electronics Sector in Nigeria project was coordinated by the National Environmental Standards and Regulations Enforcement Agency (NESREA) and brought together key stakeholders from government, the private sector, civil society, recyclers, and EPRON to kickstart a financially self-sustaining circular economy approach for electronics in Nigeria. It was anticipated that the project would facilitate ESM for E-Waste, create safe employment, and ensure protection of the health of the operators and the environment. The GEF project supported the implementation of Extended Producer Responsibility (EPR) legislation and resulted in the publication of a revised E-Waste framework in January 2023. The proposals underpinning the revised legislation would strengthen the EPR program, making producers accountable for the end of life (EoL) of their products and reducing pollution from the electronics sector. With the revised legislation, manufacturers, importers, and retailers of EEE are now legally and financially responsible for the management of the EoL of their products.

Building on the work of Odeyingbo and colleagues [16] and the PiP project, this study focuses on understanding the value chain of informal E-Waste management in Nigeria and assessing the impact of E-Waste operators’ activities throughout the flow network. A key objective was to identify hotspots through a comparative investigation of informal operators in Lagos. In this context, hotspots refer to points or stages within the network where unsustainable practices such as material loss, environmental pollution, and human exposure to toxins are most prevalent. The aim was to evaluate the impact of recent developments in the E-Waste sector and determine whether improvements have occurred at these critical stages. The first phase of the study was conducted in 2017, with a follow-up phase carried out six years later in 2023, to monitor changes in the practices of informal operators and the overall sectoral dynamics.

Thus, the current study sought to answer the following research questions:

• What are the key hotspots in the E-Waste value chain network in Lagos, Nigeria, and how do they contribute to E-Waste mass flow?
• What roles do informal operators play within the E-Waste flow network, and how do their activities shape the sector?
• What are the economic and environmental impacts of activities at the identified hotspots, and how can these be assessed both quantitatively and qualitatively?
• What reorganizational options are available to ensure the environmentally sound management (ESM) of E-Waste in Nigeria?

EE Regulation (2022) and Recent Developments

The revised 2022 regulation led to increased registrations, with EPRON recording the highest number of registered producers since its inception, totaling 39 producers (comprising 25.6% renewals and 74.4% new registrations). The GEF project provided a detailed roadmap and implementation plan for enforcing the EEE regulations, strengthened Nigeria’s EPR system, and laid a legal basis for its enforcement. The key achievements of the GEF project are summarized thus:

• An amendment of the 2011 National EE Regulation with defined roles for stakeholders and implementation of mandated EPR.
• Development of the Black Box software, on Microsoft Azure version 1, which is a registry through which the market shares of producers are determined to enable EPRON to collect EPR levies. The levies are used to support recyclers and collectors, raise awareness, conduct research, establish standards, and EPRON administrative duties and research. The BlackBox is expected to provide a comprehensive database of producers and importers, for the management of producers’ market share data and the calculation of EPR fees for different product categories [19].
• Development of a Guidance Document for EPR implementation [20] with technical support from UNEP and international stakeholders. The Guidance Document defined the roles and responsibilities of different stakeholders and set time-bound targets for the effective implementation of the EPR scheme in Nigeria.
• Initiated a pilot E-Waste collection that constituted the first national E-Waste collection and recycling target. The E-Waste collecting and recycling pilots are in line with the new requirements of the Guidance for EPR implementation, to understand the local treatment cost for different EEE categories covered by the EPR system.

The amended EE regulations strengthened Nigeria’s EPR and made manufacturers, importers, and retailers legally and financially responsible for the management of their EoL products. This encourages resource conservation and increased recycling, while importers are no longer allowed to import non-functional electronics into the country. If well implemented, the EPR scheme will promote resource conservation and enhance recycling rates with proper management of hazardous fraction, while encouraging manufacturers to design eco-friendly alternatives. Importers are now no longer allowed to import non-functional electronics into the country, and they are also mandated to register with EPRON and subscribe to the EPR scheme [21].

The revised regulations bind all manufacturers and importers of EEE, E-Waste collection centers, and recycling facilities to register with the E-Waste Producer Responsibility Organization of Nigeria (EPRON), marking an essential step towards the operationalization of a financially self-sustaining circular electronics network. EPRON manages the EPR scheme, and this is regulated by the government. EPRON is in the process of establishing a registry through which the market shares of producers will be determined, to enable EPRON to collect the EPR levies. The levies will be used to support recyclers and collectors, raise awareness, conduct research, establish standards, and for EPRON’s administrative duties and research. The EPR scheme’s effectiveness is hampered by a lack of adequate take-off funds. EPRON recently developed a manual for E-Waste collectors and is presently test-running the training of collectors around the country.

Other outcomes of the GEP/UNEP project, as announced at the project closing ceremony in May 2023, included awareness creation and the funding of the collection and recycling of about 300 tonnes of E-Waste in Lagos in collaboration with some E-Waste recyclers. The GEF project also had an impact beyond Nigeria through the development of a practical circular electronics model for Africa and beyond, by sharing best practices, promoting regional and global dialogue, and engaging global manufacturers.

2. Results and Discussions

2.1. Demography

The demographics of the study groups for the research conducted in 2017 and the recent study of 2023 are presented in Figure 1. There are similarities in the demographic information, and this shows that the business is dominated by males, mostly in the 19 to 30 years age range.

Most of the respondents had a minimum of primary school education and had been in the E-Waste collection business for more than 3 years (Figure 2). The data further reveal the involvement of respondents having tertiary education in 2023, which was lacking in 2017, perhaps due to more awareness creation and the impact of the policy attracting more educated people into the business in 2023.

2.2. Operations of the Informal Collectors

The findings from the study show that the activities of the informal collectors were found to be unregulated. The scavengers either collect materials from local dumpsites, roadside containers, or directly from households. Many households in the study area often sell EoL products which have a net scrap value to the scavengers (of several types), mostly of small capacities, for the collection and transportation of E-Waste and other recyclables, which they take home and store in their backyards to accumulate before they are sold. The typical management approach involves the collection, cutting, sorting, and transportation of materials to designated locations for sale. The data for 2017 and 2023 have striking similarities. In both years, the operators indicated that they did not operate as registered businesses, rather they focused more on maximizing financial gains, with little or no attention paid to their safety and environmental protection. They separated electronic waste from general waste, focusing on specific valuable components like copper cables, circuit boards, and aluminum parts.

Most collectors preferred to dismantle and separate components (84% in 2017 and 80% in 2023) to make more money than from selling the E-Waste collected to the recyclers without preprocessing. Depending on the condition of the collected devices, they may repair and sell for reuse (14% in 2017 and 6% in 2023 followed this route).

For both years, 60% of the respondents indicated that not all E-Waste collected was valuable. The operators pointed out that though they source and collect E-Waste from diverse places such as homes and waste dumpsites, they get more from refurbishers and repairers of electronics. They accumulate E-Waste and other scrap materials, and then dismantle E-Waste to retrieve valuables such as copper wire, steel, printed wiring board (PWB), and other valuable metals. The retrieved valuable components were sold to unregistered E-Waste dealers (merchants) in 2017, but in 2023 there were diverse sale options for the E-Waste collectors. Selling the collected E-Waste components to government accredited collectors without dismantling the E-Waste after collection was now an option, which served as a substitute for the informal dealers who were readily available to buy valuable dismantled E-Waste components.

Although regulatory bodies such as the Lagos Waste Management Authority (LAWMA) have banned the burning of cables to recover copper wires, operators continue to engage in this practice at night, when the regulators are off duty. Recovered valuable materials are sold to merchants (sometimes through intermediaries) that export to recyclers abroad. Some fractions (e.g., aluminum) are usually sorted and sold to blacksmiths and aluminum smelters.

Data for both the years 2017 and 2023 show that after collection, reusable components of E-Waste were mainly recovered (82% of the times) after dismantling and were sold as spare parts (84% in 2017 and 80% in 2023), while 7% were sold to recyclers. About 10% of the collected E-Waste was repaired and sold as complete functional devices for reuse.

In general, the collectors focus more on items that do not require them to pay much to the consumers, particularly when the consumer is unwilling to give the items away for free. In 2017, 92% of collectors indicated that they go for low priced items, while the rest opined that they confidently go for medium to high priced items as they are optimistic of making profit from the sales. This is corroborated by findings from the observation in 2023, with 94% for low priced E-Waste items. They would rather offer small financial incentives to consumers and gradually increase the offer if the item would yield them more profit. They would rather access scraps from waste dumps, but for some E-Waste components that yield more profit for the collectors, they are willing to pay more. For items such as cables, steel, and PWBs, the collectors were willing to pay higher prices, because there is a good market for such items and they are profitable. Presented in Figure 3 is a summary of the major sources of E-Waste for collectors. It illustrates the evolving dynamics of E-Waste management in Nigeria from 2017 to 2023, highlighting the realities in the collection practices. Dump sites emerged as the dominant E-Waste source, with the number of respondents increasing from around 15 to 27, reflecting persistent informal practices and inadequate formal collection infrastructure. In contrast, EEE repairers, traditionally a major E-Waste source, saw a slight decline, from about 20 to 18 respondents, due to a shift from repair to replacement driven by lower prices of new electronics or more effective refurbishment and repair activities reducing waste generation. The marked decrease in E-Waste collection from EEE refurbishers, from 6 to 2 respondents, likely suggests challenges such as limited access to spare parts, increasing competition from new products, or improved formal collection arrangements. Meanwhile, EEE retail shops showed a modest increase from 3 to 4 respondents, likely indicating a rise in the collection of nonfunctional electronics from consumers or outdated product disposal. These trends underscore the need to address policy gaps, integrate informal collectors, and strengthen formal E-Waste collection and recycling systems, to reduce environmental risks and promote sustainable practices.

2.3. Economic Aspects

Comparison of the data from both years shows that collectors made more money in 2017 than in 2023 (Figure 4). Inflation cannot be ruled out as one of the factors that increased the income losses since 2017. Between 2017 and 2023, Nigeria witnessed a significant surge in inflation, primarily attributed to supply-side constraints, currency devaluation, lingering effects of the COVID-19 pandemic, and fiscal policy challenges, among many other factors. According to data from the National Bureau of Statistics (NBS), the average annual inflation rate rose from around 16.5% in 2017 to approximately 22.79% in May 2023. High inflation rates have adverse implications for economic growth, income distribution, and poverty alleviation efforts. Persistent inflation erodes purchasing power, reduces real incomes as observed by the income distribution of the collectors, and influences investment and consumption decisions, thereby stifling economic and environmental development. As currently adduced, the policy and other efforts may not have influenced economic aspects of the sector, but rather inflation.

Discarded equipment such as laptops, refrigerators, and washing machines are collected and dismantled to retrieve copper, aluminum, plastics, ferrous metal, steel, and PWB. The activities of informal collectors yielded certain economic benefits that motivated their activity. Presented in Table 1 is a summary of the economic benefits derivable by the informal collectors. Despite the operational costs associated with the activities of these informal collectors (e.g., transportation, labor for burning cables, etc.), they still make a profit, which motivates the scavengers to continue despite the risks involved. Most respondents continue with the job despite the risks, as most do not have any other source of income (with 56% continuing in 2017 and 90% in 2023). The income from the sale of valuable E-Waste fraction varied depending on factors such as

(i)

type of device: computers and mobile phones attract more value compared to other devices,

(ii)

condition of device: this depends on the functionality of the device or components thereof. Functional and repairable devices are repaired and sold, or the components are reused as replacement parts. This attracts a higher profit margin,

(iii)

the number of valuable materials present: printed wiring boards (PWBs) of mobile phones and computers are of more value when compared to those of radios and other electronics.

Table 1. Monetary benefits for E-Waste collectors from selected E-Waste fractions.

E-Waste Fraction	Price in € (per kg/Unit) *
	Cost of Acquisition	Cost After Dismantling	Retail Price	Profit
Cable	0.57	0.60	0.95	0.35
Aluminum	0.71	0.86	1.0	0.14
Copper	2.86	3.71	4.50	0.79
Steel	0.85	1.00	1.20	0.20
PWB	14.28	15.00	16.00	1.00
Plastic **	0.42	0.50	0.65	0.15

* Prices were obtained from field study ** mostly plastics containing BFR.

Table 1. Monetary benefits for E-Waste collectors from selected E-Waste fractions.

E-Waste Fraction	Price in € (per kg/Unit) *
	Cost of Acquisition	Cost After Dismantling	Retail Price	Profit
Cable	0.57	0.60	0.95	0.35
Aluminum	0.71	0.86	1.0	0.14
Copper	2.86	3.71	4.50	0.79
Steel	0.85	1.00	1.20	0.20
PWB	14.28	15.00	16.00	1.00
Plastic **	0.42	0.50	0.65	0.15

* Prices were obtained from field study ** mostly plastics containing BFR.

Field work conducted in 2017 showed that 1 kg of cable recovered from E-Waste (with the plastic coatings) retailed for about USD 0.57/kg, while the value of recovered copper wires (by shredding/cutting open the plastic coverings) was USD 2.86/kg. The activities of operators in this sector are market driven, and the operators are motivated by the financial gains made. Although the incomes in 2017 and 2023 were quite similar, the reality is that the scavengers were poorer in 2023 than in 2017. Note that the conversion of the local currency, Naira (NGN), was pegged at NGN 360 to EUR 1 in 2017. As of 2023, the rate is about NGN 860 to EUR 1.

The cost of E-Waste categories under the reuse and recovery scenario presented in Table 1 gives an overview of the approach that was adopted in determining the prices of the various fractions derivable from E-Waste. This cost was deducted from the profit made from sales to determine the income earned by the scavengers, based on the average volume of E-Waste collected per week. Weekly average income for scavengers in 2017 was estimated to be NGN 21,600 as against the weekly average of NGN 16,650 in 2023. In a further analysis, the monthly average income for scavengers in 2017 was estimated to be NGN 86,400 (EUR 240), as against the monthly average of NGN 66,600 (EUR 78) in 2023. These findings illustrate the enduring nature of the businesses’ practices and the similarities in their operations over the years. In PPP terms, NGN 20,000 in 2023 equates to roughly NGN 8000–10,000 in 2017 values. Informal E-Waste workers, dependent on manual labor and daily earnings, are especially vulnerable to such economic shifts. Their profits rely on the resale value of recovered materials, often pegged to international markets. However, while depreciation raises input costs (e.g., tools, fuel), resale earnings in Naira remain stagnant. Thus, despite stable or even declining nominal incomes, real incomes have deteriorated markedly, leaving workers poorer in 2023, with diminished purchasing power, rising operational costs, and lower profit margins.

2.4. Health Safety and the Environment

Collectors acknowledged the dangers associated with their dismantling operations and specifically reported that they are exposed to hazardous chemicals and physical risks. Protective gear, such as gloves, goggles, and nose masks were rarely used to mitigate these risks. Most operators had not received training on E-Waste collection and preprocessing, or in Health Safety and Environment (HSE) practices. They sourced materials primarily from dump sites and they applied no precautionary measures. Instances of periodic injuries and ailments (e.g., body pain) were noted in both years, reflecting the physically demanding nature of the work. In 2017, 80% indicated that formal training would benefit their operation, and this reduced to 68% in 2023. This reduction could result from the impact of the training of informal operators overseen by LAWMA, EPRON, and E-Waste specific non-governmental organizations (NGOs); the E-Waste Relief Foundation; and by the Basel Convention Coordinating Centre for the African Region (BCCCA) as part of the Partnership for Action on Computing Equipment (PACE) II Pilot Project in Lagos, Nigeria. Some of the E-Waste collectors that participated in the GIZ project of 2019–2023 also had some training.

Ohajinwa and colleagues [14,22,23] have written extensively on the pollution challenges at informal E-Waste processing sites in Nigeria, providing valuable insights into the environmental issues associated with such practices.

A summary of the E-Waste flows from observations during the fieldworks are presented in

Table 2. Environmental and health impacts of informal E-Waste processing in Nigeria.

Hotspot	Prevailing Activities	Implications	Environmental Impact
1	Unregulated importation of UEEE mixed with E-Waste and household items	Illegal import of E-Waste. Non-compliance with regulations. Importation of banned E-Waste components	Transboundary movements of waste (refer to the shipment of waste across country borders, often for recycling, treatment, or disposal. It is a key issue in global environmental law, especially when wealthy countries export waste to poorer ones). The imported E-Waste is not reused and only worsens the already severe socio-environmental situation.
2	Material recovery from E-Waste without PPE (e.g., breaking CRT that contain substantial amounts of lead estimate at 1–4 kg Pb/CRT)	This emits dust containing harmful chemicals (e.g., Pb). Workers complained of cuts from CRT glass in case of implosion.	Emission of dust and fumes containing metals (e.g., Pb, Cd, etc.) and organic compounds (e.g., PBDEs).
3	Open burning of cables and printed wiring board (PWB), as well as waste plastic housing units	Exposure to metal dust and combustion product of flame retarded plastics	Same as above.
4	Unregulated dumping of hazardous non-valuable components and residues. Flammable components burnt.	Exposure to dust and fumes, containing harmful chemicals. The open burning releases harmful chemicals into the air, while the fractions remaining in the ash and cinder are washed by storm runoff to contaminate drinking water sources and the food chain.	Environmental contamination and human exposure to toxins.

, including environmental and possible health impacts at the hotspots. An assessment of activities at the hotspots enabled the identification of areas of intervention that could enable a ’reorganization’ of the flow network.

Most informal operators are aware that their activities pose threats to their health, ranging from bodily cuts from sharp objects to infection. Many of their activities are conducted with no protective overclothes, boots, or hand gloves. Most operators do not use Personal Protective Equipment (PPE). About 86% of scavengers in 2017 indicated they did not use any PPE (protective overalls, boots, and gloves) against 62% in 2023. Specifically, only 14% used hand gloves in 2017 and 30% in 2023. In 2017, none of the respondents used boots or overalls, while there was an improvement in 2023 with 2% using boots and 6% using protective overalls.

Open wounds can expose them to contact with infectious and disease-causing organisms in dumpsites. Considering that medical wastes are not managed separately in Nigeria, sorting and sieving wastes from dumpsites with medical wastes could expose scavengers to several infectious diseases.

Most scavengers acknowledged that the job brings stigmatization in society with citizens avoiding having any encounter with them. Only about 14% of the respondents used hand gloves and this was higher among those actively dismantling E-Waste using tools such as a chisel and hammer. No use of overalls, safety boots, or eye protector goggles were observed during the field studies. Considering the lax enforcement of existing legislation that should ensure environmental protection, it is a huge challenge to regulate the indiscriminate open burning of cables to recover copper wires and the dumping of hazardous materials generated by this sector. This trend in lack of regulation has made these activities an open business for all. Overall, most of the respondents in 2017 and 2023 were of the opinion that training would be beneficial to their operations and enhance safety consciousness. The slightly significant improvements observed may be linked to the consistent campaign and training on safety related issues conducted by the regulatory agencies and EPRON, targeting scavengers in the study area.

2.5. Stakeholders Compliance with 2011 Regulations

The Person in Port project observed that about 6000 tons of imported UEEE are non-functional, and about 77% of these imports originated from European ports, many of which were not tested and properly documented before export or on arrival in Nigeria [16]. The national regulation bans the importation of E-Waste into Nigeria, and only functional devices are allowed into the country. The assessment of compliance with Nigeria’s EEE regulation on registration of UEEE/E-Waste importer shows that registered importers accounted for about 75 of the 2145 (3.5%) imports in containers [16]. The high degree of non-compliance and technical gaps between Nigerian EEE 2011 Regulation E-Waste guidance, and the Nigeria EPR guidance is driving the present unsustainable situation. It suffices to point out that the registration of importers is a crucial prerequisite towards the implementation of the EPR system. Other observed non-compliance activities of the importers of UEEE and the informal operators during the Person in Port project are summarized in

Table 3. Status of compliance with the 2011 EE legislation (NESREA) regulation on import of UEEE/E-Waste in 2017.

Regulatory Aspect	Provisions in Nigeria EEE Regulation, 2011	Observation During Assessment Work
Guide for producers and importers of UEEE.	(i) Every importer of EEE/UEEE should register with the NESREA	97% of UEEE importers not registered
	(ii) Importation of new EEE and functional UEEE is allowed	26% of imported UEEE are non-functional
	(iii) Importation of E-Waste is banned	Evidence of importation of E-Waste observed
	(iv) Imported E-Waste shall be sent back	None was returned during the study period
	(v) An administrative punitive fee shall be imposed on the carrier of E-Waste or UEEE mixed with E-Waste	Only a few have been reported in the past, with none during the study period
Activities that require registration and permits under the regulation:	(i) Proof of evaluation/testing and a certificate containing testing information on each item	Observed in less than 1%
	(ii) Importation of UEEE	Only a few importers are registered
	(iii) Copy of permit to import	Only 4% observed
Specific provisions of the EEE sector regulations	(i) Importation of CRT is banned	Importing is still very evident
	(ii) Manufacturers * are to take back the E-Waste, set up collection lefts, and ensure ESM of E-Waste	Not yet in existence. This is crucial to the sustainable management of E-Waste
	(iii) Consumers are to return E-Waste to the collection lefts	Non-existent now
	(iv) All importers of EEE/UEEE are to pay an administrative fee to the NESREA	Low compliance

* Represented by their, importers, distributors, or retailers; Source: Odeyingbo et al. [16].

. Presented in

Table 4. Summary of amendments in the 2022 Law and manual for informal operators in Nigeria.

Funding Mechanism for E-Waste Management According to the Revised Nigeria EEE Regulation, 2022

Summary of Key Components of Operational Guide (Manual) for E-Waste Collectors in the EPRON Manual (2023)

The mandatory EPR requirement on stakeholders (producers, marketers, collectors, consumers etc.): Register with the NESREA and the EPRON Producer/importer to pay recycling fee to EPRON. Submit annual return. Upload put on market (POM) data into the Black Box Ensure E-Waste is not stored longer than 6 months, and not disposed in a trash receptacle, dump site or landfill, or burnt. Ensure collected E-Waste is transported to designated recycling centers. Ensure ESM of E-Waste from cradle to grave based on market share. Ensure good housekeeping practices and maintain copies of E-Waste manifest and forward copies to the EPRON and NESREA. Take back EoL EEE and set up a collection center. Ensure ESM of E-Waste from collection to recycling. Ensure users of EEE return EoL EEE to a collection point. Have a sustainable community relation as part of Cooperate Social Responsibility

EPRON WEEE SMART manual provides the specifications: i. Register with EPRON and comply with renewal requirements, submit quarterly collection plans. ii. No dismantling and open burning of E-Waste components. iii. No cracking of CRTs. iv. Provide incentives (monetary, points, etc.) for informal collectors to participate in E-Waste take-back in a more organized structure (e.g., via a registered Cooperative Society or Association). v. Provide information to consumers on E-Waste collection facilities and take-back systems in their neighbourhood. vi. Comply with standard procedures defined by NESREA and apply best-management practices for handling E-Waste. vii. Keep an accurate database of E-Waste movements (categories, quantities handled, sources/origins, and mode of delivery in the black box system. viii. Submit database quarterly reports to the NESREA and EPRON. ix. Ensure that the E-Waste collected is stored in a secured facility approved by NESREA for such a purpose. x. Ensure that E-Waste is transported safely to the designated recycling facilities approved by the EPRON and NESREA, and keep track of all E-Waste transported out of collection facilities. xi. Adequate staff training and proper use of appropriate Personal Protective Equipment. xii. Provide information to producers that can be used to design or label products to facilitate collection and recovery when necessary.

are some updates on the Nigerian EE sector after the Person in Port project, which included the amendment of the 2011 Nigerian EEE Regulation to introduce mandatory EPR.

Recognizing the role of the activities of informal sector operators and supporting them with capacity building, strategic planning, and funding would enable re-organization of the sector under a defined Public–Private Partnership arrangement, especially with the involvement of registered formal sector operators, the importers, the Original Equipment Manufacturers (OEMs), and Producer Responsibility Organizations (PROs).

EPR in Nigeria is led by a private-sector-led initiative managed by EPRON and regulated by the government. EPRON was established in 2018 as the sole EEE PRO. EPRON has responsibility for implementing the EPR program in the sector, coordinating take-back of E-Waste, and ensuring that collected waste are managed using ESM; supporting the E-Waste management industry to domesticate existing standards. EPRON have established a registry which will determine market shares of producers and collect EPR levies which will be used to support recyclers and collectors, raise awareness, conduct research, establish standards, and support their own administration. Despite the establishment of EPRON and the implementation of EPR regulations, systemic challenges continue to undermine their effectiveness. Chronic funding shortfalls have constrained EPRON’s ability to implement impactful initiatives, resulting in inconsistent support for E-Waste collectors and formal recyclers. The reliance on voluntary producer contributions has proven inadequate, limiting financial sustainability and slowing the transition toward a structured E-Waste management framework [20]. As a result, the anticipated economic improvements for workers in the sector remain unrealized, reinforcing income stagnation and informality [24]. Many producers remain unaware of their obligations, while the NESREA struggles with limited capacity to monitor and enforce compliance [25]. The dominance of the informal sector exacerbates this challenge, as recyclers continue to operate without the necessary training, equipment, or financial incentives to transition to formalized systems [26]. Furthermore, inadequate infrastructure, including the absence of collection points and certified recycling facilities, creates additional barriers to compliance, even among stakeholders willing to engage with the regulatory framework [25]. Addressing these systemic failures requires a more robust and coordinated approach. Sustainable financing mechanisms, such as mandatory EPR levies or government-backed funding models, would provide a stable revenue stream for waste management programs. Strengthening enforcement through better resource allocation to NESREA would enhance compliance, while targeted capacity-building programs could facilitate the integration of informal recyclers into the formal economy [20,25]. Investment in infrastructure remains critical to ensuring that E-Waste is processed in environmentally sound conditions, mitigating health risks and economic inefficiencies [24]. Without these structural interventions, the existing EPR system risks being a symbolic effort with limited real-world impact, reinforcing existing inequalities and environmental hazards rather than addressing them effectively.

The NESREA is responsible for the implementation and enforcing of regulation related to EEE in Nigeria. The agency, established in 2007, has the responsibility to enforce all environmental laws, regulations, guidelines, rules, laws, policies, and guidelines, including the monitoring and control of E-Waste. The agency has successfully drafted Nigeria E-Waste Regulation which aims to ensure strict adherence to set standards and procedures related to the import and management of EEE at the end of its life.

The NTWDWP (National Toxic Waste Dump Watch Program) coordinated by the NESREA has been reactivated, with a special focus on the import of E-Waste. Importers of used EEE now must register with NESREA and comply with the EEE import guidelines, and this registration is a pre-condition to importing electrical equipment.

The recently amended National Environmental (Electrical and Electronic Sector) Regulations 2022 binds all producers to fulfilling their EPR obligations as necessitated by the National Environmental Electrical/Electronic Regulation 2022 S.I. No 79, 2022 [21,27] (refer to section below in Table 4). In a recent report, EPRON explained that the review of the regulation has increased the compliance rate for registration by stakeholders, which shows a significant improvement when compared to the observations and recommendations in Odeyingbo et al. [16,17], which reported that only 3 percent of the importers of UEEE were registered with the regulatory agencies. The EPRON report further explained that it recorded its highest number of producer registrations since inception, with 39 producers (25.6% renewals; 74.4% fresh registrations, comprising 25.6% for new EEE producers and 48.7% for UEEE). Integrating the informal sector into the formal sector can improve the social status of the informal sector and scavengers by legitimizing their activities and minimizing illegal activities that are highly polluting. The activities of EPRON are regulated by the National Environmental Standard and Regulation Enforcement Agency (NESREA), which was established in 2007 by the Nigerian Government. The NESREA has the responsibility to enforce all environmental laws, regulations, and guidelines, including the monitoring and control of E-Waste.

2.6. Reorganizing the Current E-Waste System

The 2022 revision of the National Environmental (Electrical and Electronic Sector) Regulations and the operationalization of the EPR framework aimed to address long standing deficiencies in E-Waste governance. However, despite policy reforms and donor-funded projects such as the GEF initiative, the informal sector remains dominant and environmentally sound management (ESM) remains elusive. Based on the empirical findings from a longitudinal study (2017–2023) and comparative literature from countries including India, Ghana, and South Africa, we assessed the impact of policy reforms, identified persistent implementation gaps, and proposed feasible reorganizational strategies grounded in both evidence and best practices. Our study in Lagos revealed limited improvements in the conditions and operations of informal E-Waste collectors between 2017 and 2023. Most of the E-Waste collectors remain unregistered, operate without PPE, and prioritize profit over safety or compliance. Hazardous practices such as cable burning and CRT smashing persist, despite awareness campaigns. Income levels have declined due to inflation, market volatility, and a lack of formal engagement mechanisms. However, collectors showed interest in formal partnerships if economic incentives were provided. Despite some regulatory successes, such as increased producer registration via EPRON and the rollout of the Black Box registry, informal workers continue to dominate the sector, without integration into formal structures. These findings underscore the resilience on informal networks and the limitations of top-down policy interventions when economic drivers remain unaddressed.

2.7. Policy Gaps and Challenges in Nigeria’s E-Waste Regulation

• Institutional Weakness and Fragmentation: The NESREA’s enforcement capacity remains inadequate. Regulatory overlaps and insufficient funding hinder monitoring and compliance.
• Exclusion of Informal Workers: As seen in Ghana and India, attempts to formalize E-Waste often marginalize informal workers [7,9]. Nigeria’s regulatory instruments have yet to provide a meaningful bridge between informal practices and formal policy goals.
• Weak Economic Incentives: Recyclers and collectors lack financial motivation to participate in formal take-back systems. As demonstrated in Ghana [28], economic incentives are crucial for behavioral change.

Using lessons from the literature and field data, we suggest the following pathways:

I.

Localized EPR Implementation: Policies must reflect Nigeria’s socio-economic realities. As Inverardi-Ferri [29] argues, policy mobility often results in failures when neoliberal frameworks are imposed without local adaptation. Nigeria’s EPR scheme should incorporate flexible compliance pathways and recognize informal actors as primary stakeholders.

II.

Economic Incentives and Conditional Integration: Drawing on Ghana’s and Sri Lanka’s experiments, as presented in [30], collectors could be paid bonuses for materials delivered to certified recyclers. Microcredit, tax breaks, and cooperative grants would help transition collectors toward safer practices.

III.

Cooperative Based Formalization: It is essential to encourage cluster-based cooperatives, as used in South Africa [19], to organize informal collectors. Provide training, health insurance, and shared facilities to improve occupational safety and legal compliance.

IV.

Phased Enforcement and Monitoring: The NESREA should implement a phased enforcement plan targeting high volume E-Waste zone with stricter monitoring. Digital tracking systems via EPRON’s Black Box can support real-time compliance checks and identify potential perpetrators.

V.

Gender-Inclusive Policy Measures: Building on Balde et al. [5], policies must address gender-based disparities by offering women better access to training, tools, and leadership roles in recycling cooperatives.

VI.

Cross-Border E-Waste Controls: Cameroon’s “Guichet Unique” provides a replicable model to screen imports and reduce illegal E-Waste shipments [19]. Nigeria must strengthen port inspections and require standardized documentation for all used EEE imports.

Nigeria’s E-Waste reforms represent a step forward, but significant policy and implementation gaps persist. Effective governance requires more than legislation; it demands integration, incentives, and infrastructure. Through contextualization of local challenges within a global policy framework and grounding recommendations in both empirical evidence and comparative cases, this paper contributes to scholarly and policy debates on EPR localization, circular economy inclusion, and intentional informal sector engagement. The proposed reorganization of Nigeria’s E-Waste management system should be rooted in cooperative models, economic realignment, and stakeholder accountability, offering a practical path toward socially inclusive and environmentally sustainable E-Waste governance.

Since the informal sector in Nigeria is strong and highly connected, plans for including the informal with the formal sector, as seen in South Africa, could improve the situation in Nigeria. Economic incentives have been proposed as a viable option for E-Waste retrieval from informal collectors [30] and were tested in Ghana [28]. To ensure that collected E-Waste is channeled to formal processors, economic incentives can be used to motivate collectors such that E-Waste materials are redirected towards ESM. This includes, for example, offering collectors a 5% or a 10% increment on profit to that already made for E-Waste collected. Funding for this could be derived from the EPR scheme. Better economic motivation through higher incomes and better working conditions could create a better controlled informal sector that reduces the negative environmental impacts of the informal sector and improves the quality of resources retrieved. The identification and understanding of hotspots in the flow of materials would allow for an intervention after an assessment of the willingness of the stakeholder involved (especially the collectors), to change the direction of the material flow towards ESM and to prevent negative impacts on the environment, human health, and resource loss.

Beyond the crude means of retrieval of valuables from E-Waste, informal workers play a crucial role in extending the lifespan of electronic devices through repair, refurbishing, and reuse activities. This aspect of the informal economy is often overlooked in policy discourses, which focus primarily on the environmental risks associated with crude dismantling and cable burning. Our fieldwork revealed that a considerable proportion of informal actors specialize in diagnostics, soldering, screen replacement, battery swaps, and other repairs, helping to delay product obsolescence. Informal markets in cities like Lagos and Onitsha are home to vibrant repair ecosystems that support affordability and accessibility for low-income households by extending the lifetime of electronics beyond their original design life. This contributes directly to E-Waste reduction, decreases demand for new electronics, and supports local employment. Studies by Davis and Garb [31], as well as Schulz and Lora-Wainwright [32], further emphasized the value of informal repair economies in promoting circularity from below. While these practices are often informal, fragmented, and unregulated, they represent untapped potential for scaling sustainable consumption when supported with training, incentives, and proper tools. Thus, Nigeria’s E-Waste policy should not only aim to regulate end-of-life disposal, but also recognize and formalize repair and reuse sectors as part of the solution. This could be accomplished through repair cooperatives, certification programs, and designated zones for safe repair and refurbishment. Doing so would both leverage the expertise of informal actors and align national policy with circular economy goals.

The government and its agencies, as well as the private sector (through the Producer Responsibility Organization (PROs), could intervene at the identified hot spots to switch to a re-direction of ‘materials’ to a safer route and destination, to avert negative consequences. These entities may include government institutions (via legislation, communication, enforcement, financial benefits), researchers (outcomes of research, e.g., assessing how strategic plans reflect the policy and legal framework), the public (identifying obstacle to management plans), recyclers (external operators), and producers (e.g., EPR obligations).

There are, however, circumstances that could limit/mitigate the maximizing of the economic potential of these operations. Such limitations include

i.

Financial dependency: Inability to fund their operations restricts the scavengers/informal operators. Therefore, collectors and processors are not sufficiently free to direct materials as they wish. Funding would free the informal operators to change the flow of their collected E-Waste route for better financial gains.

ii.

Loyalty and dependency: Most scavengers/dismantlers are migrant workers. Intermediaries or their agents bring them from rural areas and engage them in the cities. They also provide accommodation and support with daily living until they are integrated into city life. This makes the informal workers completely dependent on the agents funding their operations. Loyalty makes the operators give the materials collected to agents rather than to the formal recyclers, even if they offer to pay more.

iii.

Weak regulation, enforcement, and monitoring of the sector: An unregulated informal sector with very lax enforcement of existing regulation invariably allows the informal operators freedom to engage in activities that expose man and the environment to a cocktail of toxins. Furthermore, compromising of regulators is one of the key factor that hampers these efforts. A regulated sector would allow the formulation of laws, which when enforced and monitored, could result in grave consequences for offenders and the risk of fines.

Reorganizing the existing system to exclude some or all activities at the hotspots identified in this study is a step in ensuring the ESM of E-Waste in Nigeria. This can be achieved as follows:

i.

Slowly linking the informal activities to the formal sector might be an initial option for those fractions that are hazardous, which would allow the collectors to continue their operations, while ensuring that they hand over hazardous material to a proper treatment operator. This would bring the informal operators closer to the official system and make it easier to engage them and improve their situation step by step, which could, in the end mean, integration into the formal sector.

ii.

Integrating the activities of the informal operators into that of formal stakeholders in the E-Waste management sector. To effectively integrate informal operators into Nigeria’s formal E-Waste sector, a structured, incentive-driven approach is needed. Since informal processors dominate E-Waste collection and pre-processing, they should be engaged as primary collectors and dismantlers, with restrictions on hazardous activities like CRT breaking and open burning. Practical steps include issuing collector identification cards, establishing designated drop-off points, and providing buy-back schemes where formal recyclers purchase pre-processed materials at fair prices. Training programs on safe dismantling techniques, supported by microfinance schemes, could help informal workers transition into safer, income-generating roles. Partnerships between government agencies, industry players, and cooperatives could create hybrid recycling hubs, where informal workers are integrated into the formal processing chain. To ensure compliance, enforcement should combine incentives (such as tax breaks or equipment grants) with strict penalties for environmental violations. A phased approach, starting with major E-Waste hotspots, would allow for adjustments based on local realities, ensuring a scalable, sustainable transition that benefits workers, businesses, and the environment.

iii.

Some of the collectors receive daily loans, often from the treatment operators or scrap dealers, which they payback. Supporting the informal operators with a living wage and other incentives (based on the type and quantities of fraction collected) would enable them to hand over materials to formal processors. This could be funded through the EPR via the formal operators or other transfer channels.

iv.

Establishing a financing mechanism by exploring the strength of the current EPR system through monitoring and enforcement. Data collection and storage are also key for ensuring the success of the system. The recording and development of a database on volumes of imports is important for the development of a financial system for the EPR. This automatically makes importers an especially important stakeholder in the EPR system. A review of the existing policy guidance on EEE and the introduction of an Environmental Health Standard (EHS) would ensure ESM.

v.

The review of the legislation banning the importation of E-Waste and its enforcement is crucial in controlling the illegal importation of E-Waste.

vi.

Continuous education and enlightenment of the informal operators should be incorporated into the activities of the regulatory agencies and other stakeholders.

This reorganization would contribute towards achieving United Nations sustainable development goals. Addressing human elements such as improved health, decent working conditions, and reducing inequality is essential in aligning the reorganization effort with the United Nations Sustainable Development Goals (SDG). Reorganization of the E-Waste management system would improve labor conditions and jobs (SDG 8), and reduce environmental impacts (SDG 6, SDG 11, and SDG 13–15), lack of knowledge about health risks (SDG 3), and the loss of valuable materials (SDG 8 and SDG 12) [33]. The reorganization of E-Waste management and specific policy formulation that directly targets the identified challenges could be realized through the active involvement of the local stakeholders in planning, negotiation, and implementation, through partnerships for E-Waste reduction and waste management initiatives and projects. Overall, this could be a step in implementing sustainable businesses driven by a new E-Waste processing paradigm that integrates the use of the best available technologies and data management, while ensuring that occupational health and safety standards for workers are maintained.

Although there are differences in each developing country, the solution to E-Waste management in a country is achievable by developing policies and guidelines that integrate the real-life situation or realities on E-Waste flows, as these studies have revealed. This will allow the implementation of best practice systems that can address unique local norms and customs, as well as the social and economic culture [34]. The activities of the informal sector should not be eradicated, because of the ineffectiveness of their activities associated with environmental pollution; rather their activities should be limited to the collection of E-Waste materials.

Considering an increase in intra-African trade in used EEE and E-Waste, especially among countries with porous borders and in West Africa, a stricter compliance system should be introduced and enforced to achieve significant improvement in the current situation. Recently, Cameroon introduced a robust system to manage the import and control of products that use hydrochlorofluorocarbons (HCFCs), to check inflows. This was achieved through a “one-stop shop system” (Guichet unique) that verifies all shipments before they are cleared to enter the country [4].

Considering that E-Waste is still disposed of as general waste before any take-back by scavengers, collection and pre-treatment constitute good business. Moreover, some merchants are interested in funding E-Waste collectors to ensure regular supply and a good profit margin for the collection center owner. As a result, operators of collection centers travel to rural areas to engage migrant workers, mostly youths in their 20s and provide them with accommodation and a family scenario (same tribe, religion, state of origin, etc.) to ensure loyalty. Within the collection centers, a set of dismantlers are also actively involved in the manual dismantling of E-Waste, after which the various components are sorted according to type or material. Reusable recovered components (e.g., mother boards, external hard drives, etc.) are sold to technicians who use them for repair activities. Other fractions are also sorted according to metal types and then sold to merchants for export. To ensure better E-Waste management, especially routing E-Waste towards the formal E-Waste operators in Nigeria (such as E-terra, Hinkley), the Nigerian government published a revised version of the 2011 environmental regulation with an amendment to the National Environmental (Electrical and Electronic Sector) Regulations (in January 2023). The amendment strengthened the EPR, while making producers accountable for the EoL of their products. Although EPR is established in Nigeria as a private sector-led initiative, the details of operations and performance is lacking. EPRON manages the Nigerian EPR, while the government regulates the system. To achieve this, EPRON is establishing a registry for manufacturers and importers, to determine their market shares and enable collection of EPR levies. The funds realized will be used to support recyclers and collectors, raise awareness, conduct research, establish standards, and support administration. This is yet to be actualized, but substantial progress has been made.

The introduction of a mandatory EPR scheme in Nigeria could be part of the long-term approach to managing EoL electronics waste in Nigeria. Nigeria could follow the step of South Africa of creating a mandatory EPR scheme in 2021. Deutsche Gesellschaft für Internationale Zusammenarbeit [35] reported that the mandatory EPR showed a better result and effects than voluntary efforts, which only provided limited revenue generation and scope in South Africa.

Furthermore, there is a need for ethical ways to implement EPR that includes informal workers and which goes beyond tokenistic inclusion. This requires restructuring power relations that often exclude marginal actors from formal governance processes. In many low- and middle-income contexts, informal E-Waste workers provide essential environmental services, yet EPR models imported from OECD countries tend to marginalize these actors by imposing rigid compliance standards and formal-sector biases [36]. Ethical EPR must therefore move beyond technical fixes to adopt participatory, justice-oriented approaches that recognize informal labor as structurally embedded in waste economies [37]. This involves co-designing policy with informal worker cooperatives, creating transitional support systems (e.g., training, financial tools), and ensuring that legal frameworks protect rather than criminalize their work. Failing to do so risks reproducing environmental injustices under the guise of sustainability, reinforcing socio-economic exclusion while privileging formal-sector compliance [38].

Mandatory EPR systems would be effective, because they entail better monitoring and enforcement and less free riding, which enables a levelled playing field for relevant actors and expands the scope of covered wastes. In the context of the study area, where transboundary movement places both used electronics and new electronics on the market, a mandatory EPR system would allow provision for all products (domestically produced and imports) put on the domestic market to comply with the same requirements. This means that EPR usually does not represent a trade barrier, nor does it negatively impact the competitiveness of domestic producers.

The transboundary movement of electronics means that when these products become waste in other markets, they are not captured by the collection and recycling requirements of the EPR system where the product was placed on the market. This creates externalities in financing the collection and treatment in the market where they eventually become waste, resulting in undervalued EPR fees in the market of origin. The working out of these details creates further research gaps that need to be filled.

We recommend the adoption of green technologies for metal recovery from E-Waste, as outlined in recent research [39]. These eco-friendly methods reduce environmental impacts and improve recovery efficiency. Integrating such technologies into Nigeria’s E-Waste management framework could promote sustainability and enhance worker safety.

3. Materials and Methods

3.1. Study Tools

This study employed a combination of desk research and fieldwork. The desk research focused on the existing literature, reports, and newly developed policy frameworks and guidance documents relevant to Nigeria. The field study utilized a survey tool developed after desk research to consult and interview E-Waste scavengers (informal collectors) in person. The survey also contained demographic questions, such as the age, sex, and education level of the responders. Furthermore, market visits were made to investigate the monetary value of materials and components, this was in addition to one-on-one interviews with fifty E-Waste scavengers (informal collectors). These techniques captured both quantitative and qualitative data via the questionnaire and onsite observation. Data were collected in 2017 and 2023 and used for an in-depth comparative analysis of the progress achieved in the sector.

3.2. Study Area and Approach

The study was conducted at two identified locations with a high dominance of informal E-Waste processing: Abule Egba and Ojota, both in Lagos State, Nigeria. The selection of Abule Egba and Ojota as study sites for E-Waste collection clusters in Nigeria was grounded in their strategic significance within Lagos State, which serves as the primary hub for electronic waste flow and informal E-Waste management in the country. According to the UNU Report [1], both Ojota (Olusosun dump site) and Abule-Egba (Oke-Odo site) are official landfill sites in Lagos, playing critical roles in the accumulation, informal processing, and disposal of E-Waste. These sites represent major nodes in the informal E-Waste economy, characterized by activities like scavenging, burning, dismantling, and resale of used electronic and electrical equipment (UEEE). Moreover, these sites are part of a well-established informal network for E-Waste handling. They are not only heavily patronized by scavengers and recyclers, but are also locations where the adverse environmental and health impacts of informal processing such as open burning of cables are most visibly manifest. Their centrality in the E-Waste economy of Lagos, coupled with the volume of waste processed, makes them ideal proxies for studying national-level dynamics in the absence of a formal E-Waste management infrastructure. While it is valid to raise concerns about sampling bias when using only two urban locations to represent a national scenario, Lagos holds a disproportionate share of E-Waste activity in Nigeria due to its status as Nigeria’s largest urban center and import gateway (via Apapa Port). There is a concentration of informal recyclers, refurbishers, and dump sites in and around these hubs. Abule Egba and Ojota serve as representative microcosms of the broader E-Waste challenges and dynamics in Nigeria, particularly those rooted in urban, informal-sector-driven systems.

The focus was on the informal collectors (commonly referred to as scavengers) who collect, sort, and dismantle E-Waste (and other scrap metals), and form the bottom of the E-Waste management pyramid. The collectors operate in clusters, often funded by E-Waste merchants, who are mostly foreigners. Fifty (50) informal collectors were selected randomly for the study within different E-Waste clusters at the two study sites for both study periods of 2017 and 2023. The sample sites and size of fifty were appropriate given the qualitative nature of this study. The informal E-Waste sector in Lagos operates within tightly knit networks, where practices are often replicated across various locations. As a result, data saturation could be reached with as few as 30 respondents [40]. Furthermore, participants were purposively selected to capture diverse roles such as collectors, dismantlers, burners, and intermediaries, ensuring representation across major E-Waste hotspots. Additionally, in qualitative research focused on hard-to-reach or mobile populations, such as informal workers, smaller sample sizes are considered sufficient for generating in-depth insights and contextual understanding [41]. Finally, previous studies on informal E-Waste practices in similar contexts have relied on comparable sample sizes to draw valid conclusions [42].

The study covered a period of about 3 months field work each in 2017 and in 2023. Observation during the field study enabled the identification of the economic value attached to E-Waste components and materials, the identification of hot spots where undesirable activities that result in pollution take place, as well as other unsustainable practices within the informal sector.

In addition, data on the economic values and benefits of the various components/materials of E-Waste were obtained using market surveys focusing on five household appliances: refrigerators, washing machines, CRT TVs, desktop computers, and laptops. These devices were selected because they were observed to be the major constituents of E-Waste generated, collected, and managed at the study sites. Attention was also paid to the material flow of various fractions, from collection to material recovery; as well as the fate of the hazardous fractions that are of little or no value to the operators. Information on the compliance with existing regulations was obtained in collaboration with the PIP project [16,26,33].

A Chi-Square analysis tool was employed to compare variables from 2017 to 2023. As a statistical method, the Chi-Square test was used to determine whether there were significant associations between categorical variables. Specifically, the test analyzed the relationship between variables such as income levels, recycling behaviors, and demographic factors across the two years. This approach helped assess whether the observed differences or associations were statistically significant rather than occurring by random chance. Categorical data were collected through field surveys and interviews, including income brackets and recycling habits. The Chi-Square test compared the expected frequencies (assuming no association) with the observed frequencies from the collected data. A p-value below the significance level (typically 0.05) indicated a statistically significant association between variables.

4. Limitations and Conclusions

This study has limitations that could influence the interpretation of its findings. First, the relatively short time frame (2017–2023) restricts the ability to assess the long-term effects of policy changes, as the full impacts may take longer to materialize [43]. Additionally, external factors such as inflation and market demand may also have affected the outcomes, making it challenging to attribute the observed changes solely to policy shifts. This concern has been noted in previous studies in the sector [F9]. Furthermore, given the reliance on informal sector workers for data collection, there was the potential for response bias, as participants may have aligned their answers with perceived policy goals or expectations, a concern highlighted in similar research. Lastly, for a more nationally representative analysis, future studies could incorporate E-Waste clusters in other geopolitical zones such as Aba, Onitsha, Kano, or Port Harcourt to capture regional variations.

Finally, this research paper examined the impact of Nigeria’s revised E-Waste management framework, specifically focusing on the informal sector between 2017 and 2023. The informal E-Waste sector remains dominant, with informal collectors retrieving valuable components for export, often through environmentally harmful methods such as burning cables to extract copper. Despite policy changes like the 2022 EPR law and the establishment of E-Waste collection centers, informal collectors’ practices and income levels have seen minimal improvement. Collectors’ earnings were higher in 2017 than in 2023, due to inflation and limited incentives under the new framework. Furthermore, the informal collectors continue to work in unsafe conditions, with low usage of protective gear, exposing them to hazardous materials and physical risks. There is environmental contamination from practices like open burning persists due to lax enforcement. The paper advocates integrating the informal sector into formal E-Waste management, providing incentives, training, and funding. This could reduce environmental and health risks, while ensuring sustainable E-Waste practices. The study has revealed that the revised E-Waste framework has had limited success. Greater efforts to regulate, incentivize, and safely integrate informal operators are essential for achieving environmental and social improvements.