Divisive definitions tarnish gold sustainability drive

This April, the Alliance for Responsible Mining (ARM), which promotes standards and criteria for small-scale artisanal gold miners, published an open letter, signed by 10 other non-governmental organisations, headed “Old jewellery is not waste!”. Their aim was to contest the term “recycled gold”.

The letter was addressed to the International Organization for Standardization (ISO), the London Bullion Market Association (LBMA), the Responsible Jewellery Council (RJC), and the Responsible Minerals Initiative (RMI).

And, in it, the letter’s authors state why they believe the term “recycled gold” — which makes up more than half the gold refined each year — is problematic: “The term ‘recycled’ as used today by many companies falsely implies to consumers that using such gold has a decisive positive social and environmental impact, and deserves to be called eco-friendly, ethical and responsible.”

The letter explains that these claims of zero carbon footprint for recycled gold, which disregard historic carbon emissions, not only mislead consumers but diminish the role of artisanal mining and discourage the more complex and costly process of e-waste retrieval.

Artisanal mining employs 100mn people, or 2-3 per cent of the global working population, who rely on it as a source of income. Over the past decade, co-operatives, mainly in Central and South America, have been formed, with support from bodies such as ARM and Fairtrade, to create mercury-free extraction methods that have positive social and environmental impacts.

The letter goes on to argue that the word “recycled” is incorrect as, unlike plastic bottles or tin cans, gold is never a waste product and, by its very nature, is never knowingly discarded. The only exception is gold in waste electronics, which is costly to extract. According to the UN Environment Programme, only 20 per cent of e-waste is formally recycled.

The letter urges the industry to adopt a definition of recycled gold consistent with international laws and to clarify the positive and negative impacts of this source of gold. It proposes replacing the term “recycled gold” with “reprocessed gold”, as agreed at the non-profit Precious Metals Impact Forum in 2022.

“Bringing artisanal gold to the market is expensive, so makers prefer to use ‘recycled’ instead of investing in artisanal sources, which, because of the small scale of the many mines, is costly to grow production,” explains Patrick Schein, a gold refiner and chair of ARM.

The issue of the terminology has been long debated. Since 2022, the RJC, the industry standard-setting organisation, has held three consultations. But the mixed feedback on a potential review of the definition after two consultations left the topic unresolved, leading to a third consultation, which closed last May. The outcome and implementation are due to be announced by the end of the year.

So far, the open letter has received responses from the ISO, the RMI, and the LBMA. The LBMA says it “defines recycled gold with regard to due diligence requirements, not for product claims. This is consistent with the definition outlined in OECD Due Diligence Guidance, against which the RGG (Responsible Gold Guidance) is measured.”

Schein is sceptical about the outcome. “As incredible as it may be, there is no sign from the industry that ‘recycled’ will be restricted to waste as the laws of most countries define,” he says. “The only initiative today is with the US Federal Trade Commission, where the Jewelers Vigilance Committee has made a submission asking them to avoid ‘recycled’ when it comes to precious metals and gems.”

The letter also urges the OECD to clarify the scope of its Due Diligence Guidance for Responsible Supply Chains of Minerals From Conflict-Affected and High-Risk Areas and calls on all companies to rigorously verify the origins of their recycled gold.

The letter points out that the supply regulations are flawed, as due diligence for “recycled gold” is only carried out as far as the first supplier. There is no control over where this gold re-enters the market and the risk of problematic gold — from sources such as sanctioned Russian producers, money launderers, tax evasion, African conflict areas, and other criminal activities — entering the supply chain. A 2020 study by NGO SwissAid identifies the United Arab Emirates as the trading hub for risky gold.

The problem of Russian gold infiltrating the supply chain is addressed in the UK’s National Economic Crime Centre Red Alert file on Gold-based Financial and Trade Sanctions Circumvention, published in November 2023. “Gold is a significant income stream for Russia’s war effort . . . worth £12.6bn to the Russian economy in 2021,” it says.

“Given the increasing demand for recycled gold from legitimate entities keen to reduce their environmental impact from mining, there is a risk that new Russian gold enters the supply chain as mislabelled recyclable gold.”

Mined gold is also subject to infiltration issues. However, the RJC says that “the same level of due diligence is required for all sources of material accepted to enter the chain of custody. In the case of recycled material, the supply chain is generally longer and more complex than for new mined material.”

New sources of sustainable gold include the UK’s Royal Mint recycling facility that will open in south Wales this year. It will be able to process up to 4,000 tonnes of e-waste from printed circuit boards per annum. It has adopted the term “recovered” gold.

“Recognising there is currently no single definition for ‘recycled gold’, and that the term can be ambiguous for the consumer, we have purposefully chosen ‘recovered’ as we feel this most accurately describes the process undertaken within our precious metals recovery plant,” says Sean Millard, chief growth officer at the Royal Mint.

Some jewellers, including Chopard, have shown a strong commitment to responsible gold sourcing. “Our objective is to maintain a threshold of a minimum of 60 per cent of gold sourced from accredited artisanal mines,” says a company spokesperson.

“This sourcing allows us to have the full traceability of our gold and a significant impact on mining communities, on the health and safety of workers and on the environment (no mercury use). This is where we can have a leverage and an impact, whereas gold will be in any case recycled.”

Schein says that changing the term from “recycled” to “reprocessed” is unlikely to change the industry, “but it will oblige more transparency with the consumer about the real impact of different gold sources, encouraging those that contribute to positive social and environmental outcomes and avoid greenwashing”.

“Responsible sourcing can only be achieved by including all gold sources, not just the cheapest and easiest options like the ‘recycled’ one. The term ‘recycled gold’ is used as a synonym for responsible sourcing and allows false carbon footprint claims.”