“StEP finds it confusing to talk about e-waste and equipment that may be e-waste. Maybe it would be better to use another term e.g. take-back Material or end-of-life equipment. It is actually possible that it won't be decided, whether the material is waste, until it reaches its final destination/recycling plant.”

From p. 5 of Solve the E-waste Problem (StEP) response to Basel Secretariat. 2012. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version of 27 September 2012)’. http://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW-OEWG.8-INF-9-Rev.1.English.doc.

“The United States supports the partial or full deletion of Section IV provisions for “Procedures for transboundary movement of used equipment that is not waste.” However, if Section IV A and/or B remains in the document then it is not correct to state that the guidelines focus on “e-waste” and used equipment “that may be e-waste.” With the inclusion of Section IV, the guidelines clearly discussed used equipment that is not waste.

Additionally, the sentence does not make sense if these words are included. Inclusion of the words results in the sentence stating that the guidelines provide guidance for managing TBM of waste and used equipment “that may be waste.” However, if the used equipment is waste then it is covered in the first part of the sentence. The second part of the sentence does not add anything. Therefore, we suggest deleting these words.”

From p. 5 of  response by United States to Basel Secretariat. 2012. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version of 27 September 2012)’. http://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW-OEWG.8-INF-9-Rev.1.English.doc.