“The use of the term "e-waste" is potentially confusing given that the purpose of the guidelines is to provide a distinction between waste and non-waste. While "e-waste" is a common term, its use in this document suggests that the shipment is already a waste. We recommend replacing the term "e-waste" with "used or end-of-life electronic and electrical equipment" throughout the document and characterizing the term. Also, the title of the guidance document should be revised accordingly and include reference to the Basel Convention for additional clarification.”
From p. 1 of Canada’s response to Basel Secretariat. 2010. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 22 September 2010)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.
“[…] the statement "To distinguish between waste and non waste in the case of e-waste focuses on equipment that is supposed to be still in working order or at least to be in such a state that it could be put into a state of normal functioning without too much handling" (i.e. paragraph 3) is vague […]”
From p. 2 of Canada’s response to Basel Secretariat. 2010. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 22 September 2010)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.
“The reference to ‘if not packed’ contradicts to what is required above in relation to the disctinction [sic] between waste and non-waste. Moreover, in figure 1, improper packaging implies the waste procedure.”
From p. 10 of EU response to Basel Secretariat. 2010. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 22 September 2010)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.
“We suggest careful look at the use of the term E-waste throughout the document. The term is sometimes used inter-changeably with electrical and electronic equipment, even in situations where it has not been determined whether such equipment is waste. It should be clear that used electrical and electronic equipment is not always waste.”
From p. 4 of United States response to Basel Secretariat. 2010. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 22 September 2010)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.