“[…] the guidelines should characterize what is deemed to be a ‘missing essential part’ for the purpose of evaluating whether equipment is a waste […]”
From p. 2 of response by Canada 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 above warrants further discussion.]”
From p. 8 of response by BAN 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.
"ITI recommends some further discussion on whether incidental parts replacement should be a basis for classifying otherwise whole and valuable equipment as waste. In many instances, valuable equipment may need some minor repair or refurbishment prior to remarketing. The continued use of such equipment can conserve resources and provide other important environmental and economic benefits. Such repair or refurbishment could generate parts or components that require disposal. The parties should clarify that incidental or minor parts replacement by legitimate refurbishment and repair operators is not in and of itself sufficient to qualify an export of used equipment for reuse a waste. Such an approach could have the unintended effect of directing functional equipment requiring only minor repair or refurbishment to materials recovery before the end of its useful life, with unnecessary environmental costs and lost social, economic and environmental benefits that an arise from legitimate reuse. One option would be to require minor repairs to take place at a facility certified to comply with the forthcoming Basel PACE Refurbishment Guidelines to ensure that any incidental wastes from the refurbishment process are managed properly. At a minimum, the guidance should recognize that the Convention leaves it to the parties to decide whether used equipment exported for repair or refurbishment with the intention of reuse should be managed as a waste or a non-waste/product. ]"
From p. 9 of response by Information Technology Industry Council (ITI) 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.