“Footnote 17 [referring to Basel Convention Annex IX B1110]  is the source of great contradiction and therefore confusion.   The problems with this footnote are that it does not distinguish between direct reuse and reuse.   And further never defines major reassembly.  It was recommended by the MPPI working group to just ignore this footnote and clearly distinguish between reuse involving repair (often involves recycling and disposal) and reuse not involving repair (direct) in the guideline.   – I think a note in this document describing the problem above is warranted.”

From p. 15 of BAN response to Basel Secretariat. 2011. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version: 21 February 2011 )’. http://archive.basel.int/techmatters/code/comments.php?guidId=78.

 

“I think it is misleading to state that “reuse can also have a negative impact if not done properly.”  Reuse most always has a better environmental impact.  I believe the author was trying to suggest that there are exporters that pretend to be sending equipment for reuse but in reality it is going for other purposes.  I would appreciate this language being clarified.”

From p. 1 of response by PC Rebuilders & Recyclers (PCRR) to Basel Secretariat. 2011. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version: 21 February 2011 )’. http://archive.basel.int/techmatters/code/comments.php?guidId=78.