“These numbers are pure guesses and the second paper only refers to the previous BAN reference.  I believe that such a controversial reference should be excluded from an otherwise authoritative document.”

From p. 1 of 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.

“Paragraph 10 states that 50 - 80% of e-waste from industrialized countries is exported, mainly to China and other East Asian countries. While it is not disputed that export does occur to developing countries and countries with economies in transition, it is questionable whether these figures are reliable given the complexity of international trade and increasing international efforts to combat illegal flows of e-waste. Furthermore, we believe that it is inappropriate to suggest that all operations in non-OECD regions lack capacity to manage recyclable materials or wastes in an environmentally sound manner. Given that Paragraphs 9 and 11 introduce the issue of a-waste exports and challenges faced by developing countries, it is recommended that Paragraph 10 be removed.”

From p. 2 of response by Canada 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.

“We support the deletion of this paragraph [referring to 50-80% figure]. The statistics used in this paragraph have been continually cited by the media and NGOs; however, there is no qualitative analysis to back them up. Currently, the UNU StEP, MIT, and the NAFTA Council for Environmental Cooperation are conducting analysis of transboundary flows of e- waste exports. The challenges that have been posed in terms of the historical lack of tracking data, illustrate the complexity of discerning such figures.”

From p. 5 of United States 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 8 May 2012)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.