“The Medical Devices Industry recommends amending the TG [the Technical Guidelines], to ensure that legitimate and environmental friendly activities will not be hindered or even prohibited, according to the following recommendations:

1. To establish a clear distinction between consumer goods and capital investment goods for professional use
2. To develop sets of criteria/exclusions for capital investment goods for professional use.”

From p. 1 of joint response of American Chamber of Commerce to the European Union (AMCHAM EU), European Radiological, Electromedical and Healthcare IT Industry (COCIR), National Electrical Manufacturers Association (NEMA), and the Japanese Industries Association of Radiological Systems (JIRA) 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 would like to underline a critical aspect of the Guidelines document. It does not distinguish between consumer goods and capital investment goods for professional use. The latter, in particular medical devices, can have very long service life (higher than 10 years) and are subject to refurbishment or repair practice under very strict and controlled conditions. Due to their high technologic content they can often be repaired only at the site of the original manufacturer or their specialized centers of which only a few exist worldwide.”

From p. 3 of Joint Healthcare Industry response to 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.

“StEP is concerned that the language used is mainly for consumer products only, but leaving servers, medical equipment etc. aside. Therefore this section should be re-visited to address also the missing EEE and the specifics of the B2B sector.”

From p. 10 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.