“Referencing characteristics of hazardous components is perferred [sic] over making exhaustive lists of hazardous and non-hazardous equipment. Technology and legislation will continue to change the substances used in equipment changing status from hazardous to non-hazardous or visa versa. The issue is the accuracy of a static list over time, which could mislead enforcement authorities in making hazardous determininations.”
From p. 1 of response by Philips 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.