“This criterion is neither enforceable not quantifiable. The use of the term "life-span" seems cumbersome and perhaps counterproductive. Life-span, as many different design useful-lives, each related to a specific batch of products, may not correspond to the condition of a particular used product, the life span depends by many factors by on the kind of EEE, the conditions for using EEE, the climate and so on.”
From p. 12 of response by European Union to Basel Secretariat. 2014. ‘Draft Technical Guidelines on Transboundary Movements of Electronic and Electrical Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention (Draft of 20 November 2014)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.
"This [enforceability problem] can also be said for the “Age limit” which was newly suggested at SIWG. We need to recognize that there is no indication of the product year and the serial number on many used parts, which makes it very difficult to identify the age of the equipment. ”
From p. 3 of response by Japan to Basel Secretariat. 2014. ‘Draft Technical Guidelines on Transboundary Movements of Electronic and Electrical Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention (Draft of 20 November 2014)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.
“We appreciate the intent of this proposed condition in seeking to avoid imports of used equipment that have a short life, which then pose a waste disposal problem for countries that do not possess the capability to manage the waste stream in an environmentally sound manner.
However, we consider the criteria on residual life/age […] do not offer a practical solution, and pose a significant risk (if adopted) of stopping the legitimate export of used equipment for the purpose of repair/refurbishment and the premature scrapping of many products”
From p. 1 of response by Australia to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.