“We are concerned as regards referring to the listing of facilities. We think it would be very burdensome, in particular for large countries with many facilities, to list all relevant facilities and keep the information up to date.”

From p. 13 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/Imp

“We recognize the necessity of information regarding testing/repair, refurbishment services facilities for exporting countries to identify camouflaged cases. However, we wonder the necessity and feasibility of registering all the facilities and maintaining the database.
We suggest removing this criterion from this paragraph and alternatively creating a new paragraph which gives guidance for exporting countries.”

From p. 2-3 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 are unsure of the practicality of indicating to the Secretariat a list of all permitted facilities that test, repair, or refurbish equipment, as suggested in the third sentence of subparagraph (i).  We note that countries currently do not report waste facilities, which are within the scope of the Basel Convention.  This is likely in recognition that doing so is impractical, among other reasons, due to the burden on both countries and the Secretariat to keep any list up to date.  However, we agree that a tool that would allow enforcement officials and exporters to easily identify countries with capacity to test, repair, or refurbish equipment could also be useful in ensuring that shipments are actually going to be repaired or refurbished in the destination country.  Such information would help exporting companies identify locations where their equipment could be repaired or refurbished and could help enforcement officials build evidence that a shipment of equipment is actually a waste shipment.”

From p. 2 of response by United States 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