“We consider that the biggest argument concerning paragraph 26b is the residual waste which are possibly generated through the process of repair and refurbishment services. However, when considering the amount of hazardous wastes shipped illegally, recycled improperly and illegally repaired/refurbished, such hazardous wastes are relatively smaller amounts and can be monitored. We believe that if we cannot adopt the TGs due to disagreement on this criterion, we would have to say that it’s preposterous. Moreover, equipment imported as new products and UEEEs for direct reuse will become huge e-wastes once they reach their end-of-life. To deal with this essential problem, we need to promote and strengthen the implementation of ESM framework under the Convention.”

From p. 4 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.