“We consider it important that hazardous waste arising from failure analysis, repair and refurbishment activities be disposed of in an environmentally sound manner.
Rather than establishing criteria that specifies the destination for residual waste, we consider it would be more appropriate to place emphasis on transparency provisions and the obligations of exporters to demonstrate that any residual wastes generated will be managed in an environmentally sound manner in suitably licensed facilities. This could be in the State of import or elsewhere, as per the provisions for environmentally sound management of hazardous wastes exported under the Basel Convention.
Australian IT companies currently engaged in such trade have terms and conditions in their contracts to comply with all applicable environmental regulations, including proper disposal of any residual waste generated from repair operations. Some members also have programs to review supplier' environmental impacts. For original equipment manufacturers, handling and processing residual wastes is a strict and measurable requirement they place on their preferred repairers.
It is notable that the majority of countries that are conducting repair operations on electronic products sourced from Australia also manufacture new products that generate similar wastes as would be generated from repair. These countries, which are predominantly non-OECD countries, have advanced processing facilities (adhering to international environmentally sound management I best practices) that exceed capabilities within Australia.
We are not aware of any incidents in, or concerns from, importing countries regarding current practices for the management of residual wastes arising from the existing trade in used equipment for failure analysis, repair and refurbishment from Australia.”
From 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.
“The area of disagreement relates to whether there are further restrictions on the waste element. The more problematic items (in square brackets) relate to suggestions that any residual can only be returned to the country exporting the non-functional equipment for repair. We are opposed to this approach because:
The country exporting the item for repair may have no facilities to properly manage the residual from repairs
The country designing and making the item may well be the country doing the repairs (especially if this is under warrantee). Following the logic underpinning extended producer responsibility (EPR) the producer is usually best equipped to manage the product. This restriction would prevent this.
An example of the problem with the wording would be (say) a Chinese designed and made product under warrantee could be repaired but the defective parts would be returned to the country that imported the equipment in the first place. The parts would be exported for ESM again if the country using the computer had no resource recovery facilities.
The suggestion gives no recognition to the position of small countries dependent of offshore suppliers for electronic equipment and nor does it recognise that there are costs and adverse impacts from shipping wastes backwards and forwards (ie waste miles).”
From p. 5 of response by New Zealand 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.