"[RoHS] was developed and applied in the European Union (UE) [sic] but not in the whole world"

From p. 1 of response by Argentina 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 recognize the risk of high content of hazardous substances possibly generated from repaired and refurbished equipment. However, we consider that EU ROHS is not appropriate as a condition in the TGs because EU ROHS is only a regional regulation and is able to be changed by EU without other region’s agreement. Moreover, we consider that a reference to ROHS is not enforceable because if equipment is properly packed as suggested by paragraph 24(d), enforcement officials cannot easily reveal it to confirm.”

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 understand that this measure [reference to RoHS] may be intended to help countries to identify equipment that is likely waste due to its age.  However, we do not think it is appropriate to include a regional requirement in international guidelines.”

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

“Brazil considers that the reference to RoHS is not feasible and enforceable at this moment, mainly because it is a norm that does not apply to all parties of the Basel Convention.”

From p. 1 of response by Brazil 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.