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2010-09 Draft Technical Guidelines [2010 Sept]
Document
1
#437777
CONTEXT
(Help)
-
Electronic Waste »
Electronic Waste
Electronic Waste☜An issue map of electronic waste as a matter of concern.☜F1CEB7
▲
Draft Technical Guidelines »
Draft Technical Guidelines
Draft Technical Guidelines☜An issue map of the negotiations over the design of Technical Guidelines on transboundary movement of e-waste, in particular regarding the distinction between waste and non-waste.☜9FDDBE
▲
Documents »
Documents
Documents☜☜B5ACA0
■
2010-09 Draft Technical Guidelines [2010 Sept]
2010-09 Draft Technical Guidelines [2010 Sept]☜☜B5ACA0
◄
Countries cannot unilaterally declare non-waste »
Countries cannot unilaterally declare non-waste
Countries cannot unilaterally declare non-waste☜A position that holds that the Basel Convention defines a list of hazardous wastes. Signatories (countries) may add to this list, but they may neither unilaterally subtract from it nor unilaterally declare a given material to be non-waste or non-hazardous (and thus exempt from the Convention).☜FFFACD
◄
E-waste generation and flow figures need clarification »
E-waste generation and flow figures need clarification
E-waste generation and flow figures need clarification☜What figures to use to characterize the amount of e-waste generated and how those figures are arrived at becomes an issue amongst protagonists.☜FFFACD
◄
BAN responsible for 50-80 percent export figure »
BAN responsible for 50-80 percent export figure
BAN responsible for 50-80 percent export figure☜BAN commentary notes the organizations report Exporting Harm as the source for the 50-80 percent export figure. BAN suggests clarifying both the source of the figure and that it comes from an industry insider/consultant.☜FFFACD
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Global e-waste generation figures needed »
Global e-waste generation figures needed
Global e-waste generation figures needed☜The Draft Technical Guidelines of 22 September 2010 quote numbers for generation of e-waste in the European Union.☜FFFACD
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Scope of Technical Guidelines needs clarification »
Scope of Technical Guidelines needs clarification
Scope of Technical Guidelines needs clarification☜☜FFFACD
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Control procedures must match the Convention »
Control procedures must match the Convention
Control procedures must match the Convention☜A position that the Technical Guidelines must accurately reflect the legal provisions for control of transboundary movement of hazardous waste under the Basel Convention. The Guidelines should not establish separate requirements relating to the control of tansboundary movements of electronic discards.☜FFFACD
◄
Precision needed in distinction between waste/non-waste »
Precision needed in distinction between waste/non-waste
Precision needed in distinction between waste/non-waste☜☜FFFACD
◄
Recognize benefits of repair and reuse »
Recognize benefits of repair and reuse
Recognize benefits of repair and reuse☜A position that prolonging the use of electronics as well as their repair and reuse have economic, social and environmental benefits that should be made explicit in the Technical Guidelines.☜FFFACD
◄
Recognize the benefits of recovery »
Recognize the benefits of recovery
Recognize the benefits of recovery☜A position that holds that recovery is a desirable way to manage electronic discards.☜FFFACD
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Scope of Guidelines should cover parts and components »
Scope of Guidelines should cover parts and components
Scope of Guidelines should cover parts and components☜☜FFFACD
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Technical Guidelines should link to MPPI and PACE »
Technical Guidelines should link to MPPI and PACE
Technical Guidelines should link to MPPI and PACE☜A position that the Technical Guidelines should link to or be harmonized with parallel initiatives underway in the Basel process, namely the Mobile Phone Partnership Initiative (MPPI) and the Partnership for Action on Computing Equipment (PACE).☜FFFACD
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Transboundary movement of e-waste should be primary issue »
Transboundary movement of e-waste should be primary issue
Transboundary movement of e-waste should be primary issue☜The distinction between waste and non-waste is important but subordinate to a broader issue: the transboundary movement of e-waste.☜FFFACD
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Whole-part distinctions difficult to make »
Whole-part distinctions difficult to make
Whole-part distinctions difficult to make☜Whole-part relationships between equipment and its components are difficult to make and the relationship can change. For example, a computer is comprised of components that are sometimes marketed as standalone components (e.g., keyboard, monitor, RAM).☜FFFACD
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Guidelines should support BAN Amendment. »
Guidelines should support BAN Amendment.
Guidelines should support BAN Amendment.☜BAN notes that the Amendment adopted in 1995 though not yet in force has been implemented, by many countries.☜FFFACD
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Risk of repair as loophole. »
Risk of repair as loophole.
Risk of repair as loophole.☜BAN acknowledges importance of export for repair, but argues that the most common motivation for export is cost externalization for more environmentally sound management.☜FFFACD
◄
Annex VIII and IX of Convention need review »
Annex VIII and IX of Convention need review
Annex VIII and IX of Convention need review☜Annex VIII and IX of the Basel Convention defined lists of hazardous and non-hazardous wastes respectively. Both Annexes contain materials relevant to e-waste which causes confusion for the Technical Guidelines.☜FFFACD
◄
Consider using price paid to disntinguish waste/non-waste »
Consider using price paid to disntinguish waste/non-waste
Consider using price paid to disntinguish waste/non-waste☜If prices paid for used equipment are below what would be expected for working equipment, this may be a good indicator of a waste shipment.☜FFFACD
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Situations in which used equipment is or is not waste »
Situations in which used equipment is or is not waste
Situations in which used equipment is or is not waste☜☜FFFACD
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Clarification needed on the meaning of "essential part" »
Clarification needed on the meaning of "essential part"
Clarification needed on the meaning of "essential part"☜☜FFFACD
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Lack of sufficient information about shipment means it is waste »
Lack of sufficient information about shipment means it is waste
Lack of sufficient information about shipment means it is waste☜There must be sufficient information available to any relevant authority (e.g., customs, police, or environmental agencies) to show that the equipment in a given shipment meets the criteria of non-waste. If insufficient information accompanies a shipment, it should be considered a waste shipment and thus subject to precautionary prohibition.☜FFFACD
◄
Parties can independently/voluntarily define what is waste »
Parties can independently/voluntarily define what is waste
Parties can independently/voluntarily define what is waste☜☜FFFACD
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EU wants further discussion of Section III D »
EU wants further discussion of Section III D
EU wants further discussion of Section III D☜The EU notes that inclusion of a voluntary procedure in the Draft Technical Guidelines may have implications that need further discussion.☜FFFACD
◄
Independent definition of waste risks accelarated waste generation »
Independent definition of waste risks accelarated waste generation
Independent definition of waste risks accelarated waste generation☜Independent or voluntarily definitions of waste by Parties risks late model equipment suitable for repair and reuse being designated as waste, thereby accelerating waste generation.☜FFFACD
◄
Parties cannot opt out of Article 1.1a of Basel Convention »
Parties cannot opt out of Article 1.1a of Basel Convention
Parties cannot opt out of Article 1.1a of Basel Convention☜The Draft Technical Guidelines are a guide not law and thus cannot supersede the legal requirements of the Convention itself. The Convention does not permit Parties to opt out of the list of materials deemed hazardous as defined in Article 1.1a☜FFFACD
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Processing recovered materials may render them commodities »
Processing recovered materials may render them commodities
Processing recovered materials may render them commodities ☜A position that holds that processing materials deemed waste may lead to their redefinition as commodities in some jurisdictions.☜FFFACD
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Shipments for maintenance, repair, or refurbishment are not wastes »
Shipments for maintenance, repair, or refurbishment are not wastes
Shipments for maintenance, repair, or refurbishment are not wastes☜A position that holds that transboundary shipments of equipment destined for activities such as routine maintenance, repair, upgrading, servicing, or refurbishing should not cont as waste.☜FFFACD
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Meanings of maintenance, refurbishment, and repair need clarification »
Meanings of maintenance, refurbishment, and repair need clarification
Meanings of maintenance, refurbishment, and repair need clarification☜☜FFFACD
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Only return for reuse and under warranty acceptable »
Only return for reuse and under warranty acceptable
Only return for reuse and under warranty acceptable☜☜FFFACD
◄
If no disposal from MRR, then not waste »
If no disposal from MRR, then not waste
If no disposal from MRR, then not waste☜If any activity related to maintenance, repair or refurbishment of used equipment leads to the discard or recycling of any component or material that meets the Basel Convention definition of hazardous waste, then the shipment of equipment is deemed hazardous and subject to Basel Convention control.☜FFFACD
◄
Shipments under warranty/lease/product servicing are not waste »
Shipments under warranty/lease/product servicing are not waste
Shipments under warranty/lease/product servicing are not waste☜A position that holds that transboundary shipments of used equipment should not be considered waste if the shipment constitutes warranty/lease/product servicing returns from a producer to the original producer, original component supplier, or a contract agent completing warranty/lease/product servicing activity on behalf of an original producer.☜FFFACD
◄
There is a need for functionality tests prior to shipment »
There is a need for functionality tests prior to shipment
There is a need for functionality tests prior to shipment☜Functionality tests should be performed on used equipment to determine its suitability for reuse.☜FFFACD
◄
All equipment must be tested fully functional prior to shipment »
All equipment must be tested fully functional prior to shipment
All equipment must be tested fully functional prior to shipment☜An premise supporting shipments for maintenance, repair, or refurbishment on the condition that the equipment to be shipped is tested as fully functional before transboundary movement occurs.☜FFFACD
◄
Use key function approach »
Use key function approach
Use key function approach☜☜FFFACD
◄
Clarification needed on meaning of 'fully functional' »
Clarification needed on meaning of 'fully functional'
Clarification needed on meaning of 'fully functional'☜☜FFFACD
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Need for guidance on who performs testing »
Need for guidance on who performs testing
Need for guidance on who performs testing☜☜FFFACD
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Tests need to capture broad range of equipment »
Tests need to capture broad range of equipment
Tests need to capture broad range of equipment☜☜FFFACD
◄
Make innefficiency of informal sector explicit »
Make innefficiency of informal sector explicit
Make innefficiency of informal sector explicit☜A position that claims the informal sector is inefficient at material recovery compared to formal sector operations. ☜FFFACD
◄
Term "e-waste" confuses waste/non-waste distinction »
Term "e-waste" confuses waste/non-waste distinction
Term "e-waste" confuses waste/non-waste distinction☜Because the term e-waste already contains the term waste, its use in the Technical Guidelines confuses what the document is supposed to accomplish, that is, the distinction between waste and non-waste. It would be better to use the phrase used and end of life electronic and electrical equipment.☜FFFACD
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Entered by:-
Josh Lepawsky
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#437777
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Entry date (GMT):
7/21/2016 11:20:00 AM
Last edit date (GMT):
7/21/2016 11:31:00 AM
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