“[…] it is unclear what would constitute a "whole appliance". This issue is further complicated by the fact that many components of used and end-of-life electrical and electronic equipment are marketed as stand alone products on their own (e.g. monitors, keyboards, video cards, RAM memory, etc.). We also recommend replacing the term "appliance" with "equipment" which generally has a broader interpretation in North America (e.g. appliances are frequently associated with large white goods such as refrigerators, washing machines, etc.). Furthermore, the statement "To distinguish between waste and non waste in the case of e-waste focuses on equipment that is supposed to be still in working order or at least to be in such a state that it could be put into a state of normal functioning without too much handling" (i.e. paragraph 3) is vague”
From p. 2 of Canada’s response to Basel Secretariat. 2010. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 22 September 2010)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.
“This work should be a comprehensive guide to all e-waste and its fractions. The industry and market is very capable of moving fractions as well as whole equipment. Indeed the distinction between fractions and whole equipment can be difficult as parts are often shipped. More importantly though, there is a great deal of movement of circuit boards, power supplies, monitors, CRT tubes, cables, CRT glass, etc. etc. It is vital, particularly when looking at the issue of what is hazardous and what is not, what is functional and what is not, that all of these fractions be included in this document. Indeed if more scrutiny and rigor is applied to whole equipment, this might encourage meaningless acts to break apart whole equipment to avoid the rigorous actions recommended by the guideline.”
From p. 5 of response by BAN to Basel Secretariat. 2012. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version 8 May 2012)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.