“[BAN Comment: I think it is a critical mistake to not include parts or components in the definitions here and in particular in distinguishing waste from non-waste. It is incorrect to assume them either as waste or non-waste until their functionality and fate is known and there is no reason to limit the scope of this guideline to being for whole equipment only. This guideline should be as comprehensive as possible and include all that we have learned on this issue elsewhere. What we have learned is that there is a very robust market for used parts and components that serves the cause of re-use. We just need to make sure that such trade, if it falls under the Convention, is controlled accordingly.”
From p. 4 of response by BAN 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.