“BAN has been involved in this discussion for a long time and we have found no evidence that Parties do not consider used equipment for which part will need to be discarded as a non-waste. The US took this position in the past (MPPI) discussion but it is unknown whether they still take that position. And of course they are not as yet a Party. Further, this guidance document should not simply repeat what has already been done at MPPI and leave it up to the Parties. This document should propose a way forward to be followed by all of the Parties. It needs to give direction and make recommendations to Parties as how to interpret this question and not simply say its up to the Parties to decide. If all of these questions were simply up to the Parties, then we would not need a guidance document. We believe that the logic of the decision tree (MPPI) is strong. That is repair is both re-use and disposal at the same time when parts are replaced and old ones discarded. In such cases then the material is clearly a waste.”
From p. 10 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.