BAN's comments on the Draft Technical Guidelines of 22 September 2010 suggest a title change for the guideline document from "Draft Technical Guidelines on Transboundary Movement of E-waste, in Particular Regarding the Distinction Between Waste and Non-Waste" to "Draft Technical Guidelines on Transboundary Movement of E-waste". BAN's comments note that the distinction between waste and non-waste, "should not be the primary purpose or singled out. While this is an important matter, the document needs to be comprehensive."

From p. 1 of BAN's response to ‘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.