“This document must cover all electronic waste including shredded, broken, or crushed material as well as component parts and whole equipment.  There can be no good reason to not cover this material as the industry routinely disassembles and shreds electronics and much of these subparts are then exported.”

From p. 1 of BAN response to Basel Secretariat. 2011. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version: 21 February 2011 )’. http://archive.basel.int/techmatters/code/comments.php?guidId=78.

BAN is particularly concerned that, “[t]he mandate is to discuss ALL transboundary movements of e-waste whole or in parts no matter how small.   One is to look IN PARTICULAR at waste non-waste but that is not the entire scope of the mandate at all.   IN PARTICULAR means with an emphasis on, not solely on.   It would be a very serious mistake to make distinctions based on size of sub part.   Further such activities, depending on the interpretations herein might cause recyclers or handlers to unduly keep equipment whole or alternatively crushed or shredded.   Whereas the Basel Convention does not readily make distinctions on such criteria but rather on inherent hazardousness.   It is a serious misread of the mandate and a mistake to leave out e-wastes which is considered by the rest of the world as e-waste, from this guidance.”


From p. 5 of BAN response to Basel Secretariat. 2011. ‘Draft Technical Guidelines on Transboundary Movement of E-Waste, in Particular Regarding the Distinction between Waste and Non-Waste (Version: 21 February 2011 )’. http://archive.basel.int/techmatters/code/comments.php?guidId=78.