“The consequence of a strict Annex VI that places a requirement of a functionality test on manufacturers before moving products for repair or refurbishment would make these legitimate shipments of non-functional devices illegal. Requiring a functionality test would be an impossible requirement to meet. We cannot declare that a product is functioning until it has been reviewed by an expert. This test would effectively shut down the repair and refurbishment market.”
From p. 3 of response by American Chamber of Commerce to European Union (AMCHAM EU) 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.