“Please note that POP BFRs are not analogues of PBBs. POP BDEs and PBBs are very different as they have different toxicity and mode of action. Even within the PBDEs, there are considerable differences. As a result, we believe that entry A3180 in Annex VIII of the Basel Convention should not apply to POP BDEs.”

From p. 16 of response by Bromine Science and Environmental Forum (BSEF) to to Basel Secretariat. 2014. ‘Draft Technical Guidelines on Transboundary Movements of Electronic and Electrical Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention (Draft of 20 November 2014)’. http://www.basel.int/Implementation/Ewaste/TechnicalGuidelines/DevelopmentofTGs/tabid/2377/Default.aspx.