"No clear definition of 'residual life'."
From p. 1 of response by African Group to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.
“We appreciate the intent of this proposed condition in seeking to avoid imports of used equipment that have a short life, which then pose a waste disposal problem for countries that do not possess the capability to manage the waste stream in an environmentally sound manner.
However, we consider the criteria on residual life/age […] do not offer a practical solution, and pose a significant risk (if adopted) of stopping the legitimate export of used equipment for the purpose of repair/refurbishment and the premature scrapping of many products”
From p. 1 of response by Australia to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.
“It is our understanding that it is difficult to determine the residual average age for all electronics because it depends on multiple factors as the type, handling, social habits, technology used, among others.”
From p. 1 of response by Brazil to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.
“In order to be accurate, the determination of residual lifetime must consider many factors (e.g. type and make of the equipment, age of manufacturing or start of use, age of certain parts, conditions of use, etc.). An arbitrary residual lifetime value (e.g. one third, since date of manufacture) would lead to the discard of products that may have years of functional life left and work against the waste hierarchy agreed upon under the Basel Convention. We note serious implementation challenges with the residual lifetime criterion that may create barriers to the trade of these goods if not adequately defined.
[…]
At this time and based on our current knowledge, we do not consider it possible to use this criterion
in the determination of waste or non-waste status under the Basel Convention.”
From p. 1 of response by Canada to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.
“Colombia considers that the requirement of the residual useful life […] is a difficult parameter, if not impossible to determine with technical certainty.”
English translation from p. 2 of response by Colombia to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.
“Imposing an arbitrary residual lifetime for all medical devices as a condition of ‘non-waste shipment’ is not reasonable. A “one size fits all” threshold level will preclude many modalities from refurbishment or repair.”
From p. 2 of response by Global Diagnostic Imaging, Healthcare IT & Radiation Therapy Trade Association (DITTA) to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.
“The ICT sector recognizes the legitimate concerns that many countries have regarding the import of used electronic equipment that, while still functional, may be near the end of its useful life. Our member companies do not engage in the unrestrained business of re-selling such “near end-of-life” equipment.
As a practical matter, determining the residual life of a product is very difficult and often depends on the way it was used, the conditions of use (e.g., humidity) and maintenance. We therefore view this proposal as a problematic criterion for making waste/non-waste determinations.
We note that used equipment that is put back into commerce by the manufacturer (or its contracted vendor) often carries a warranty or similar guarantee. Our companies stand behind this equipment and would not consider such products to be “near end-of-life.” This may be different from brokers who sell used equipment in bulk to other brokers or middlemen, offer no warranties and have no connection with the ultimate customer.”
From p. 3 of Information Technology Industry Council (ITI) response to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx
“i) Disagree with the residual life of the equipment is no longer than 1/3 of the normal life-span of this kind of new equipment.
ii) The used equipment shall be considered as waste by the National Legislation or national guidelines for used electrical and electronic equipment including the age of the used equipment from the date of manufactured.”
From p. 2 of response by Malaysia to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx
“this [residual life no longer than 1/3 normal lifespan] is unworkable. It requires a regulator to have a view of the ‘normal lifespan’ of each type and make of equipment. We don’t have this information and we cannot see how this would work in practice, especially since some people are happy to use items that are older (and outdated) whilst other aren’t. (Note too that this criterion is much more difficult to implement than ‘is it functional’?”
From p. 2 of response by New Zealand to Basel Secretariat. 2015. ‘Decision BC-12/5 | Technical Guidelines on Transboundary Movements of Electrical and Electronic Waste and Used Electrical and Electronic Equipment, in Particular Regarding the Distinction between Waste and Non-Waste under the Basel Convention’. http://www.basel.int/TheConvention/ConferenceoftheParties/Meetings/COP12/tabid/4248/mctl/ViewDetails/EventModID/8051/EventID/542/xmid/13027/Default.aspx.