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/ Secretariat of the Basel Convention
BSC technical guidelines on TBM of E-waste - comments by Norway

Submission by Norway related to decision IX/6 on the environmentally sound management of E-waste, and decision OEWG-VII/5 on the development of E-waste guideline agreed on by the Open-ended Working Group of the Basel Convention at its seventh session in May 2010.

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General comments

Norway would like to thank the Secretariat of the Basel Convention for the efforts in developing the draft guidelines on E-waste. Norway would like to suggest enhanced consistency between the different efforts on E-waste under the Convention. In particular some sections would benefit from taking into account the comprehensive work which is being carried out under the PACE partnership to a larger degree. Furthermore, we would like to suggest that the guideline would benefit from consistency in wording, in particular relating to the use of the terms shipment, consignment, transboundary movement and movement. In this regard, the guideline would highly benefit from a section on glossary of terms.

Specific comments

·  Paragraph 9: we would suggest moving the part on hazardous substances to the first part of the first sentence. This in order to better highlight the importance of ESM of E-waste in terms of its hazardous substances. The new sentence would read: E-waste may contain both hazardous substances such as mercury, PCB, asbestos and CFC’s requiring careful waste management as well as valuable materials that are recovered for recycling such as copper and precious metals.

·  Paragraph 22: We prefer this information to accompany all shipments of used equipment. We suggest removing the following text “the following should be provided to back up this claim to an authority on its request”, and replacing it with; “the following should accompany the shipment to back up this claim to an authority”, consistent with paragraphs 28, 30 and figure 1 under paragraph 32.

·  Paragraph 23, bullet point b: We understand the need for this paragraph. However, we are concerned the possibility of using repair centre as a loophole to circumvent the Convention.We therefore identify a need for further clarification on the term “repair centre” and perhaps include the similar term from PACE and MPPI “intended to be returned to them the same or similar products.”

·  Paragraph 34. Line 2: We believe the wording should read used equipment, and not used mobile phones.

·  Paragraph 38, line 1: We suggest inserting the word used. The sentence would then read: All pieces of used equipment, individually or in partitioned batches, must be appropriately documented with reference to the above-mentioned Statement, or other suitable method, so that recipients in the importing country are properly informed.

·  Paragraph 39, line 2: We believe 3 calendar days is rather limited amount of time, and suggest giving the authorities 3 working days to acknowledge the shipment.

·  Paragraph 41, line 5-7: We will suggest lifting this sentence because we believe it is highly relevant and important. We suggest including this sentence as a separate paragraph.

·  Paragraph 48: We suggest including in the wording: The examples are not meant to be exhaustive.

·  Paragraph 48: We suggest to include the following hazardous components on the list of examples:

o  Other components containing or contaminated with mercury, such as mercury switches, contacts, thermometers, which are assigned to annex VIII entry A 1010/1030/1180. This waste also belongs to category Y29 in Annex 1, Mercury; mercury compounds and is likely to possess hazard characteristics H6.1, H11, H12 and H13.

o  Waste oils/liquids, which are assigned to annex VIII entry A 4060 “Waste oil/water, hydrocarbons/water mixtures, emulsions”. The waste also belongs under category Y8, Y9 and is likely to possess hazardous characteristics H3, H11, H12and H13.

o  Components containing asbestos, such as in wires, cooking stoves and heaters, which are assigned to annex VIII entry A 2050. The waste also belongs under category Y 36 and is likely to possess hazardous characteristic H 11.

·  Appendix II: Under the heading functionality test we suggest to include the following: Functionality test of key functions.

·  Appendix II: Under the heading computers we suggest to make an inquiry to PACE – project group 1.1, as they have carried out comprehensive work on the topic in: Guideline on environmentally sound testing, repair and refurbishment of used computing equipment (Section 3.1.11 in draft version 7, august 2010.).