FEAD and EERA Joint Response to the Possible Incorporation into the OECD Decision of Recent Amendments to Basel Convention

With the occasion of the last Basel Convention e-waste amendments and the ongoing discussion about their integration into the OECD Decision, FEAD and EERA consider it crucial to bring
the need for clear and efficient shipment rules to the negotiation table.

To enable the circular economy in a competitive and innovation driven way, with the minimum environmental impact, waste managers need an economy of scale in which end-of-life products can find its way to the most adequate and specialised facilities in order to be recycled into valuable secondary raw materials that will reenter the product’s value chain.

Unnecessarily heavy, costly, and lengthy procedures are trade impediments to circular business models, which should be based on open and safe markets.

Following a survey among the Members of both Associations, the results show clear deficiencies and big disparities, for example, in the implementation of the Prior Informed Consent (PIC) procedure. It is therefore critical to update and improve the procedure to make it simple, online and transparent, strengthening the pre-consent status for facilities and revising of the financial guarantees by including a risk-based approach.

FEAD and EERA strongly advocate for such improvements that will facilitate the trade of recyclables in an environmentally sound and economically efficient manner, and hope that the practical examples provided will serve the legislator and competent authorities to address the issue and implement the needed reforms
in the system.

Kurt Kyck, EERA President said: “The pre-consented status for facilities must become a reality recognised by all competent authorities in OECD countries. For this to happen, it should become a mandatory obligation to implement, and not a mere possibility. It is worrying to see that 30 years after its regulation, members reported there being little or no difference in the administrative and financial burden between a consignment made to a pre-consented facility or not”.

Peter Kurth, FEAD President said: “Notification procedures are currently long and burdensome, which needs to change if we want to make the circular economy a reality. In this sense, the unification and harmonisation of administrative costs is also important. These are currently prohibitively high and not proportional to the risk, costs or work involved, and significantly increase the overall financial burden of legitimate global e-waste operators. What we are asking for is harmonised, transparent, risk-based requirements that result in reasonable and justifiable administration costs.


Source: FEAD (Brussels, November 09, 2022)