November 10, 2022

EERA and FEAD Joint Response to the European Commission on the incorporation into the OECD decision of recent amendments to Basel Convention

EERA and FEAD ardently believe that the harmonisation and improvement of regulations intended for the shipment of waste will bring about the prevention of the dumping of untreated e-wastes in those countries without the correct infrastructure and knowledge to ensure that harmful substances are eradicated.

EERA and FEAD have each made statements in recent months regarding the amendments to Annexes II, VIII and IX to the Basel Convention, and its’ possible impact and implications.

Both Associations note that these amendments need to ensure it is clear that imports from non-OECD countries to OECD countries are not prohibited, and that the PIC system has to be updated before they are implemented. Considering the increase in PIC applications the amendments will imply, clear guidance and specific training is essential to ensure that all Competent Authorities globally work to the same procedure and policies.

The PIC procedure itself needs to be simplified, online and transparent, especially the procedure for consignments being made to pre-consented facilities. In addition, the methodology for financial guarantees should also be revised and simplified using a risk-based approach. This is in order to facilitate the trade of recyclables in an environmentally sound and economically efficient manner.

We wish to complement our positions with the following additional collaborative comments (with our recommendations in boxes): see attached paper.