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  • Notification controls for electrical and electronic waste: Prepare early for changes coming on January 1, 2025

Notification controls for electrical and electronic waste: Prepare early for changes coming on January 1, 2025

  • 30 March 2023

Following a UN Basel Convention decision in 2022, a prior informed consent (PIC) notification procedure will apply to all electrical and electronic waste with effect from January 1 2025. A survey conducted by BIR has concluded that this change will bring about a substantially increased workload for government and company administrators.

Under the UN Basel Convention ruling, newly-listed Y49 and A1181 “electrical and electronic waste” will require prior written notification and then consent from exporting, transit and importing countries’ competent authorities as from January 1 2025. At present, it is the hazardous waste listed in A1180 “Waste electrical and electronic assemblies or scrap” that requires prior written notification and then consent from the exporting, transit and importing countries’ competent authorities.

The BIR survey has enabled a comparison of the numbers of notifications for hazardous A1180 wastes and EU Annex VIIs for the non-hazardous B1110 “Electrical & Electronic Assemblies”, which helped predict the increase in notifications that competent authorities will need to process when Y49 notifications come into effect in 2025.

It is estimated from the survey results that the burden on governments will increase by a factor of four owing to the large number of notifications which will have to be processed.

Notification controls, written notifications and consent procedures from respective competent authorities are handled at the speed of government administration, frustratingly not at the speed of business. Furthermore, associated financial guarantees, fees and charges are likely to deter transboundary movements to recycling facilities which are necessary for a circular economy.

This fourfold increase in notifications will impose a significant burden on authorities given their limited personnel and resources, while also impacting on businesses by further delaying agreements for shipments. All countries’ competent authorities and recyclers of electrical and electronic waste will be affected unless the OECD and the EU agree that non-hazardous electrical and electronic waste does not require notification, instead introducing other assurances that these wastes will be recycled in an environmentally sound manner within OECD member countries and EU Member States.

BIR strongly recommends its members to be proactive and to plan ahead regarding notifications. It is also recommended that companies demonstrate they are environmentally soundly managed and apply for pre-consented status under OECD and EU legal frameworks. And BIR is also urging businesses to address these matters with their respective competent authorities, bringing to their attention this future workload and identifying solutions to process notifications more efficiently ahead of all the new requests quickly piling up.

If, in 2025, notifications for electrical and electronic equipment going for recycling do not increase as predicted, the question should be asked whether those recyclables are becoming trapped in countries without recycling facilities and, if so, what then is happening to those resources.

The BIR Secretariat would like to extend its thanks to all members who participated in this survey and for their valuable input, which provided the quantitative elements needed to make stronger and more tangible statements when advising governments.