Export of electronic waste (e-waste)May 2014

The Environmental Protection Authority (EPA) recommends all e-waste be

considered hazardous waste, unless it is verified otherwise.

Before exporting e-waste from New Zealand, the exporter must check whether

the waste is hazardous, using the criteria for hazardous waste in the Basel

Convention and under Schedule 3 of the NZ Imports and Exports (Restrictions)

Prohibition Order (No 2) 2004) (the Order) (www.legislation.govt.nz).

It is likely mixed e-waste will contain some wastes that are defined as hazardous under the

Order. Exporters should obtain an export permit for all e-waste exports unless there is

evidence to demonstrate it is not hazardous waste. The EPA cannot issue an export permit

for hazardous waste without the specific prior consent of the importing country. Exporters

should check the rules governing the import of hazardous waste for the country they

are exporting to.

The draft Basel e-waste guidelines advise exporters to include evidence to demonstrate

their e-waste is not hazardous when exporting it as non-hazardous waste. Exporters should

also include evidence to show the proposed treatment of the waste is environmentally sound.

You should be aware that if you send e-waste as non-hazardous and it is subsequently

found to be hazardous, the country of import may require that the shipment be returned,

and you would be responsible for the cost of any return shipment. You may also be liable

for prosecution under the Imports and Exports (Restrictions) Act 1988.

The EPA cannot verify that any particular shipment is or is not hazardous waste.

This responsibility rests with the exporter.

The Basel ConventionThe Basel Convention is an international treaty

to control the movement of hazardous waste

between nations and specifically to prevent

transfer of hazardous waste from developed

to less developed countries. Electronic waste

can be of a type defined under the convention.

Exporters can use the text of the Basel

Convention to help determine whether their

waste is hazardous. Electronic waste that falls

under code A1180 (Annex VIII) of the Basel

Convention is hazardous; if it falls under B1110

(Annex IX) it is non-hazardous. The definitions

of these codes can be found on the Basel

Convention web site at www.basel.int under

“The Convention”.

The draft guideline UNEP/CHW/OEWG.8/

INF/9/Rev.1 is available on: www.basel.

int/Implementation/TechnicalMatters/

DevelopmentofTechnicalGuidelines/

Ewaste/tabid/2377/Default.aspx

Export of electronic waste (e-waste) EPA0132

May 2014 2

E-waste items containing brominated flame retardants E-waste exporters should check whether any plastic e-waste might

contain brominated flame retardants (BFR). Plastic e-waste

containing BFR is classed as hazardous under the Basel

Convention. Many countries also have local rules concerning the

import of e-waste and BFR plastic.

Chemicals of particular concern are the BFR’s listed under the

Stockholm Convention:

hexabromodiphenyl ether and heptabromodiphenyl ether

(also known as octabromodiphenyl ether and octaBDE), and

tetrabromodiphenyl ether, and pentabromodiphenyl ether

(also known as pentabromodiphenyl ether, pentaBDE).

Advice for exporters of plastic e-waste Plastics containing BFR and unsorted plastics should be classified

as Organohalogen compounds in Part 2 Schedule 3 of the Imports

and Exports (Restrictions) Prohibition Order (No 2) 2004 with

hazardous characteristics 13, 14 and 15. The corresponding Basel

entry is A3180 (this also corresponds to Y45 in Annex 1) and Basel

hazardous characteristics H11, H12, H13.

Information from studies both overseas and in NZ, and other

UN guidance, indicates most old televisions will have BFR in their

plastics and this may include octa-BDE.

Unsorted plastic or plastic containing BFR may only be accepted

for export if it will be incinerated in a high temperature

incinerator. This is because it may contain the Stockholm-

listed bromodiphenyl ethers (BDEs).

Other options for unsorted plastic or BFR-containing plastic

would be to dispose of it at a Class A New Zealand landfill or to

store it until other overseas disposal options become available.

If the plastic is sorted into BFR-containing and non-BFR-containing

fractions then the former would be treated as unsorted plastic

and the non-BFR- containing portion could be exported as

non-hazardous waste under Basel code B3010.

Screening studies of e-waste materials in New Zealand indicate

some items have very high levels of BFR in the plastics.

These include:

printed circuit boards – are likely to have high levels of BFRs.

Those that have high power loads or are exposed to heat may

have very high or high levels. Other types may have very little

CRT TVs and computer monitors – usually very high levels in

the plastic housing and foot, coil and some of the printed circuit

boards. High levels in the remaining printed circuit boards. TV

remote controls usually have very high levels in the printed

circuit boards, the connectors and power unit

computers – usually very high levels in the fan, some of the

printed circuit boards (especially in older models) and in many

CD drives. Other components containing high levels include

printed circuit boards, hard drives and CPUs

modems and routers – most have very high levels in the plastic

printers – sometimes very high levels in the laser printer fuser

units. High levels were often, but not always, present in

other printer units. Toner cartridges do not have high levels.

photocopiers – sometimes very high levels in plastic on

outside panels. Printed circuit boards often have high levels

EFTPOS machines

power boards/multiplugs

telecommunications wire splitters

fan heaters – very high levels in some models, high in others

hair dryers – few tested but very high in one model but not

in two others, and

microwave ovens – can be very high in the door panels.

Items with high levels of BFR in plastic components include:

stereo equipment – varies between models and makes. A

few items have very high levels in components, others high

levels and many have low levels

light bulb fittings

some CD players

some washing machines

some fridges (in the plastic by the power source)

dishwashers, and

some freezers.

Note:

Very high means >10% of plastic component is BFR by weight;

high means >1% of plastic component is BFR by weight.

The age of items is a consideration - the Stockholm-listed

BDEs started to be phased out in 2004 and by 2008 most

manufacturers had stopped using them.

Printed circuit boards should be processed under Basel code

A1180 and exported with a permit unless the exporter can

demonstrate the hazardous components have been removed.

The Stockholm Convention listed BFRs are not considered to

be significant components in printed circuit boards.

More informationFurther guidance on which types of e-waste may be able to

be exported for recycling, and which may not, can be found

on the Ministry for the Environment’s website. Search for

Managing waste that may contain brominated flame retardants.

This document has references for more information.