• Beginning January 1, 2025, international trade in most recyclable and recycled electrical and electronic materials will be subject to the controls of the Basel Convention.
• The United States is not a party to the Basel Convention, so these new trade controls will significantly restrict the available export markets for U.S. exports of these products.
• Each country is responsible for implementing these new trade controls, so it is expected there will be disruptions that may not be resolved for weeks or even months.

Background
At the June 2022 Basel Convention Conference of Parties (COP-15), the parties (countries) to the Convention agreed to add new control measures governing the international trade of hazardous and non-hazardous “e-waste” and “e-scrap” materials. The entry into force of these new E-Amendments is January 1, 2025, and will subject shipments to prior informed consent (PIC) notifications, where exporters must obtain written consent from the importing country’s government that it will legally accept that shipment.

What is the Basel Convention?
The Basel Convention is a United Nations (UN) multilateral environmental treaty that controls international trade in primarily hazardous waste.

It was initially designed to reduce transboundary movement of hazardous waste products from the developed world to the developing world and to ensure environmentally sound management of these materials, but the scope of the Convention has increased in recent years and now controls trade in many recycled and recyclable products.

It does this by utilizing an expansive definition of waste subject to the controls of the Convention to include materials destined for recovery facilities. Many governments utilize similar definitions in their own national laws, which ignores the critical role recycled materials play in global manufacturing supply chains.

Currently, there are 191 parties to the Convention, but there is a party/non-party trade ban in effect that prohibits trade in Basel-controlled materials between parties and non-parties, unless there is a separate agreement in place that ensures stringent environmentally sound management of traded materials.

What Materials and Products are Covered by these Controls?
The Basel Convention has always controlled electronic materials that would be classified as hazardous or possessing hazardous characteristics, but the E-Amendments have created new classifications for both hazardous (A1181) and importantly for traders of recyclables, non-hazardous (Y49), electronic products. These new listings include three categories for hazardous and non-hazardous materials:

• Whole equipment
• Components, such as circuit boards, display devices, etc.
• Fractions that result from processing, such as shredding and dismantling

There are certain carveouts for materials that may be covered by a different Basel listing code, some of which may fall under Annex IX of the Convention (materials not covered by Basel controls). However, individual countries that are party to the Convention may choose to implement the E-Amendments differently and take different approaches to interpreting what falls in the bounds of recycled electrical and electronic materials.

Is the United States a Party to the Convention?
The United States is not a party to the Basel Convention. Because the Convention is an international treaty, it requires both the approval of the U.S. Senate and the legislative implementation of the obligations of the Convention into the U.S. statutory framework.  

The Bush-41 administration signed the agreement in 1990, and the Senate provided its “advice and consent” in 1992, but Congress never implemented the statutory obligations under the Convention and so the U.S. has never ratified the Convention.

As a result of the non-party status of the United States, U.S. traders in Basel-controlled materials have limited opportunities to legally trade these products abroad through side agreements under Article 11 of the Basel Convention.

What is Article 11 of the Basel Convention?
One key provision of the Basel Convention is Article 11, which allows parties to enter into agreements/arrangements with other countries (including non-parties) to govern trade of Basel-controlled materials, as long as the environmentally sound management of the materials is not weaker than those dictated by the Convention.

This provision allows non-parties, like the U.S., to trade in Basel-controlled recycled products, such as plastics and electrical/electronic products, with Basel parties, including many key trading partners. 

The most significant is the agreement related to materials destined for recovery among OECD member states (see below), but the U.S. has separate bilateral agreements with several countries, including Canada, that facilitate trade in these products and are crucial for the competitiveness of U.S. recycled materials exporters.

What is the OECD Council Decision?
The Organization for Economic Cooperation and Development (OECD), consists of 38 member states, primarily states considered developed countries, such as most of the European Union, United Kingdom, Canada, Japan, South Korea, Australia, New Zealand, Israel and Mexico. The OECD has its own Council Decision which acts as an Article 11 agreement among its member states and is the primary agreement that allows the U.S. to trade in Basel-controlled materials.

The OECD procedures for PIC are more streamlined and allow governments to pre-approve certain recovery facilities, which allow for smoother trade in Basel-controlled materials among member states.

Typically, the OECD will incorporate new Basel control measures into the Council Decision, but after more than a year of negotiations, member states failed to reach consensus. Thus, each member state can choose the extent to which it will incorporate the Basel or OECD control procedures into its regulations, which will impact whether countries will accept imports of recycled electrical and electronic materials from U.S. exporters.

Which Export Markets Can U.S. Exporters Send Material?
OECD member states will be the only option available for U.S. exporters of recycled electrical and electronic materials starting January 1, 2025. Countries that are outside the OECD should not accept these shipments, unless the government in the importing or transit country has negotiated a separate agreement with the U.S. government. To date, the U.S. has not entered into any new Article 11 arrangement with a non-OECD country to cover materials traded under the new E-Amendments.

The government of Canada recently announced that it would not impose strict PIC notifications and permits on recyclable electronics imported into Canada from OECD countries, like the United States, for recycling. This decision maintains the status quo for trading with Canada.

Additionally, the Japanese government has announced that it will not require PIC on imports of printed circuit boards and other electrical and electronic items. The competent authorities of several other countries, including those in the European Union, have outlined guidance about the necessary PIC procedures, but we will continue to compile formal guidance for ReMA members as it becomes available.

What’s Next?
Since the U.S. government does not regulate the export of most recycled electrical and electronic products as hazardous under U.S. law, it is critical that exporters work directly with the customer and the competent authority in the importing and/or transit country to determine the notification process and new rules that have been imposed. EPA expects most OECD countries to require PIC for shipments within the bloc, and no country has outright announced it will ban the shipments from non-parties, like the U.S.

Each OECD member state will determine whether it will require PIC notification or will use the old OECD codes for non-hazardous electronic materials. The OECD is expected in January to publish guidance for each member state as the governments finalize the regulations for trade in these products.

We will send this information out to ReMA members as it becomes available and are developing a tracking tool for ReMA members to help determine what rules will be in place for each OECD member state and countries with which the U.S. has an Article 11 agreement.

We will discuss the implementation of the E-Amendments at the next monthly meeting of the Electronics Division on Thursday, January 16, 2025, at 2:00pm EST.

The next in-person meeting of the Electronics Division will be held on Thursday, February 27, 2025 at 10:30am, in conjunction with the ReMA 2025 Winter Meeting at the Watergate Hotel in Washington, DC.

Additional Resources

• Basel Convention FAQs on “E-Waste Amendments”

• U.S. Environmental Protection Agency (EPA) guidance on new E-Amendments, including October webinar for regulated communities

For More Information
Please contact Adam Shaffer, ReMA AVP of International Trade and Global Affairs at 202-662-8532 or ashaffer@recycledmaterials.org.

• Beginning January 1, 2025, international trade in most recyclable and recycled electrical and electronic materials will be subject to the controls of the Basel Convention.
• The United States is not a party to the Basel Convention, so these new trade controls will significantly restrict the available export markets for U.S. exports of these products.
• Each country is responsible for implementing these new trade controls, so it is expected there will be disruptions that may not be resolved for weeks or even months.

Background
At the June 2022 Basel Convention Conference of Parties (COP-15), the parties (countries) to the Convention agreed to add new control measures governing the international trade of hazardous and non-hazardous “e-waste” and “e-scrap” materials. The entry into force of these new E-Amendments is January 1, 2025, and will subject shipments to prior informed consent (PIC) notifications, where exporters must obtain written consent from the importing country’s government that it will legally accept that shipment.

What is the Basel Convention?
The Basel Convention is a United Nations (UN) multilateral environmental treaty that controls international trade in primarily hazardous waste.

It was initially designed to reduce transboundary movement of hazardous waste products from the developed world to the developing world and to ensure environmentally sound management of these materials, but the scope of the Convention has increased in recent years and now controls trade in many recycled and recyclable products.

It does this by utilizing an expansive definition of waste subject to the controls of the Convention to include materials destined for recovery facilities. Many governments utilize similar definitions in their own national laws, which ignores the critical role recycled materials play in global manufacturing supply chains.

Currently, there are 191 parties to the Convention, but there is a party/non-party trade ban in effect that prohibits trade in Basel-controlled materials between parties and non-parties, unless there is a separate agreement in place that ensures stringent environmentally sound management of traded materials.

What Materials and Products are Covered by these Controls?
The Basel Convention has always controlled electronic materials that would be classified as hazardous or possessing hazardous characteristics, but the E-Amendments have created new classifications for both hazardous (A1181) and importantly for traders of recyclables, non-hazardous (Y49), electronic products. These new listings include three categories for hazardous and non-hazardous materials:

• Whole equipment
• Components, such as circuit boards, display devices, etc.
• Fractions that result from processing, such as shredding and dismantling

There are certain carveouts for materials that may be covered by a different Basel listing code, some of which may fall under Annex IX of the Convention (materials not covered by Basel controls). However, individual countries that are party to the Convention may choose to implement the E-Amendments differently and take different approaches to interpreting what falls in the bounds of recycled electrical and electronic materials.

Is the United States a Party to the Convention?
The United States is not a party to the Basel Convention. Because the Convention is an international treaty, it requires both the approval of the U.S. Senate and the legislative implementation of the obligations of the Convention into the U.S. statutory framework.  

The Bush-41 administration signed the agreement in 1990, and the Senate provided its “advice and consent” in 1992, but Congress never implemented the statutory obligations under the Convention and so the U.S. has never ratified the Convention.

As a result of the non-party status of the United States, U.S. traders in Basel-controlled materials have limited opportunities to legally trade these products abroad through side agreements under Article 11 of the Basel Convention.

What is Article 11 of the Basel Convention?
One key provision of the Basel Convention is Article 11, which allows parties to enter into agreements/arrangements with other countries (including non-parties) to govern trade of Basel-controlled materials, as long as the environmentally sound management of the materials is not weaker than those dictated by the Convention.

This provision allows non-parties, like the U.S., to trade in Basel-controlled recycled products, such as plastics and electrical/electronic products, with Basel parties, including many key trading partners. 

The most significant is the agreement related to materials destined for recovery among OECD member states (see below), but the U.S. has separate bilateral agreements with several countries, including Canada, that facilitate trade in these products and are crucial for the competitiveness of U.S. recycled materials exporters.

What is the OECD Council Decision?
The Organization for Economic Cooperation and Development (OECD), consists of 38 member states, primarily states considered developed countries, such as most of the European Union, United Kingdom, Canada, Japan, South Korea, Australia, New Zealand, Israel and Mexico. The OECD has its own Council Decision which acts as an Article 11 agreement among its member states and is the primary agreement that allows the U.S. to trade in Basel-controlled materials.

The OECD procedures for PIC are more streamlined and allow governments to pre-approve certain recovery facilities, which allow for smoother trade in Basel-controlled materials among member states.

Typically, the OECD will incorporate new Basel control measures into the Council Decision, but after more than a year of negotiations, member states failed to reach consensus. Thus, each member state can choose the extent to which it will incorporate the Basel or OECD control procedures into its regulations, which will impact whether countries will accept imports of recycled electrical and electronic materials from U.S. exporters.

Which Export Markets Can U.S. Exporters Send Material?
OECD member states will be the only option available for U.S. exporters of recycled electrical and electronic materials starting January 1, 2025. Countries that are outside the OECD should not accept these shipments, unless the government in the importing or transit country has negotiated a separate agreement with the U.S. government. To date, the U.S. has not entered into any new Article 11 arrangement with a non-OECD country to cover materials traded under the new E-Amendments.

The government of Canada recently announced that it would not impose strict PIC notifications and permits on recyclable electronics imported into Canada from OECD countries, like the United States, for recycling. This decision maintains the status quo for trading with Canada.

Additionally, the Japanese government has announced that it will not require PIC on imports of printed circuit boards and other electrical and electronic items. The competent authorities of several other countries, including those in the European Union, have outlined guidance about the necessary PIC procedures, but we will continue to compile formal guidance for ReMA members as it becomes available.

What’s Next?
Since the U.S. government does not regulate the export of most recycled electrical and electronic products as hazardous under U.S. law, it is critical that exporters work directly with the customer and the competent authority in the importing and/or transit country to determine the notification process and new rules that have been imposed. EPA expects most OECD countries to require PIC for shipments within the bloc, and no country has outright announced it will ban the shipments from non-parties, like the U.S.

Each OECD member state will determine whether it will require PIC notification or will use the old OECD codes for non-hazardous electronic materials. The OECD is expected in January to publish guidance for each member state as the governments finalize the regulations for trade in these products.

We will send this information out to ReMA members as it becomes available and are developing a tracking tool for ReMA members to help determine what rules will be in place for each OECD member state and countries with which the U.S. has an Article 11 agreement.

We will discuss the implementation of the E-Amendments at the next monthly meeting of the Electronics Division on Thursday, January 16, 2025, at 2:00pm EST.

The next in-person meeting of the Electronics Division will be held on Thursday, February 27, 2025 at 10:30am, in conjunction with the ReMA 2025 Winter Meeting at the Watergate Hotel in Washington, DC.

Additional Resources

• Basel Convention FAQs on “E-Waste Amendments”

• U.S. Environmental Protection Agency (EPA) guidance on new E-Amendments, including October webinar for regulated communities

For More Information
Please contact Adam Shaffer, ReMA AVP of International Trade and Global Affairs at 202-662-8532 or ashaffer@recycledmaterials.org.

• Beginning January 1, 2025, international trade in most recyclable and recycled electrical and electronic materials will be subject to the controls of the Basel Convention.
• The United States is not a party to the Basel Convention, so these new trade controls will significantly restrict the available export markets for U.S. exports of these products.
• Each country is responsible for implementing these new trade controls, so it is expected there will be disruptions that may not be resolved for weeks or even months.

Background
At the June 2022 Basel Convention Conference of Parties (COP-15), the parties (countries) to the Convention agreed to add new control measures governing the international trade of hazardous and non-hazardous “e-waste” and “e-scrap” materials. The entry into force of these new E-Amendments is January 1, 2025, and will subject shipments to prior informed consent (PIC) notifications, where exporters must obtain written consent from the importing country’s government that it will legally accept that shipment.

What is the Basel Convention?
The Basel Convention is a United Nations (UN) multilateral environmental treaty that controls international trade in primarily hazardous waste.

It was initially designed to reduce transboundary movement of hazardous waste products from the developed world to the developing world and to ensure environmentally sound management of these materials, but the scope of the Convention has increased in recent years and now controls trade in many recycled and recyclable products.

It does this by utilizing an expansive definition of waste subject to the controls of the Convention to include materials destined for recovery facilities. Many governments utilize similar definitions in their own national laws, which ignores the critical role recycled materials play in global manufacturing supply chains.

Currently, there are 191 parties to the Convention, but there is a party/non-party trade ban in effect that prohibits trade in Basel-controlled materials between parties and non-parties, unless there is a separate agreement in place that ensures stringent environmentally sound management of traded materials.

What Materials and Products are Covered by these Controls?
The Basel Convention has always controlled electronic materials that would be classified as hazardous or possessing hazardous characteristics, but the E-Amendments have created new classifications for both hazardous (A1181) and importantly for traders of recyclables, non-hazardous (Y49), electronic products. These new listings include three categories for hazardous and non-hazardous materials:

• Whole equipment
• Components, such as circuit boards, display devices, etc.
• Fractions that result from processing, such as shredding and dismantling

There are certain carveouts for materials that may be covered by a different Basel listing code, some of which may fall under Annex IX of the Convention (materials not covered by Basel controls). However, individual countries that are party to the Convention may choose to implement the E-Amendments differently and take different approaches to interpreting what falls in the bounds of recycled electrical and electronic materials.

Is the United States a Party to the Convention?
The United States is not a party to the Basel Convention. Because the Convention is an international treaty, it requires both the approval of the U.S. Senate and the legislative implementation of the obligations of the Convention into the U.S. statutory framework.  

The Bush-41 administration signed the agreement in 1990, and the Senate provided its “advice and consent” in 1992, but Congress never implemented the statutory obligations under the Convention and so the U.S. has never ratified the Convention.

As a result of the non-party status of the United States, U.S. traders in Basel-controlled materials have limited opportunities to legally trade these products abroad through side agreements under Article 11 of the Basel Convention.

What is Article 11 of the Basel Convention?
One key provision of the Basel Convention is Article 11, which allows parties to enter into agreements/arrangements with other countries (including non-parties) to govern trade of Basel-controlled materials, as long as the environmentally sound management of the materials is not weaker than those dictated by the Convention.

This provision allows non-parties, like the U.S., to trade in Basel-controlled recycled products, such as plastics and electrical/electronic products, with Basel parties, including many key trading partners. 

The most significant is the agreement related to materials destined for recovery among OECD member states (see below), but the U.S. has separate bilateral agreements with several countries, including Canada, that facilitate trade in these products and are crucial for the competitiveness of U.S. recycled materials exporters.

What is the OECD Council Decision?
The Organization for Economic Cooperation and Development (OECD), consists of 38 member states, primarily states considered developed countries, such as most of the European Union, United Kingdom, Canada, Japan, South Korea, Australia, New Zealand, Israel and Mexico. The OECD has its own Council Decision which acts as an Article 11 agreement among its member states and is the primary agreement that allows the U.S. to trade in Basel-controlled materials.

The OECD procedures for PIC are more streamlined and allow governments to pre-approve certain recovery facilities, which allow for smoother trade in Basel-controlled materials among member states.

Typically, the OECD will incorporate new Basel control measures into the Council Decision, but after more than a year of negotiations, member states failed to reach consensus. Thus, each member state can choose the extent to which it will incorporate the Basel or OECD control procedures into its regulations, which will impact whether countries will accept imports of recycled electrical and electronic materials from U.S. exporters.

Which Export Markets Can U.S. Exporters Send Material?
OECD member states will be the only option available for U.S. exporters of recycled electrical and electronic materials starting January 1, 2025. Countries that are outside the OECD should not accept these shipments, unless the government in the importing or transit country has negotiated a separate agreement with the U.S. government. To date, the U.S. has not entered into any new Article 11 arrangement with a non-OECD country to cover materials traded under the new E-Amendments.

The government of Canada recently announced that it would not impose strict PIC notifications and permits on recyclable electronics imported into Canada from OECD countries, like the United States, for recycling. This decision maintains the status quo for trading with Canada.

Additionally, the Japanese government has announced that it will not require PIC on imports of printed circuit boards and other electrical and electronic items. The competent authorities of several other countries, including those in the European Union, have outlined guidance about the necessary PIC procedures, but we will continue to compile formal guidance for ReMA members as it becomes available.

What’s Next?
Since the U.S. government does not regulate the export of most recycled electrical and electronic products as hazardous under U.S. law, it is critical that exporters work directly with the customer and the competent authority in the importing and/or transit country to determine the notification process and new rules that have been imposed. EPA expects most OECD countries to require PIC for shipments within the bloc, and no country has outright announced it will ban the shipments from non-parties, like the U.S.

Each OECD member state will determine whether it will require PIC notification or will use the old OECD codes for non-hazardous electronic materials. The OECD is expected in January to publish guidance for each member state as the governments finalize the regulations for trade in these products.

We will send this information out to ReMA members as it becomes available and are developing a tracking tool for ReMA members to help determine what rules will be in place for each OECD member state and countries with which the U.S. has an Article 11 agreement.

We will discuss the implementation of the E-Amendments at the next monthly meeting of the Electronics Division on Thursday, January 16, 2025, at 2:00pm EST.

The next in-person meeting of the Electronics Division will be held on Thursday, February 27, 2025 at 10:30am, in conjunction with the ReMA 2025 Winter Meeting at the Watergate Hotel in Washington, DC.

Additional Resources

• Basel Convention FAQs on “E-Waste Amendments”

• U.S. Environmental Protection Agency (EPA) guidance on new E-Amendments, including October webinar for regulated communities

For More Information
Please contact Adam Shaffer, ReMA AVP of International Trade and Global Affairs at 202-662-8532 or ashaffer@recycledmaterials.org.

• Beginning January 1, 2025, international trade in most recyclable and recycled electrical and electronic materials will be subject to the controls of the Basel Convention.
• The United States is not a party to the Basel Convention, so these new trade controls will significantly restrict the available export markets for U.S. exports of these products.
• Each country is responsible for implementing these new trade controls, so it is expected there will be disruptions that may not be resolved for weeks or even months.

Background
At the June 2022 Basel Convention Conference of Parties (COP-15), the parties (countries) to the Convention agreed to add new control measures governing the international trade of hazardous and non-hazardous “e-waste” and “e-scrap” materials. The entry into force of these new E-Amendments is January 1, 2025, and will subject shipments to prior informed consent (PIC) notifications, where exporters must obtain written consent from the importing country’s government that it will legally accept that shipment.

What is the Basel Convention?
The Basel Convention is a United Nations (UN) multilateral environmental treaty that controls international trade in primarily hazardous waste.

It was initially designed to reduce transboundary movement of hazardous waste products from the developed world to the developing world and to ensure environmentally sound management of these materials, but the scope of the Convention has increased in recent years and now controls trade in many recycled and recyclable products.

It does this by utilizing an expansive definition of waste subject to the controls of the Convention to include materials destined for recovery facilities. Many governments utilize similar definitions in their own national laws, which ignores the critical role recycled materials play in global manufacturing supply chains.

Currently, there are 191 parties to the Convention, but there is a party/non-party trade ban in effect that prohibits trade in Basel-controlled materials between parties and non-parties, unless there is a separate agreement in place that ensures stringent environmentally sound management of traded materials.

What Materials and Products are Covered by these Controls?
The Basel Convention has always controlled electronic materials that would be classified as hazardous or possessing hazardous characteristics, but the E-Amendments have created new classifications for both hazardous (A1181) and importantly for traders of recyclables, non-hazardous (Y49), electronic products. These new listings include three categories for hazardous and non-hazardous materials:

• Whole equipment
• Components, such as circuit boards, display devices, etc.
• Fractions that result from processing, such as shredding and dismantling

There are certain carveouts for materials that may be covered by a different Basel listing code, some of which may fall under Annex IX of the Convention (materials not covered by Basel controls). However, individual countries that are party to the Convention may choose to implement the E-Amendments differently and take different approaches to interpreting what falls in the bounds of recycled electrical and electronic materials.

Is the United States a Party to the Convention?
The United States is not a party to the Basel Convention. Because the Convention is an international treaty, it requires both the approval of the U.S. Senate and the legislative implementation of the obligations of the Convention into the U.S. statutory framework.  

The Bush-41 administration signed the agreement in 1990, and the Senate provided its “advice and consent” in 1992, but Congress never implemented the statutory obligations under the Convention and so the U.S. has never ratified the Convention.

As a result of the non-party status of the United States, U.S. traders in Basel-controlled materials have limited opportunities to legally trade these products abroad through side agreements under Article 11 of the Basel Convention.

What is Article 11 of the Basel Convention?
One key provision of the Basel Convention is Article 11, which allows parties to enter into agreements/arrangements with other countries (including non-parties) to govern trade of Basel-controlled materials, as long as the environmentally sound management of the materials is not weaker than those dictated by the Convention.

This provision allows non-parties, like the U.S., to trade in Basel-controlled recycled products, such as plastics and electrical/electronic products, with Basel parties, including many key trading partners. 

The most significant is the agreement related to materials destined for recovery among OECD member states (see below), but the U.S. has separate bilateral agreements with several countries, including Canada, that facilitate trade in these products and are crucial for the competitiveness of U.S. recycled materials exporters.

What is the OECD Council Decision?
The Organization for Economic Cooperation and Development (OECD), consists of 38 member states, primarily states considered developed countries, such as most of the European Union, United Kingdom, Canada, Japan, South Korea, Australia, New Zealand, Israel and Mexico. The OECD has its own Council Decision which acts as an Article 11 agreement among its member states and is the primary agreement that allows the U.S. to trade in Basel-controlled materials.

The OECD procedures for PIC are more streamlined and allow governments to pre-approve certain recovery facilities, which allow for smoother trade in Basel-controlled materials among member states.

Typically, the OECD will incorporate new Basel control measures into the Council Decision, but after more than a year of negotiations, member states failed to reach consensus. Thus, each member state can choose the extent to which it will incorporate the Basel or OECD control procedures into its regulations, which will impact whether countries will accept imports of recycled electrical and electronic materials from U.S. exporters.

Which Export Markets Can U.S. Exporters Send Material?
OECD member states will be the only option available for U.S. exporters of recycled electrical and electronic materials starting January 1, 2025. Countries that are outside the OECD should not accept these shipments, unless the government in the importing or transit country has negotiated a separate agreement with the U.S. government. To date, the U.S. has not entered into any new Article 11 arrangement with a non-OECD country to cover materials traded under the new E-Amendments.

The government of Canada recently announced that it would not impose strict PIC notifications and permits on recyclable electronics imported into Canada from OECD countries, like the United States, for recycling. This decision maintains the status quo for trading with Canada.

Additionally, the Japanese government has announced that it will not require PIC on imports of printed circuit boards and other electrical and electronic items. The competent authorities of several other countries, including those in the European Union, have outlined guidance about the necessary PIC procedures, but we will continue to compile formal guidance for ReMA members as it becomes available.

What’s Next?
Since the U.S. government does not regulate the export of most recycled electrical and electronic products as hazardous under U.S. law, it is critical that exporters work directly with the customer and the competent authority in the importing and/or transit country to determine the notification process and new rules that have been imposed. EPA expects most OECD countries to require PIC for shipments within the bloc, and no country has outright announced it will ban the shipments from non-parties, like the U.S.

Each OECD member state will determine whether it will require PIC notification or will use the old OECD codes for non-hazardous electronic materials. The OECD is expected in January to publish guidance for each member state as the governments finalize the regulations for trade in these products.

We will send this information out to ReMA members as it becomes available and are developing a tracking tool for ReMA members to help determine what rules will be in place for each OECD member state and countries with which the U.S. has an Article 11 agreement.

We will discuss the implementation of the E-Amendments at the next monthly meeting of the Electronics Division on Thursday, January 16, 2025, at 2:00pm EST.

The next in-person meeting of the Electronics Division will be held on Thursday, February 27, 2025 at 10:30am, in conjunction with the ReMA 2025 Winter Meeting at the Watergate Hotel in Washington, DC.

Additional Resources

• Basel Convention FAQs on “E-Waste Amendments”

• U.S. Environmental Protection Agency (EPA) guidance on new E-Amendments, including October webinar for regulated communities

For More Information
Please contact Adam Shaffer, ReMA AVP of International Trade and Global Affairs at 202-662-8532 or ashaffer@recycledmaterials.org.