2025 Basel E-Waste Changes

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On January 1, 2025, the Basel Convention implemented significant changes to e-waste classifications, deleting two widely-used codes and fundamentally altering international e-waste trade procedures.

What Changed

DELETED CODES (Invalid as of January 1, 2025):

B1110:Electrical and electronic assemblies

• Previously covered: Circuit boards, electronic components, assemblies
• Classification: Non-hazardous, did not require PIC in OECD trade
• Deleted because: Inconsistent interpretation, frequent misclassification of hazardous e-waste

B4030:Assembled electronic equipment

• Previously covered: Whole units including computers, monitors, phones
• Classification: Non-hazardous, did not require PIC in OECD trade
• Deleted because: Abused for illegal hazardous waste shipments disguised as functional equipment

NEW CLASSIFICATIONS (Effective January 1, 2025):

Y49:Electrical and electronic waste not covered elsewhere

• Covers: E-waste that does not exhibit Annex III hazardous characteristics
• Listed in:Basel Annex II(controlled non-hazardous waste)
• PIC required:YES - Full notification procedure required even though non-hazardous
• Key change: Even clean e-waste now requires Prior Informed Consent

A1181:Waste electrical and electronic assemblies or scrap containing hazardous components

• Covers: E-waste containing Annex I constituents or exhibiting Annex III characteristics
• Listed in:Basel Annex VIII(hazardous waste)
• PIC required: YES - Full notification procedure with hazardous waste requirements
• Key change: Most e-waste falls into this category due to lead solder, BFRs, or heavy metals

Impact on E-Waste Trade

BEFORE JANUARY 1, 2025:

• B1110 and B4030 shipments between OECD countries: No PIC required
• Simple customs declaration sufficient for non-hazardous e-waste
• Large volume of circuit boards and whole units traded as B1110 or B4030
• Minimal documentation and testing requirements

AFTER JANUARY 1, 2025:

• ALL e-waste requires PIC procedure (Y49 or A1181)
• Full Basel notification package required even for non-hazardous waste
• Detailed waste characterization mandatory
• 60-day competent authority review period versus immediate shipment under B codes
• Significantly increased compliance costs and timeline

Transition Period

NOTIFICATIONS APPROVED BEFORE JANUARY 1, 2025:

• Remain valid until expiration date (typically 12 months from approval)
• Can continue shipping under B1110 or B4030 until notification expires
• No need to re-classify mid-year shipments

NOTIFICATIONS SUBMITTED BEFORE JANUARY 1, 2025 BUT NOT YET APPROVED:

• Some competent authorities honored pre-2025 submissions
• Others required re-submission under Y49 or A1181
• Check with specific competent authority for their policy

NEW NOTIFICATIONS SUBMITTED AFTER JANUARY 1, 2025:

• MUST use Y49 or A1181
• B1110 and B4030 will be rejected
• No exceptions or grace period

How to Transition Existing Waste Streams

STEP 1: REVIEW CURRENT CLASSIFICATIONS

• Identify all active notifications using B1110 or B4030
• Note expiration dates
• Determine if waste is genuinely non-hazardous (Y49) or should be A1181

STEP 2: RE-CHARACTERIZE WASTE

• Conduct testing or obtain manufacturer certifications
• Identify all Annex I constituents including lead, mercury, cadmium, BFRs
• Assign H-codes for hazardous waste (seeHazardous Characteristics Assessment)
• Document methodology for Y49 versus A1181 determination

STEP 3: PREPARE NEW NOTIFICATIONS

• Submit 90-120 days before current notification expires
• Use Y49 or A1181 based on characterization
• Include additional documentation now required such as waste analysis and ESM demonstration
• Budget for longer approval timeline (60-90 days versus immediate under B codes)

STEP 4: ADJUST BUSINESS OPERATIONS

• Account for 3-4 month lead time instead of immediate shipment
• Increased compliance costs including testing, documentation, notification fees
• Potential facility upgrades if moving from B1110 to A1181 (hazardous waste permits)
• Carrier changes if A1181 requires dangerous goods certification

Country-Specific Implementation

OECD COUNTRIES:

• Previously allowed B1110 and B4030 without PIC under OECD Decision
• Now require full notification for all e-waste
• Tacit consent still available for Y49 in some OECD bilateral agreements (30 days versus 60)
• A1181 always requires written consent

NON-OECD COUNTRIES:

• Always required PIC for B1110 and B4030, so less operational change
• Main impact: Need to reclassify as Y49 or A1181
• Some countries including Malaysia, Thailand, India issued updated guidance on Y49 and A1181

COUNTRIES WITH E-WASTE IMPORT BANS:

• China banned all e-waste imports (no change from 2025 amendments)
• Vietnam restricted A1181 imports (check current policy)
• Some countries used 2025 changes to implement new restrictions

Common Transition Errors

• Continuing to use B1110 or B4030 in 2025 notifications (immediate rejection)
• Assuming Y49 is equivalent to B1110 when Y49 requires full PIC while B1110 did not
• Not budgeting adequate time for first Y49 or A1181 notification approval
• Failing to upgrade facility permits from non-hazardous to hazardous when moving to A1181
• Not updating carrier contracts for dangerous goods requirements (A1181)

Practical Guidance

FOR EXPORTERS:

• Start new notification process 4-6 months before needed
• Budget 2-3 times more for compliance costs versus B1110 and B4030 era
• Establish testing protocols for waste characterization
• Consider segregating obviously hazardous components such as CRTs and batteries to potentially keep some streams as Y49

FOR FACILITIES:

• Verify permits cover Y49 and A1181 as appropriate
• Upgrade to hazardous waste permit if receiving A1181
• Update ESM documentation to address new classifications
• Train staff on identifying hazardous characteristics

FOR BROKERS AND TRADERS:

• Educate clients on timeline changes (no more immediate shipment)
• Adjust pricing to reflect increased compliance costs
• Establish relationships with testing laboratories
• Maintain detailed records showing Y49 versus A1181 determination methodology

For guidance on completing notifications under the new classifications, see ourBasel Form GuideandY49 vs A1181 Classification Guide.

References

• Basel Convention Technical Guidelines on E-Waste (2024 Update)
• Basel Convention Amendments
• OECD Decision C(2001)107/FINAL

COP-17 update: Annex IV and e-waste guidelines

COP-17 was held from 28 April to 9 May 2025 and adopted 28 Basel Convention decisions. Operators should treat those decisions as the current reference point when preparing Basel Convention files for transboundary movements.

BC-17/15 adopted a replacement Annex IV. The update is scheduled to become effective on 1 January 2030, following depositary communication on 1 July 2029. Until national implementation is confirmed, use current domestic rules but plan workflows, contracts, and recovery/disposal references for the 2030 Annex IV replacement.

BC-17/4 adopted new technical guidelines on transboundary movements of e-waste and used electrical and electronic equipment (EEE). For e-waste and used EEE movements, reference these COP-17 guidelines when preparing classification, PIC, ESM, and supporting documentation.

Practical operator note: for 2025–2029 files, record which Basel decision basis is being used, confirm competent-authority expectations, and revisit Annex IV and e-waste assumptions before shipment approval or renewal.