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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

Section: E-Waste · Type: guide