DexMetal

Component-Level Classification

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Understanding when to classify e-waste at the component level versus whole assembly level is critical for accurate Basel notification. Segregated components may qualify for different classifications than intact assemblies.

When Component-Level Classification Applies

SEGREGATED COMPONENTS:

  • Circuit boards removed from housings and shipped separately
  • Cables and wiring sorted by type (copper, aluminum, fiber optic)
  • Plastic housings separated from internal components
  • Metal chassis and frames sorted by metal type
  • Power supplies removed and consolidated
  • Hard drives or storage media segregated for destruction

WHOLE ASSEMBLY CLASSIFICATION:

  • Complete equipment units shipped intact
  • Partially disassembled equipment with hazardous components still attached
  • Mixed containers of various equipment types
  • Equipment where disassembly is not economically feasible

Circuit Board Classification

HIGH-GRADE BOARDS (Typically A1181):

  • Motherboards from computers and servers
  • Graphics cards and video cards
  • Network interface cards
  • Memory modules (RAM, ROM)
  • CPU boards with processors attached

CLASSIFICATION FACTORS:

  • Lead solder presence (pre-2006 boards almost always contain lead)
  • Precious metal content (gold, silver, palladium in connectors and traces)
  • Component density (higher density typically means more valuable but also more hazardous)
  • Brominated flame retardants in board substrate

TYPICAL H-CODES FOR CIRCUIT BOARDS:

  • H6.1: Lead in solder (most common)
  • H11: Chronic toxicity from lead and BFRs
  • H12: Ecotoxic due to heavy metal content
  • H13: Can yield hazardous substances through leaching

SeeCircuit Board Classificationfor detailed guidance on PCB types.

Metal Component Classification

FERROUS METALS (Often Y49 if clean):

  • Steel chassis from computers and appliances
  • Iron frames and structural components
  • Magnetic shielding materials

NON-FERROUS METALS (Often Y49 if segregated):

  • Aluminum heat sinks and housings
  • Copper wiring and cables (without lead coating)
  • Brass components and connectors

CONTAMINATION CONCERNS:

  • Lead coating on copper wire (triggers A1181)
  • Cadmium plating on steel (triggers A1181)
  • Mercury switches still attached to metal frames (triggers A1181)
  • Circuit board fragments mixed with metal scrap (triggers A1181)

SEGREGATION REQUIREMENTS:For metal components to qualify as Y49, they must be visibly free of hazardous attachments including circuit boards, batteries, mercury switches, and capacitors.

Plastic Component Classification

PLASTIC TYPES IN E-WASTE:

  • ABS (Acrylonitrile Butadiene Styrene) - common in housings
  • HIPS (High Impact Polystyrene) - monitors and TV cases
  • PC (Polycarbonate) - optical drives, protective covers
  • PP (Polypropylene) - cables, connectors
  • PVC (Polyvinyl Chloride) - cable insulation

BROMINATED FLAME RETARDANTS (BFRs):

  • Common in plastics from pre-2008 equipment
  • Threshold: 1000 ppm triggers hazardous classification
  • Testing: XRF screening or laboratory analysis required for verification
  • If BFR content exceeds threshold: Classify as A1181 with H11, H12, H13

CLEAN PLASTIC CLASSIFICATION (Y49):

  • Post-2008 RoHS-compliant equipment housings
  • Laboratory verification showing BFR content below 1000 ppm
  • No metal inserts, circuit board fragments, or other attachments
  • Sorted by plastic type for optimal recycling

Cable and Wiring Classification

COPPER CABLES (Often Y49):

  • Category 5/6 network cables
  • Power cords without lead coating
  • Internal copper wiring from equipment

FIBER OPTIC CABLES (Y49):

  • Glass fiber core with plastic sheathing
  • No heavy metal content if properly segregated

HAZARDOUS CABLE TYPES (A1181):

  • Lead-coated copper wire (common in older equipment)
  • Cables with PVC insulation containing lead stabilizers
  • Cables still attached to connectors with lead solder
  • Armored cables with cadmium plating

Power Supply Classification

POWER SUPPLIES (Typically A1181):

  • Contain circuit boards with lead solder
  • Electrolytic capacitors with liquid electrolyte (H3)
  • Transformers with copper windings
  • Metal housing with attached circuit boards

CANNOT CLASSIFY AS Y49 unless:

  • Completely disassembled with circuit boards removed
  • Only metal housing and transformer core remaining
  • All capacitors and electronic components separated

Battery Component Rules

BATTERIES REQUIRE SEPARATE CLASSIFICATION:

  • Lithium-ion batteries: A1181 with H1, H3, H6.1, H12
  • Lead-acid batteries: A1181 with H6.1, H8, H12, H13
  • NiCad batteries: A1181 with H6.1, H11, H12
  • Alkaline batteries: May qualify as Y49 depending on jurisdiction

EQUIPMENT WITH BATTERIES ATTACHED:If batteries remain in equipment, the entire assembly must be classified as A1181 even if other components would qualify as Y49.

SeeBattery and Power Component Rulesfor detailed battery classification guidance.

When to Use Assembly-Level Classification

USE WHOLE ASSEMBLY CLASSIFICATION when:

  • Equipment contains multiple component types that cannot be economically segregated
  • Hazardous components are integrated and cannot be easily removed
  • Mixed equipment types in same shipment (laptops, monitors, peripherals)
  • Customer requires intact equipment for data destruction or refurbishment assessment

WORST-CASE CLASSIFICATION PRINCIPLE:When classifying mixed or intact assemblies, use the most hazardous component to determine overall classification. Example: Laptop with lead-free motherboard but lithium battery still attached = A1181 due to battery.

Segregation Best Practices

TO MAXIMIZE Y49 CLASSIFICATION:

  • Remove all batteries before export
  • Separate circuit boards from metal housings
  • Remove mercury-containing components (switches, backlights)
  • Segregate CRT glass from other materials
  • Sort plastics by type and test for BFR content
  • Remove lead-coated components from otherwise clean metal

ECONOMIC CONSIDERATIONS:

  • Segregation labor costs versus classification benefits
  • Market value differences between Y49 and A1181 materials
  • Transportation cost differences (hazardous versus non-hazardous)
  • Facility permit requirements for processing A1181 versus Y49

Documentation Requirements

FOR COMPONENT-LEVEL NOTIFICATIONS:

  • Detailed component inventory by type and weight
  • Segregation methodology description
  • Photographs showing segregated material streams
  • Testing results for each component category
  • Quality control procedures to prevent cross-contamination

When completingBlock 13: Physical CharacteristicsandBlock 16: Composition and Properties, specify whether classification applies to segregated components or whole assemblies.

Common Errors

  • Classifying circuit boards as Y49 when still attached to metal housings with boards containing lead solder
  • Not accounting for BFRs in plastic components
  • Assuming all copper wire is Y49 without checking for lead coating
  • Failing to document segregation procedures in notification
  • Mixing component types that should be classified separately

References

Section: E-Waste · Type: guide