Is Technically Not Imported "E-Waste" Still Exported "eWaste?"

The term "competent authority" sounds so good.  But is it too good to be true?

What if you took a trip to Cancun, and when you came back home, an environmental agent (or other authority without expertise in Immigration and Naturalization) said that you had not vacationed, but had emigrated and were no longer a citizen?

In the world of contract manufacturing, assembly, piece work, and repair, the terms "import" and "export" are not thrown around lightly. There are many commerce treaties involved, and sometimes a device is more of a tourist than an immigrant.    The discussion of "export rules" begs the question, if someone thinks they are the authority, and their national courts say they are not, then how competent are they?

In Mexico, the Ibarrolas (customs agents) must document that loads brought into the "maquila" zone have not been imported.  The maquilas were set up to bring assembly jobs for televisions and automobiles, creating employment for Mexicans in the border area.   Ford makes car parts, sends them to a Ford plant in Mexico, and the screws are affixed and the car is brought back for sale in the USA.  Nothing remains in Mexico, Mexico does not collect customs on any parts or cars, and the USA Commerce Department does not consider the car parts to have been exported and Mexico does not consider them to have been imported.

China has "special economic zones", and the island of Macau in Chinese waters is an entire small economy based on "not importing" into China.

Now there is a company in India, Intarvo, which has created "refurbishing" factories for electronics.  India is notorious for not allowing import of used equipment, and famous for its brilliant young techs who can fix anything with a cord.   Intarvo has set up facilities to bring in used electronics without "importing" the e-scrap.  They repair what they can, but cannot keep it in India... it has to leave the country.

Personally I think this is a lot of work to create recycling and repair facilities in places which have the knowledge and skill to recycle and repair used electronics.  But when I asked an EPA person whether this is "exporting" (in the case of our Mexico facility, which ships all the screws and plastic and CRTs back into Arizona for processing after testing and disassembly), the person said "of course it's exporting if it leaves the country".

What I'm pointing out is that you can split out the two issues - primitive polluting shameful practices and technically adept refurbishing - and not even get to the definition of import and export at all.

Even Radiohead (the rock band) knows what a "Maquiladora" is.  My point is that a group of people gets together to figure out what the rules should be for "ewaste exports", and they don't even bring in a representative from Commerce, they don't bring in anyone from an importing country, and they start to make rules based on what a small non-profit says that the Basel Convention says...  And I'm not complaining or trying to be mean.  It's kind of funny, if you aren't being clubbed to death.

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