What changed for e-scrap exports after the Basel amendments?
Consent moved to the front of the shipment. Since January 1 2025, international shipments of e-waste and scrap, hazardous and non-hazardous, move only with the prior written consent of the importing country (EPA).
The consent belongs to the importing country. The answer is therefore different country by country.
Consent before the container moves
The United States is not a party to the Basel Convention. EPA says "some countries may not allow trade in certain Basel-controlled e-waste with the United States" (EPA).
For a recycler, the practical change is one of sequence. The destination's answer is established before a load is committed rather than after it is booked.
Cathode ray tubes carry their own step
Exports of cathode ray tubes for recycling need a notice to EPA and an Acknowledgement of Consent before shipment (40 CFR 261.39).
That is a named document with a named recipient. The sorting record and the shipping record have to describe the same material.
What a written scrap export procedure produces
The procedure produces a file. Ours names the following.
- Who classifies the material as scrap, recovery or reuse, and on what evidence.
- Which country the material is destined for, and what its consent position is.
- Who obtains the prior written consent and where it is filed.
- When a cathode ray tube notice goes to EPA, and who holds the Acknowledgement of Consent.
- What is photographed and weighed before the container is sealed.
- Where the whole file lives afterwards.
The same procedure sits inside the wider program. An R2v3 facility already runs a transboundary shipment check under Appendix A and keeps a legal compliance plan under Core Requirement 4. The scrap export procedure is written into both rather than beside them.
What the Basel Action Network reported
The Basel Action Network published "Brokers of Shame" on October 22 2025. The network's finding, in its own words, was that "Eight out of the ten identified brokers hold R2V3 Certifications" (Basel Action Network).
For a recycler, the record that answers a question about a shipment is the one attached to that container.
The scrap export procedure is one element of the export compliance program. To have one written or reviewed, use the form at /practice-inquiry.
Questions
Does this apply to non-hazardous scrap as well?
Yes. Since January 1 2025, international shipments of e-waste and scrap, hazardous and non-hazardous, move only with the prior written consent of the importing country (EPA).
The United States never ratified Basel. Does that help?
The United States is not a party to the Basel Convention. EPA says "some countries may not allow trade in certain Basel-controlled e-waste with the United States."
What do cathode ray tubes need?
A notice to EPA and an Acknowledgement of Consent before shipment, under 40 CFR 261.39.
We are R2v3 certified. Is our transboundary check enough?
Your Appendix A check is the place this work belongs. What we write is the export-side procedure that fills it, along with the legal compliance plan you keep under Core Requirement 4.
Does whole working equipment count as scrap?
That is the classification question the procedure answers first. It names who decides, on what evidence, and what is recorded for the file.
Can you get consent for us?
No. We do not represent a company before a government agency. We write the procedure, name the owner of each step and review the file that comes out of it. For inventory that is being sold rather than recycled, see sell-through on commission.
Start an inquiry We reply within two working days, with a quote or with the questions we need answered first.