U.S. Department of Commerce Seeks Comment on Prohibiting Export of Electronic Waste Responses due by December 24, 2018

The Bureau of Industry and Security (BIS) within the U.S. Department of Commerce is seeking public comment on prohibiting the export of “electronic waste.”  Comments are being sought on:  the definition of electronic waste, prohibition exemptions, identifying means of disposal if the waste cannot be exported and implementation of recordkeeping and tracking requirements.
BIS is inviting comment on the definition of electronic waste, as well as any alternative definition.  Waste that could be exempt from the export prohibition could include consumer appliances with electronic features; electronic parts of motor vehicles; tested and working used electronics and recalled electronics.
Two approaches for the reporting of exempted electronic waste are being considered.  One approach would be a new export license while the other would be a new data element in the Automated Export System (AES).
Finally, the Federal government is seeking comments on the prevalence of counterfeit components in the electronic supply chain and whether the changes contemplated would alleviate the problem.
This initiative represents recognition that exported electronic waste is typically harvested for electronic components.  These harvested parts are often the source of counterfeit parts.

The deadline for submitting comments is December 24, 2018.  The full text of the BIS announcement may be found at https://www.federalregister.gov/documents/2018/10/23/2018-23044/request-for-public-comments-regarding-foreign-disposition-of-certain-commodities 

x Brown