ENStarting point
Assessment of an international pathway begins with characterisation and classification of the material, followed by verification of origin, transit and destination requirements. Commercial acceptance does not replace applicable authorisations and consents, or demonstrate that the receiving facility will perform the intended operation.
What changed in electrical and electronic waste controls
The Basel Convention's e-waste amendments entered into force on 1 January 2025. They expanded controls on transboundary movements, with entry A1181 covering hazardous electrical and electronic waste within its description, and Y49 covering other electrical and electronic waste within its scope, subject to the prior informed consent procedure, known as PIC. [1]
The descriptions also cover components and certain processing fractions, according to the terms of the entries. The Convention's FAQ identifies the exception for Parties that notified non-acceptance of the amendments within the prescribed period. [1] Therefore, beyond a general reading, the status of the countries and applicability to the specific material and pathway need confirmation. The term “non-hazardous scrap” is not enough to conclude that the movement is free from controls.
Distinguish used equipment, waste and processed fractions
The commercial name used in a proposal does not determine classification. A batch advertised as equipment for reuse needs appropriate evidence of its condition and intended purpose. A collection of parts with no demonstrated function does not become a product simply because it will have economic value at the destination. Likewise, shredding or separating waste does not automatically eliminate applicable controls.
Prepare a technical description covering origin, composition, physical state, intended function and destination operation. Include reports or tests where relevant to the assessment. Classification should be carried out by the competent responsible parties, considering the rules of the countries involved. If interpretations at origin and destination differ, resolve the difference before final contracting and shipment, retaining a record of enquiries and responses.
Confirm Ibama's role and the pathway's requirements
Ibama identifies itself as the Brazilian competent authority for authorising exports of hazardous or controlled waste under the Convention. Its export guidance brings together information on classification and applications, including references to the changes for electrical and electronic equipment. [2] The federal service describes the application and processing steps related to consent and authorisation for the movement. [3]
Consult current guidance when planning the operation and confirm export, import and transit requirements. Applicability depends on the waste, countries and conditions. Do not assume one authority's acceptance automatically resolves every stage, or that documentation used in a previous shipment remains sufficient for a new pathway. Specific prohibitions or restrictions need examination before forecasting revenue and timing.
Assess the receiving party by the operation it will perform
Identify the physical facility, operator and intended activity. Distinguish the commercial buyer from the treatment facility. Check material compatibility, capacity and the evidence needed to monitor receipt and processing. Where intermediaries are involved, describe each one's role and who will be responsible for incorrect information, load discrepancies or changes in destination.
The commercial assessment should consider verifiable history, receiving conditions, sampling, refusal criteria and settlement method. A high price may depend on quality assumptions the batch does not meet. Connect the technical description sent to the buyer with the description used in the authorisation process and movement documents, so the parties are not contracting for different loads on paper.
Build a single dossier for the batch and movement
Organise documents by version, owner and relationship to the shipment. Together, they should identify the material, parties involved, transport, destination and approved conditions. The actual list of documents and forms must be confirmed in official guidance and by those responsible for the operation; an editorial table does not replace that review.
As an internal control, use a consistency matrix. Compare codes and descriptions, masses, packaging, dates, the destination facility and party identification. Record which information remains preliminary and which already corresponds to the shipment. A later change may require reassessment or updates to applicable procedures; do not substitute pathways simply because the new buyer offers the same commercial terms.
Suggested internal control, without replacing official documentation
Block
- Material
- Verification question
Are origin, composition and description consistent?
- Parties
- Verification question
Are the buyer, operator and facility identified?
- Movement
- Verification question
Do the pathway and carriers match the plan?
- Conditions
- Verification question
Are applicable authorisations and consents satisfied?
- Close-out
- Verification question
Who will demonstrate receipt and the operation at destination?
Compare the economic result with explicit contingencies
The assessment should consider freight, handling, preparation, analyses, documentary expenses, storage, relevant insurance, weighing differences and payment terms. Compare proposals at the same delivery point and with the same distribution of responsibilities. A quotation per tonne alone does not show how much will remain for the seller or who will bear an incident during the journey.
A hypothetical example: a 20 t shipment has illustrative contractual gross revenue of R$ 80,000 and expected costs of R$ 28,000 within the scope considered. Preliminary contribution is R$ 52,000, before items excluded from the calculation. If a hold adds R$ 12,000 in costs, it falls to R$ 40,000. The example demonstrates sensitivity, without estimating actual prices, taxes or timelines and without assuming the pathway is authorised.
Define discrepancy handling before shipping
Agree on how differences in mass, composition and load condition will be addressed. Specify responsibilities for communication, sample preservation, discrepancy analysis and legally admissible next steps. Refusal or inability to complete the operation requires coordinated action by the parties and competent authorities as appropriate; it should not be resolved through improvised rerouting.
Commercial scheduling should allow time for documentary stages and confirmation of necessary conditions. Do not promise a definitive shipment date while it depends on unresolved decisions. Monitoring needs to indicate the actual status of each requirement and who will resolve the outstanding issue. This allows an assessment of whether to retain, revise or abandon the international alternative before increasing financial exposure.
Close out the chain and preserve evidence
Delivery to the carrier or departure from the country does not in itself demonstrate the agreed final treatment. Define the receipt, weighing, operation and close-out records that must return to origin, respecting applicable procedures. Reconcile discrepancies and maintain access to final versions. The quality of close-out should influence the decision on further shipments.
The assessment of partners and the chain and the materials brokerage need to use the same description of the batch and destination. This guide organises questions for technical and documentary analysis; classification and authorisations are specific to the operation. An international pathway becomes a concrete alternative only when the market, execution and applicable requirements converge in a demonstrable flow.
Sources and references
References accessed on 5 October 2026. The numbering in the text indicates the concepts supported by each source.
- Secretariat of the Basel Convention. E-waste Amendments FAQs — Entry into force, entries A1181 and Y49, and prior informed consent.
- Ibama. Waste exports — Basel Convention. Guidance from the Brazilian competent authority.
- Federal Government / Ibama. Obtain authorisation to export waste controlled by the Basel Convention. Service and application stages.
Circuvia corporate content to support project discussions. Methods, acceptance criteria and applicable requirements are defined within the scope of each operation.
