BIR published on 30 October 2026 its write-up of the Electronics Committee plenary held in Malaga on 26 October, during the World Recycling Convention. The session, chaired from Pan American Zinc, recorded growing demand for critical materials recovered from electronics and said inconsistent waste classifications still block international trade.
The same convention already sits on this site for the India free-trade argument, African ferrous offtake and brass export barriers. The electronics file is a coding and consent problem for a prepared fraction. The Commission’s 21 November metal-waste list is a separate decision. See the India FTA briefing.
What A1181 and Y49 do to a metal shipment
BIR’s Senior Trade and Environment Policy Officer told delegates that end-of-life electronics have been under the Basel Convention’s prior informed consent procedure since January 2025, under two new entries: A1181 and Y49. The Basel Secretariat’s FAQ uses the same start date. A1181 covers hazardous e-waste, components and processing residues. Y49 covers other covered e-waste, components and processing residues that do not sit in A1181. Both can require written consent from the importing state, and from transit states where that applies, before a transboundary movement starts.
Two problems have shown up in the yard book, BIR said. It is often unclear which materials the entries cover. Classification frequently follows the origin of the material, not only its analysis. Components taken out of electronic equipment, and fractions from their processing, are now classed as electronics because of where they came from. Official guidance was described as inadequate. BIR said recycled-metal shipments have been, and still are, rejected by customs as misclassified.
After BIR advocacy, Basel Convention staff are writing a guidance document that could be adopted at COP 18 in April 2027. The Malaga update used printed circuit boards, liquid crystal displays and electric motors, before and after shredding, as examples of that work. On shredded motors, the talks had clarified that metal fractions from shredded motors, and Zorba and Tense, do not need to be 100 percent pure to stay classified as metals. Zorba and Tense are already named on this site. See ISRI scrap codes and aluminium scrap.
A question from the chair asked whether an incidental circuit-board fragment in a recycled-metal container should turn the whole cargo into electronic or hazardous waste. The US environmental-law briefing at the session said that would probably not be an issue in the United States and that it has become a large issue in other countries.
Black mass as the worked example
The same briefing used black mass from lithium-ion battery recycling to show how one Basel framework is applied differently. BIR recorded the powder as generally viewed as a waste under the Convention, with the hazardous question left unclear across annexes. The working conclusion at the session was that black mass is probably not a controlled waste, with room for debate, including from NGOs.
BIR then recorded a country split. India treats black mass as hazardous waste in all cases. Tests used in the United States and Mexico would likely make the same material non-hazardous. Tests used in the United Kingdom and Brazil would classify it as hazardous. China and South Korea treat it as not a waste when it meets set specifications.
The briefing tied those choices to industrial policy. Countries with spare refining capacity, China and South Korea among them, are more likely to treat the material as non-waste or non-hazardous so it can enter. Countries building domestic capacity, the European Union and India among them, are more likely to treat it as hazardous and restrict outbound movements. A third group generates little black mass and is unlikely to build refining soon; those countries may use a non-waste or non-hazardous reading to keep a trading book.
The session said a seller may need to state the source: used batteries, battery manufacturing scrap, electric vehicles or electronics, and the cell chemistry. For US exporters, the US Department of Commerce has prohibited exports of black mass and recovered tungsten unless a licence is in place. BIR recorded that the present rule applies only to certain product codes, that black mass is commonly shipped under other codes, and that the Department has indicated it is likely to extend the rule to those codes and may later cover lithium-ion batteries and possibly rare earth magnets. That US licence file is separate from the EU’s magnet-scrap mandate. See Parliament’s CRMA magnet-scrap clause.
ReMA’s chief economist told the session that the installed stock of electronics, from household appliances through data-centre and power-infrastructure build, will need maintenance and replacement, and that access to established commodity markets still matters when policy restricts that access.
Who it affects among yards, traders, mills and processors
European WEEE plants that produce a non-ferrous shred after authorised treatment already have an intra-EU offtake at Atlantic Copper’s CirCular line in Huelva, which takes pre-processed WEEE non-ferrous shreds. A waste-classified shred that stays inside the Union is not decided by the 21 November non-OECD metal column. A cargo that leaves the Union still needs the Basel code, the consent papers if A1181 or Y49 apply, and a destination that will accept that reading. See the Huelva briefing and OECD and non-OECD shipment rules.
German treatment plants sitting on EUWID’s 28 October survey, intake prices unchanged since July because copper and ferrous credits have covered extra diesel, freight and labour, with white-goods arisings often good and a summer surge in cooling appliances, still have to sell the metal fraction. A Zorba or Tense bag with a circuit-board fragment is the Malaga question on the floor. Keep boards, batteries and motors on their own tickets. An end-of-waste claim still needs the specification and the documents.
Traders booking shredded motors, Zorba or Tense toward a non-EU remelter should write the metal specification and the processing history. BIR said customs have already stopped recycled-metal containers as mis-declared electronics. Thailand’s October proposal to open every metal-scrap container for e-waste sits on the same file. See Thai Customs.
Battery recyclers and traders offering black mass into or out of the EU need the source, the chemistry and the receiving country’s current reading before they book freight. An Indian hazardous-waste notification is a different contract from a Korean specification that treats the same powder as a non-waste. Do not price a black-mass stem off Huelva or off a Berry wire bid. See copper scrap.
Copper refiners and aluminium remelters buying Berry, Birch, Tense or Taldon are not the buyer for a mixed e-scrap collection or for black mass. Dutch CRMA recyclers named in October take low-grade aluminium, copper, battery and circuit-board streams; those plants have their own intake rules. See the Dutch CRMA list.
How to name the lot
If the material is clean copper wire or solids, name the grade already used here: Barley, Berry, Birch, Candy or Cliff. If it is shredded non-ferrous from a fragmentiser, write Zorba. If it is mixed aluminium castings, write Tense. If it is a pre-processed WEEE non-ferrous shred for a smelter, write the stream, authorised-treatment status, an assay if measured, grain size or packing, city or works, and whether the sale is ex-works or delivered.
If it is black mass, write that word, the cell chemistry, whether the feed was used cells, production scrap, EV packs or electronics, moisture and packing, city, and whether the seller is offering it as a specified non-waste or as a waste movement under prior informed consent. Do not call black mass Zorba. Do not call a mixed appliance load Berry. Do not write A1181, Y49 or a recycled-content percentage on the offer as if they were a grade.
State tonnes and the intended works or destination country. An intra-EU Huelva shred, a Zorba export and a black-mass stem are different contracts.
Verified companies can list on live lots or post a wanted enquiry. Request access if you have a prepared WEEE fraction, a Zorba or Tense parcel, or a black-mass programme to cover.