21 August 2020

EU rules for waste shipping need to be more restrictive – ECOS policy contribution

ECOS calls for tighter European rules for waste trade as part of our response to a public consultation opened by the European Commission. A proposal for a review of the EU waste shipment regulation is expected in the coming months, with the potential for topping up rules to encourage re-use and recycling.

Used metal, paper, plastics… Every year, waste management companies ship big quantities of waste across European countries and to other places in the world. Only in 2019, 31 million tonnes of waste were shipped out of the EU, with Turkey as the main destination. The volume has increased a whopping 66% since 2004.

This is just one of the aspects covered by the European Waste Shipment Regulation, now being revised by the European Commission to fit the objectives set out in the European Green Deal and the Circular Economy Action Plan. We have now an opportunity to discourage waste generation, introduce more demanding requirements for recycling, and make it harder for any waste management company to engage in illegal practices.

The Waste Shipment Regulation sets the rules for companies shipping waste across borders inside the European Union and to other countries. It targets all stakeholders involved in waste shipment, including the treatment operations for waste to be shipped across borders and seeks to ensure a high level of human health and environmental protection of such operations. Moreover, it controls the import and export of waste between EU member states but also towards other countries according to ‘Environmentally Sound Management’ of waste principles. In some cases, such as for hazardous waste, this includes bans on the export towards third countries.

As part of the regulation revision, the European Commission held a public consultation, closed on 30 July, seeking to gather stakeholder views on how the regulation could help limit waste exports out of the EU and develop treatment capacity domestically to prevent so-called “waste dumping” in less developed countries. This review has the potential to support the development of a real market in the EU for preparation for re-use and recycling.

ECOS’ contribution called on the Commission to raise the ambition level of their proposed measures. Our main points include:

  • A restriction on EU-internal waste shipment to discourage waste generation overall, and mandatory declaration of chemical content of waste to be shipped (e.g. through a product passport);
  • An application of the Basel amendments relating to plastic waste in EU, without any derogation for Y48, PVC, PC, PS and PUR, including fractions of plastic waste, as of 1 January 2021;
  • A stronger stance towards illegal practices through higher fines, EU trade prohibition, mandatory reporting of quantities shipped per waste fraction and material stream, e.g. per plastic polymer;
  • Limit mutual recognition and therefore uneven practices between the EU Member States by introducing EU-wide harmonised end-of-waste criteria for waste-derived materials (e.g. destined for chemical recycling) and fuels (e.g. as solid recovered fuels);
  • A much-needed clarification of the definitions of current treatment technologies and how they are considered in EU waste policy – chemical recycling today includes pyrolysis, gasification, solvent-based purification but each of these require specific safeguards in how their feedstock, i.e. waste, is pre-treated to ensure ‘environmentally sound management’;  
  • Conditioning waste shipments for re-use and repair to a financial guarantee for proper waste treatment at end-of-life, for example through Extended Producer Responsibility fees.


ECOS is co-funded by the European Commission and EFTA

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