Tracking Hazardous Waste

Commission for Environmental Cooperation

Improving the Transboundary Tracking of Hazardous Waste 

in North America: A Regional Approach to a Global Effort 

Benefits for common data standards 

for managing transboundary 

hazardous waste shipments

September 2007

Introduction

The Commission for Environmental Cooperation (CEC) is working on a project 

which will allow the governments of Canada, Mexico and the United States to 

replace their current paper-based system of tracking transboundary shipments 

of hazardous waste and hazardous recyclable materials with an electronicbased system. 

As part of this project, the governments are developing common data standards 

for export requests and consent documents and a method for sharing this 

information electronically. 

Importers and exporters must obtain written approvals from national 

governments to ship hazardous waste or hazardous recyclable material 

from one country to another. Currently, countries share export requests and 

consents documents with one another by sending paper copies through the 

mail, by fax or by cable. This results in the exchange of hundreds of thousands 

of documents between North American governments each year. 

The CEC project will allow governments to exchange this export request and 

consent information electronically. This will reduce government administrative 

burdens, improve data quality, make it easier to provide data to environmental 

enforcement and border protection agencies, facilitate the adoption of 

emerging tracking technologies and help the governments provide more timely 

and coherent information on what crosses their national borders.

This project will also enhance compliance. The new electronic system will 

include information on shipment requirements. This will allow the governments 

to compare the requirements with the actual shipment information in order to 

determine possible violations. 

The Secretariat of the Commission for Environmental Cooperation developed this paper in cooperation with the Hazardous Waste Task Force, as part of the Trade and Enforcement of Environmental Laws Project. The information contained herein is the responsibility of the authors and 

does not necessarily reflect the views of the CEC, or the governments of Canada, Mexico or the 

United States of America.

The CEC Secretariat would like to thank Tim Whitehouse (CEC), Geneviève Cournoyer-Proulx 

(CEC), Rick Picardi (EPA), Debbie Goodwin (EPA), Robert Heiss (EPA), Loraine Deshaies (Env. 

Canada), Nabila Elsaadi (Env. Canada), Kevin Tracy (Env. Canada), Jose Lorenzo (Semarnat) and 

Emil Dzuray (LMI).

Publication Details

Publication type: Background paper

Publication date: September 2007

Original language: English

Review and quality assurance procedures:

Party review: 16 July – 13 August 2007
The Charge from the CEC Council 

In order to move in the direction of electronic exchange of information and away from 

a paper-based system, the Commission for 

Environmental Cooperation (CEC) Council 

Resolution 03-08 directs the Secretariat to 

work with the North American countries to: 

“ ... continue to examine technologies and 

systems currently being considered for hazardous waste and hazardous recyclable materials and wastes tracking in North America, 

with a view toward identifying obstacles to 

the interoperabilityof these systems, laying 

the framework for the exchange of information, and implementing automated systems 

for tracking transboundary movements in 

North America.”1

As follow up to Council Resolution 03-08, 

the CEC’s Hazardous Waste Task Force 

(HWTF) has agreed to create common North 

American data standards for the electronic 

exchange of information on governmentto-government export request (commonly 

known as a “notice”) and consent for transboundary shipments of hazardous waste or 

hazardous recyclable material. This work 

will take into consideration: 

•	 the methodology established by the United Nations Centre for Trade Facilitation 

and Electronic Business (UN/CEFACT)2

for developing global data standards and 

the work of the UN/CEFACT’s environmental group, Trade Business Group 13 

(TBG-13), and

•	 the modernization and trade facilitation 

efforts, as well as the material data standards, of the World Customs Organization (WCO). 

1 http://www.cec.org/files/PDF/COUNCIL/Res-08-HazWaste_en.pdf

2 UN/CEFACT, a United Nations body, encourages 

close collaboration between governments and business 

to improve their ability to facilitate the development of 

effective and efficient international, electronic information exchange through the creation and use of global data 

standards and protocols. The UN/CEFACT subgroup 

called TBG-13 is responsible for improving the exchange 

of environmental information among countries. For 

more information, see: www.uncefact.org

The Hazardous Waste Notice System

Canada, Mexico and the United States require 

exporters and importers to obtain approvals 

from designated government environmental authorities for shipments of hazardous 

waste and hazardous recyclable materials 

and to keep a record of the material’s fate 

from its point of origin to its final destination. Although specific requirements differ 

in the three countries, they are all based on 

the Prior Informed Consent (PIC) concept3

, 

which states that a shipment of hazardous 

waste or hazardous recyclable material may 

only be exported to another country with the 

importing country’s prior consent.

PIC is achieved through a government-togovernment export notice and consent process. Under this notice and consent process, 

an exporter must submit a notification of intent to export to the environmental authority 

3 The PIC concept does not apply to the hazardous waste 

generated by U.S. companies operating in Mexico under 

the Maquiladora Program. Under the United-States 

Mexico La Paz Agreement, the United States agreed to 

accept hazardous waste from maquiladoras, as these 

companies are referred to, without requiring Mexico to 

obtain consent from the United States. 

of the country in which the exporter is located. The exporting country’s environmental 

authority then forwards the “notice of intent” 

to the importing country which can consent 

or object to the shipment. The importing 

country then sends the approval or objection 

back to the exporting country’s environmental authority. The exporting country’s environmental authority then sends the approval 

(in the form of a consent or a permit), or objection to the exporter and records the information in a data system. 

A notice contains a variety of detailed information about the proposed hazardous waste 

or hazardous recyclable material shipments 

such as, but not limited to:

•	 the time period covered by the notice,

•	 the type and anticipated amount of waste,

•	 an estimate of the number of waste shipments that will be exported,

•	 the type of container to be used,

•	 the name and address of the party to 

whom the waste will be shipped, and

•	 the method of transportation to be used 

(air, highway, rail, water).

2 Transboundary Tracking of Hazardous Waste
The consent or approval of a permit 

may be valid for up to a year and 

may cover multiple shipments. 

The Benefits of Moving to 

an Electronic Exchange of 

Export Notice and Consent 

Information

The creation of North American data standards will allow for 

the electronic exchange of export 

notice and importing country’s 

consent information between the 

governments. A major limitation 

of the current paper-based system 

is that it does not allow for the most efficient 

and effective sharing of data. The electronic 

sharing of information will improve overall 

data quality, enhance enforcement capabilities, support border security, facilitate the 

adoption of more advanced tracking technologies, allow governments to reduce administrative burdens, and reduces the environmental footprint by wasting less paper.

Under the current system of exchanging information by fax, mail or cable the North 

American governments must enter notice 

information manually into multiple data systems, which can result in delays and data entry 

errors. If information is exchanged electronically, the government of the exporting country would send the notice information and 

consent or objection to the importing country, saving the governments both the time and 

money of data being entered multiple times, 

improving the accuracy of this information.

The electronic transmission of data is likely 

to enhance the capability of the governments 

to cooperate on compliance monitoring and 

enforcement activities of mutual interest. 

The receipt of information on a more timely 

and accurate basis is likely to improve the 

documentation of shipments between countries and enable the governments to more 

readily identify discrepancies that may indicate violations of law.

In addition, it is anticipated that customs, 

border agencies, and other governmental 

agencies could have electronic access to notice and consent information contained in 

the data system of the domestic environmental authorities. 

Electronic sharing of notice and consent information between governments requires the 

use of common data standards. Once the 

countries agree on these data standards and 

the method for electronically sharing this information, they will have a common North 

American framework which will facilitate 

improved international tracking. 

The Need for Common Data Standards

Today, data standards are commonly used 

globally for the electronic exchange of information. They are documented agreements 

on formats and definitions of common data 

shared for a particular transaction or series 

of transactions. When organizations adopt data standards, they 

agree on what information to 

send and how to send it using a 

common language for that particular data exchange. When a 

Canadian traveling in Mexico 

uses an ATM, for example, the 

bank in Mexico and the bank in 

Canada are able to exchange information on the user’s account 

and conduct the transaction because both banks use common 

data standards and have agreed 

upon rules for converting pesos 

to dollars.

Common data standards allow 

information from different data systems to 

be easily shared without changing the source 

data systems (i.e., the United States would 

not have to upgrade its system to exchange 

information with an upgraded system in 

Mexico or Canada, or vice-versa – this is also 

referred to as decoupling systems from data 

exchanges). This is especially useful for international transactions such as exports and 

imports of hazardous waste or hazardous recyclable material. The relevant information 

from the source data systems is converted to 

meet the common data standards, and then 

the data file will be electronically sent to the 

importing country’s environmental authority for internal processing into their respective data systems.4

 

Creating Common North American 

Data Standards for Notice and 

Consent Information

Some of the activities necessary for creating a 

common North American data standard for 

notice and consent information will require 

4 There will be no trilateral data system or ‘data warehouse’ in which the data from the three countries would 

be stored in one place. All that is needed is an identified 

location for the exporting country to place the data file 

for the importing country to access.

Transboundary Tracking of Hazardous Waste 3
Commission for Environmental Cooperation

393, rue St-Jacques Ouest, bureau 200, Montréal (Québec) Canada H2Y 1N9 T (514) 350-4300 F (514) 350-4314 info@cec.org - www.cec.org

identifying information, called data elements. For each data element the following 

needs to be agreed upon:

•	 Definition for the data element, i.e. what information does the data actually represent?

•	 Length of the data element, i.e. two characters long,

•	 Values that can be held in that data element, i.e. it contains a “Y” or an “N”, it 

must be a valid date, it must be one of the 

agreed upon waste codes, etc., and

•	 Any rules associated with the data element, i.e. shipping information must be a 

date which is the same or greater than the 

date shipping begins, quantity can not be 

zero, etc.

Once these common data elements have been 

agreed upon, file formats for notices must be 

developed. 

This CEC Project Ties into Other 

International Efforts

Just as the CEC recognized the need for common data standards for exchanging notice 

information, other international organizations have seen this need and begun efforts 

to develop common data standards such as 

the UN/CEFACT group, as mentioned earlier. UN/CEFACT encourages collaboration 

between governments and business to secure 

the inter-operability for the exchange of information. The CEC HWTF will coordinate 

with the UN/CEFACT to: align with the development of global data exchange standards; 

reduce duplication of efforts; share ideas so 

that the HWTF’s work is informed by what is 

occurring in the global community; and ensure that UN/CEFACT takes North American 

data needs into account. The development of 

data exchange standards by UN/CEFACT, 

the CEC and other organizations illustrates 

that the HWTF project is a timely effort. 

CEC Has a Critical Role to Play in the 

Development of International Data 

Standards

Through the implementation of a systematic 

approach to the development of data standards, the investments and planning of previous years are now coming to fruition. While 

giving consideration to larger global efforts, 

the CEC is fast tracking the development of 

the North American data standards for notification. The CEC has a key role to play because a significant proportion of hazardous 

waste and hazardous recyclable materials are 

shipped within North America. The CEC is 

better suited than the three individual countries to ensure that the ongoing UN environmental standards effort reflects the export/

import requirements unique to North America. Furthermore, the timing of the CEC effort is especially opportune because the UN 

effort is just now gaining momentum.