Exploration of potential policy responses to review the Waste Shipment Regulation.
Date: 2021-07-05
Institutions: Directorate-General for Environment
Subjects: EU Member State, administrative formalities, economic consequence, environmental impact, exchange of information, export of waste, hazardous waste, international convention, regulation (EU), report, vessel, waste management, waste recycling

Exploration of potential policy responses 
to review the Waste Shipment Regulation

June 2021

Environment

EUROPEAN COMMISSION 

Directorate-General for Environment 
Directorate B3 
Unit Circular Economy and Green Growth — Waste management and Secondary Materials 

Contact: Gaël de Rotalier 

E-mail:  gael.de-rotalier@ec.europa.eu

European Commission 
B-1049 Brussels

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PDF        ISBN 978-92-76-39441-9        doi:10.2779/224991        KH-02-21-888-EN-N 

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Contract details 

European Commission - DG Environment 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific Request Nr 4 under Framework Service Contract No ENV/F1/FRA/2019/0001 

Economic analysis of environmental policies and analytical support in the context of Better Regulation 

Presented by 

Consortium led by: 

Trinomics B.V. 

Westersingel 34 

3014 GS Rotterdam 

The Netherlands 

Contact 

Mr Keir McAndrew 

E: keir.mcandrew@woodplc.com 

T: +32 (0) 470 87 28 94 

Mr. Robert Williams 

E: rob.williams@trinomics.eu 

T: +44 07950 229 107 

Date 

Rotterdam, May 2021 

Exploration of potential policy 
responses to review the Waste 
Shipment Regulation 

Rotterdam, May 2021 

Client: European Commission - DG Environment 

Specific Request Nr 4 under Framework Service Contract No 
ENV/F1/FRA/2019/0001 

In association with: 

TEC6504EU 

Exploration of potential policy responses to review the Waste Shipment Regulation

Abstract: 
The main purpose of this report is to inform the impact assessment of the Waste Shipment Regulation 

(WSR). Multiple research methods and analytical tools have been used, including literature review and 

consultation via open public questionnaires, workshops and interviews. Modelling of potential options to 

assess their economic and environmental impacts has also been carried out. The study has considered 

the three main problems with the WSR highlighted in a previous evaluation: With regard to intra-EU 

shipments of waste, a variation between Member States in the level and manner of applying and 

enforcing the WSR; Difficulties in verifying that waste exported outside the EU is managed in an 

environmentally sound manner; and, Illegal shipments of waste and illegal treatment of legally shipped 

waste in third countries.  

The report concludes that: An Electronic Data Interchange would be a cost effective way to reduce 

administrative costs and improve the consistency of approach between MSs; There are opportunities to 

reduce the cost of financial guarantees; Restricting the export of EU wastes to third countries results in 

net positive outcomes for all wastes of between €1 billion and €13 billion depending on the extent of 

the restrictions imposed. Costs would be encountered in the EU, particularly in relation to building 

capacity to manage previously exported wastes. However, the economic value of the wastes retained, 

environmental damage avoided and additional employment in the waste management sector within the 

EU of between 10 000 and 178 000 FTEs result in a net positive outcome for the measures assessed. 

Aperçu 

L'objectif principal de ce rapport est d'informer l'analyse d'impact du Règlement concernant les 

transferts de déchets (RTD). De multiples méthodes de recherche et outils analytiques ont été utilisés, 

y compris une revue de la littérature et une consultation via des questionnaires publics, des ateliers et 

des entretiens. Une modélisation des options potentielles a également été réalisée pour évaluer leurs 

impacts économiques et environnementaux. L'étude a examiné les trois principaux problèmes du RTD 

qui avaient été mis en évidence dans une évaluation précédente: En ce qui concerne les transferts 

intra-UE de déchets, une variation entre les États membres dans le niveau et la manière d'appliquer et 

de faire respecter le RTD; Des difficultés à vérifier que les déchets exportés hors de l'UE sont gérés de 

manière écologiquement rationnelle; et, les transferts illégaux de déchets et le traitement illégal des 

déchets légalement expédiés dans des pays tiers. 

Le rapport conclut que: Un échange de données informatisé serait un moyen rentable de réduire les 

coûts administratifs et d'améliorer la cohérence de l'approche entre les États membres; Il existe des 

possibilités pour réduire le coût des garanties financières; La limitation des exportations de déchets de 

l'UE vers des pays tiers se traduit par des résultats positifs nets pour tous les déchets compris entre 1 et 

13 milliards d'euros, en fonction de l'ampleur des restrictions imposées. Des coûts seraient encourus 

dans l'UE, en particulier en ce qui concerne le renforcement des capacités de gestion des déchets 

précédemment exportés. Cependant, la valeur économique des déchets conservés, les dommages 

environnementaux évités et l'emploi supplémentaire dans le secteur de la gestion des déchets au sein 

de l'UE, compris entre 10 000 et 178 000 emplois à temps plein, se traduisent par un résultat net positif 

pour les mesures évaluées. 

Exploration of potential policy responses to review the Waste Shipment Regulation

CONTENTS

Executive Summary ..................................................................................... i 

Résumé........................................................................................................ iv 

1 

Introduction .......................................................................................... 1 

1.1 

1.2 

1.3 

Purpose of this report ............................................................................ 1 

Status of this report ............................................................................... 1 

Taking into account the impacts of Covid-19 ................................................ 1 

2  Approach to the Analysis .......................................................................... 3 

2.1 

2.2 

2.3 

2.4 

2.5 

General approach .................................................................................. 3 

Research methodology ............................................................................ 4 

Assumptions ......................................................................................... 4 

Limitations........................................................................................... 4 

Consideration of the Outermost Regions ..................................................... 5 

3  Calculations performed in the analysis ......................................................... 7 

3.1 

3.2 

3.3 

3.4 

3.5 

Introduction ......................................................................................... 7 

Determining the weight and value of wastes subject to transboundary movements
7 

Determining economic costs and benefits ................................................. 11 

Determining social costs and benefits ....................................................... 13 

Determining environmental benefits ........................................................ 14 

4  What is the problem with the existing EU waste shipments regime and why is it a 
problem? ................................................................................................. 21 

4.1  What have we learned from experience to date in the implementation of the WSR 
and Regulation 1418/2007? ..................................................................................... 21 

4.2  What problems did the evaluation of the WSR and Regulation identify? ............ 22 

4.3 

Summarising the current challenges and translating them into objectives ........ 23 

5  Existing Waste Shipment measures – defining the baseline .............................. 27 

5.1 

Introduction to the existing waste shipment policies ................................... 27 
Rationale for controlling waste shipments ..........................................................27

The Basel Convention ...........................................................................................27

The OECD Decision ...............................................................................................28

The EU Waste Shipments Regulation ..........................................................................28

The relationship between the EU Waste Shipments Regulation and Regulation 1418/2007 concerning 

export for recovery of certain listed wastes..........................................................................29

5.2 

Shipments of waste from a quantitative perspective .................................... 30 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Introduction to the numerical baseline ..............................................................30 

  Trends in waste shipments by volumes and values including countries of export and 

destination 

31 

6  Why should the EU act? .......................................................................... 71 

7  What are the measures that can contribute to addressing the objectives identified?

73 

7.1 

7.2 

7.3 

Introduction ....................................................................................... 73 

Choice of policy options ........................................................................ 73 

Description of the specific objectives and measures to address them .............. 74 
  General objective 1 – Ensuring a smoother functioning of the EU internal market for waste 

and supporting the transition to a circular economy ................................................................74 

  General objective 2 – Better guarantee waste shipped outside the EU are managed in an 

environmentally sound manner.........................................................................................81 
  General objective 3 – Better prevent and address illegal shipments of waste .................87 

8  What are the impacts of the different options and measures and who will be 
affected? ................................................................................................. 91 

8.1 

8.2 

Introduction and initial screening ............................................................ 91 

Economic impacts of measures ............................................................... 93 
  Specific objective 1a – Align shipments with the waste hierarchy ...............................93 
  Specific objective 1b - Simplification and reduction of administrative burden for intra-EU 

shipments of waste ......................................................................................................98 
  Specific objective 1c - harmonisation of interpretation, application and enforcement across 

Member States 105 

  Specific objective 1d – Better adapt to technical progress and stimulation of innovation .. 106 
  Specific objective 2a – stop or restrict export of waste outside of the EU ................... 107 
  Specific objective 2b – verify ESM in destination countries ..................................... 136 
  Specific objective 3a – Further strengthen provisions on enforcement and inspections .... 137 
  Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at 

EU and national levels and strengthen cooperation across the EU and with international partners ........ 139 

8.3 

Social impacts of measures ................................................................... 142 
  Specific objective 1a – Align shipments with the waste hierarchy ............................. 142 
  Specific objective 1b Simplification and reduction of administrative burden for intra-EU 

shipments of waste .................................................................................................... 143 

  Specific objective 1c Harmonisation of interpretation, application and enforcement across 

Member States 143 

  Specific objective 1d – Better adapt to technical progress and stimulation of innovation .. 143 
  Specific objective 2a – stop or restrict export of waste outside of the EU ................... 143 
  Specific objective 2b – verify ESM in destination countries ..................................... 150 
  Specific objective 3a – Further strengthen provisions on enforcement and inspections .... 150 
  Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at 

EU and national levels and strengthen cooperation across the EU and with international partners ........ 150 

8.4 

Environmental impacts of measures ........................................................ 151 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

  Specific objective 1a – Align shipments with the waste hierarchy ............................. 151 
  Specific objective 1b - Simplification and reduction of administrative burden for intra-EU 

shipments of waste .................................................................................................... 152 
  Specific objective 1c - harmonisation of interpretation, application and enforcement across 

Member States 152 

  Specific objective 1d – Better adapt to technical progress and stimulation of innovation .. 154 
  Specific objective 2a – Stop or restrict export of waste outside of the EU ................... 154 
  Specific objective 2b – verify ESM in destination countries ..................................... 164 
  Specific objective 3a – Further strengthen provisions on enforcement and inspections .... 164 
  Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at 

EU and national levels and strengthen cooperation across the EU and with international partners ........ 164 

8.5 

Other impacts of measures ................................................................... 165 

9  Conclusions: How do the policy options compare? ...................................... 168 

9.1 

Objective 1 – Ensuring a smoother functioning of the EU internal market for waste 
and supporting the transition to a circular economy .................................................... 174 

9.2 

Objective 2 – Better guarantee waste shipped outside the EU are managed in an 

environmentally sound manner ............................................................................... 176 

9.3 

Objective 3 – Better prevent and address illegal shipments of waste .............. 180 

Annex 1 Open Public Consultation Results ..................................................... 183 

Overview of respondents ............................................................................... 183 

Results ................................................................................................. 185 

Section 1 – General public .............................................................................. 185 
First policy objective: the WSR should support the transition to a circular economy in the EU more 

effectively .............................................................................................................. 185 
Second policy objective: Restrict the export of EU waste to third countries .......................... 189 
Third policy objective: Strengthen the enforcement of the Waste Shipment Regulation’s provisions

 ........................................................................................................................... 195 

Additional policy objectives and measures identified in the general public section of the 

consultation ............................................................................................................. 197 

Section 2 – Expert stakeholder questionnaire ..................................................... 199 

Challenge 1 - Ensuring a smoother functioning of the EU internal market for waste and 

supporting the transition to a circular economy .......................................................... 199 
Measure 1a – Align shipments with the waste hierarchy and existing EU legislation .................. 199 
Measure 1b – simplification and reduction of administrative burden for intra-EU shipments of waste

 ........................................................................................................................... 200 
Measure 1c – harmonisation of interpretation, application and enforcement across Member States201 
Measure 1d – Provide more relevant delegations to the Commission to adapt the Regulation over 
time to technical and policy progress. .............................................................................. 202 

Challenge 2 – Better guarantee waste shipped across borders are managed in an 

environmentally sound manner ............................................................................... 203 
Measure 2a – stop exporting EU waste outside of the EU ................................................. 203 

 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Measure 2b – verify ESM in destination countries .......................................................... 204 
Measure 2C ..................................................................................................... 206 

Challenge 3 – Better prevent and address illegal shipments of waste ........................ 206 
Measure 3a – Further strengthen provisions on enforcement and inspections ......................... 206 
Measure 3b – Increase the priority of addressing illegal shipments of waste and strengthen EU and 

global cooperation ..................................................................................................... 207 

Annex 2 Stakeholder workshop report .......................................................... 209 

Workshop - Exploration of potential policy responses to review the Waste Shipment 

Regulation  209 

Workshop introduction and setting the scene ..................................................... 210 

Objective 1: Ensuring a smoother functioning of the EU internal market for waste and 
supporting the transition to a circular economy .......................................................... 211 
Specific objective 1a Alignment of the waste hierarchy, WSR and other EU legislation ............. 211 
Specific objective 1b - simplification and reduction of administrative burden for intra-EU shipments 
of waste ................................................................................................................. 213 
Specific objective 1c - harmonisation of interpretation, application and enforcement across Member 
States .................................................................................................................... 216 
Ships ............................................................................................................. 218 
Levels of contamination of waste ........................................................................... 218 
Specific objective 1d - better adapt to technical progress and stimulation of innovation ........... 219 

Day Two ..................................................................................................... 221 

Objective 2: Better guaranteeing that waste shipped outside the EU is managed in an 
environmentally sound manner ............................................................................... 221 
3.1  Specific objective 2A – Stop or restrict export of waste outside the EU ......................... 221 
Specific objective 2b – Verify ESM in destination countries .............................................. 227 

Objective 3: Better preventing and addressing illegal shipments of waste ................. 229 
Specific Objective 3a – Further strengthen the WSR’s provisions on enforcement and inspections . 229 
Specific Objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and 

national levels and strengthen cooperation across the EU and with international partners ................. 230 

Additional issues considered during the workshop ............................................... 233 

Next Steps: ................................................................................................. 233 

Workshop Agenda .................................................................................... 233 

Workshop Attendees ................................................................................ 234 

Annex 3: List of references ....................................................................... 241 

Books / papers / reports ................................................................................ 241 

Legislative acts / Communications .................................................................... 243 

Websites / articles ........................................................................................ 244 

Annex 4 List of CN codes used in the determination of waste flows ..................... 247 

 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Executive Summary 

Wood E&IS GmbH and Trinomics are pleased to present this report to the European Commission. It 

constitutes the Final Report of the study ‘Exploration of potential policy options to review the Waste 

Shipment Regulation’, undertaken under the broader contract " Economic analysis of environmental 

policies and analytical support in the context of Better Regulation" (Framework Contract No. 

ENV/F1/FRA/2019/0001). 

Shipments of waste have been a concern to society for decades. However, their potential harm was 

first highlighted as a result of several high-profile events, particularly in the 1970s and 1980s including 

mislabelled waste ending up in unsuitable destinations and being left to deteriorate, thereby polluting 

the environment and threatening human health as well as several examples of wastes moving from port 

to port without seeking permission for exports of waste in the first place. 

The European Community originally introduced measures on the supervision and control of shipments of 

waste in 1984 under Council Directive 84/631/EEC. The Directive took effect from 1 October 1985 and 

covered shipments of hazardous waste; it required prior notification to the countries involved, thereby 

allowing them to object to a specific shipment.  In 1990, following international developments in the 

context of the Basel Convention and the OECD Decision, the Commission put forward a proposal for a 

Waste Shipment Regulation with the Basel Convention and, latterly, the 1992 OECD Decision forming 

the main pillars of the resulting 1993 Regulation. The 1993 Regulation entered into force on 9 February 

1993 and was applicable as of 6 May 1994. The move to a Regulation rather than a Directive was aimed 

specifically at addressing transposition and implementation issues encountered in the original 1984 

Directive.  

As both the Basel Convention and OECD Decision have evolved over time, it has been necessary for the 

Regulation to be amended to consider such developments. Furthermore, problems with the Regulation 

identified in its operation within the EU have also led to changes. The most significant change arose in 

2006 with the adoption of Regulation (EC) No 1013/2006 on shipments of waste that replaced the 1993 

Regulation. The Regulation applies to shipments of waste: 

• 

• 

• 

• 

Between EU countries within the EU or transiting via non-EU countries; 

Imported into the EU from non-EU countries; 

Exported from the EU to non-EU countries; 

In transit through the EU, on the way from or to non-EU countries. 

The Regulation was subject to an evaluation, the results of which were published in a Commission Staff 

Working document issued in 2020. That evaluation identified three main problems in the operation of 

the Regulation: 

•  With regard to intra-EU shipments of waste, different levels and manners of applying and 

enforcing the WSR, often combined with diverging interpretations of its provisions, result in 

suboptimal implementation throughout the EU. Clear examples are the different classifications 

across Member States of the same waste, or the different application of procedural delays or 

means of interchanging documents, with some competent authorities allowing for electronic 

exchange more leniently than others. This results in delays in and burdens on shipments of 

i 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

wastes across the EU, despite the fact that in many cases waste flows are of good quality and 

are being shipped for the purpose of proper recovery. This also impacts on exports from the EU 

to third countries.  

Additionally, it was identified that whilst in 2018 a substantial part of EU waste acquis was 

substantially amended to enhance its contribution to a circular economy (e.g. more ambitious 

recycling rates), the WSR was not. The WSR as it stands does not clearly reflect the need to favour 

recycling (and preparation for re-use) over other recovery operations (like incineration), so that in 

this respect it is not fully aligned with the rest of the existing EU waste legislation and other policy. 

Finally, the use of paper-based systems of notifications remains high and, thereby, has failed to 

capitalise on the benefits of digitalisation of processes that both reduces burden as well as 

stimulating innovation. 

• 

Difficulties for competent authorities of the EU Member States to verify that waste exported 

outside the EU is managed in an environmentally sound manner in the importing country. 

Furthermore, while Regulation (EC) No 1418/2007 regulating exports of non-hazardous wastes 

to non-EU, non-OECD countries has contributed to the achievement of the WSR’s environmental 

objectives, in its current from it suffers from a slow and very resource intensive update 

mechanism.  

• 

This is the case especially for export of wastes outside the EU, in particular to developing 

countries.  

• 

Illegal shipments of waste and illegal treatment of legally shipped waste in third countries 

remain a considerable problem. The persistence of illegal waste shipments is inter alia due to 

the fact that competent authorities in Member States often lack comparable resources and 

that Member States do not cooperate sufficiently with each other, or in a coordinated way pan-

European. Illegal shipments find the path of least resistance to get through or leave Europe. 

There are also illegal shipments of wastes within the EU, linked to activities of organised 

criminal networks. These difficulties remain despite the efforts to address enforcement and 

compliance shortcomings in a revision to the WSR that was made in 2016. 

This study looked to examine the potential impacts of policy options and measures contained therein to 

address these three problematic areas by defining three overall objectives, and within those three 

overall objectives eight specific objectives as shown below. 

General objective 

Specific objective 

General objective 1 – Ensuring a smoother 

functioning of the EU internal market for 

waste and supporting the transition to a 

circular economy 

Specific objective 1a – Align shipments with the waste hierarchy 

and existing EU legislation 

Specific objective 1b – Simplification and reduction of 

administrative burden for intra-EU shipments of waste 

Specific objective 1c – harmonisation of interpretation, application 

and enforcement across 

Member States 

Specific objective 1d – Better adapt to technical progress and 

stimulation of innovation 

General objective 2 – Better guarantee 

Specific objective 2a – stop or restrict export of waste outside of 

waste shipped outside the EU are 

the EU 

managed in an environmentally sound 

Specific objective 2b – verify ESM in destination countries 

manner 

ii 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

General objective 

Specific objective 

Specific objective 3a – Further strengthen provisions on 

enforcement and inspections 

General objective 3 – Better prevent and 

Specific objective 3b – Increase efficiency in the fight against 

address illegal shipments of waste 

illegal shipments of waste at EU 

and national levels and strengthen cooperation across the EU and 

with international partners 

The methodology applied can be summarised as follows: 

• 

Identification of the baseline – identifying the trajectory of waste shipments based on existing 

policies and market mechanisms. A bespoke quantitative model was developed using trade 

data from Eurostat examining shipments of specific wastes (non-ferrous metal, ferrous metal, 

plastic, paper & cardboard, glass and textiles) as well as notifiable wastes. The information 

gathered addressed the period 2004-2019 in order to examine longer-term changes in flows of 

waste by both weight and € value. 

• 

Identifying a long-list and subsequently and shortlist of measures – identifying a long list of 

measures that could be applied to achieve the objectives identified above, that was then 

short-listed through discussion with the European Commission. The short-listed measures were 

subject to the detailed assessment included in this study. 

•  Modelling economic impacts of measures, most notably in respect to costs of compliance and 

administrative costs. 

•  Modelling social impacts of measures, most notably in relation to employment of social 

conditions in third countries resulting from their treatment of EU sourced wastes. 

•  Modelling environmental impacts of measures including environmental externalities avoided 

through the application of the shortlisted measures. 

This report assumes the following: 

• 

The data provided in Eurostat are accurate in terms of reported € value. A sense check was 

performed using approximated market values of materials in order to determine the impact of 

the final economic outcomes of measures and to compare with the trade reported values to 

Eurostat. 

• 

Different measures are related to different outcomes: as such, the range of ambition is 

reflected in the variation in the types of measures deployed. 

The data available in relation to waste shipments is variable in its quality. To the extent possible this 

report uses published sources which are, in the opinion of the team, the most dependable with a 

preference for data collected at the EU level and with the most transparent methodology. However, 

gaps in evidence remain and where this is the case they are explained in the detailed assessment. 

The key results of the assessment can be summarised as: 

• 

Doubts were expressed by stakeholders as to whether measures addressing stricter provisions 

for energy recovery and landfilling would effect in aligning shipments with the waste hierarchy 

and existing EU legislation. It was moreover felt by some stakeholders that landfilling, 

incineration and R1 activities are likely to remain a necessity for the foreseeable future for 

certain waste types as well as waste management capacity issues in some Member States. This 

should be taken into account when pursuing such measures.  

iii 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

Reducing the administrative burden and other costs linked with notification procedures for 

waste shipped for reuse or recycling offers the opportunity to reduce costs when compared 

with the present consenting approach. This would particularly be the case if this approach also 

reduced the time necessary for approval of a shipment to take place. However, ESM should 

remain ensured at destination.  

• 

The savings gained in comparison to the cost of implementing an Electronic Data Interchange 

(EDI) makes the EDI an obvious measure to implement under all circumstances. 

•  Multiple possibilities exist to alternatively provide for sufficient funds to address application of 

the guarantee to problematic shipments. But many complexities remain. 

•  Measures could be introduced to ensure greater consistency of approach in relation to 

categorisation of waste within the legislation. However, the broad range of wastes concerned 

mean that this may be better served through guidance. 

• 

The sharing of experiences via online platforms would offer positive impacts at little cost, 

albeit effort may be best placed in improving use of existing platforms rather than starting an 

additional sharing system. 

• 

Restricting the export of EU wastes to third countries results in net positive outcomes for all 

wastes depending on the extent of the restrictions imposed both in terms of materials as well 

as third countries concerned. Whilst costs would be encountered in the EU, particularly in 

relation to building capacity to manage wastes within the EU that were previously exported, 

the savings in terms of economic value of the wastes retained, the environmental damage 

avoided and the additional employment in the waste management sector within the EU result 

in a net positive outcome for the measures assessed. 

• 

Additional action to address ESM in third countries through both clarification of the Regulation 

in relation to ESM, as well as additional compliance assessment at the EU level and work with 

third country stakeholders via shared working groups and bodies would reduce poor 

management of EU wastes outside of the EU whilst further addressing illegal shipments. 

Résumé 

Wood E&IS GmbH et Trinomics ont le plaisir de présenter ce rapport à la Commission européenne. Il 

constitue le rapport final de l'étude « Exploration des options politiques potentielles pour la révision du 

règlement concernant les transferts de déchets », entreprise dans le cadre du contrat plus large 

"Analyse économique des politiques environnementales et soutien analytique dans le contexte d'une 

meilleure réglementation" (contrat-cadre n ° ENV/F1/FRA/2019/0001). 

Les transferts de déchets préoccupent la société depuis des décennies. Cependant, leur danger 

potentiel a été mis en évidence pour la première fois à la suite de plusieurs événements très 

médiatisés, en particulier dans les années 1970 et 1980, notamment des déchets mal étiquetés se 

retrouvant dans des destinations inappropriées et se détériorant, polluant ainsi l'environnement et 

menaçant la santé humaine ainsi que plusieurs exemples de déchets se déplaçant d'un port à l'autre 

sans demander l'autorisation d'exporter des déchets en premier lieu. 

La Communauté européenne a initialement introduit des mesures de surveillance et de contrôle des 

transferts de déchets en 1984 au sein de la Directive du Conseil 84/631/CEE. La directive est entrée en 

vigueur le 1er octobre 1985 et couvrait les transferts de déchets dangereux; elle exigeait une 

notification préalable aux pays concernés, leur permettant ainsi de s'opposer à un envoi spécifique. En 

iv 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

1990, à la suite des développements internationaux dans le contexte de la convention de Bâle et de la 

décision de l'OCDE, la Commission a présenté une proposition de Règlement sur les Transferts de 

Déchets avec la convention de Bâle et, dernièrement, la décision de l'OCDE de 1992 constituant les 

principaux piliers du règlement de 1993. Le règlement de 1993 est entré en vigueur le 9 février 1993 et 

était applicable à partir du 6 mai 1994. Le passage à un règlement plutôt qu'à une directive visait 

spécifiquement à résoudre les problèmes de transposition et de mise en œuvre rencontrés dans la 

directive initiale de 1984. 

La convention de Bâle et la décision de l'OCDE ayant toutes deux évolué au fil du temps, il a été 

nécessaire de modifier le règlement pour tenir compte de ces évolutions. En outre, les problèmes avec 

le règlement identifiés dans son fonctionnement au sein de l'UE ont également conduit à des 

changements. Le changement le plus important est survenu en 2006 avec l'adoption du règlement (CE) n 

° 1013/2006 sur les transferts de déchets qui a remplacé le règlement de 1993. Le règlement s'applique 

aux transferts de déchets: 

• 

• 

• 

• 

Entre pays de l'UE au sein de l'UE ou transitant par des pays tiers; 

Importés dans l'UE à partir de pays non membres de l'UE; 

Exporté de l'UE vers des pays non membres de l'UE; 

En transit à travers l'UE, en route depuis ou vers des pays tiers. 

Le règlement a fait l'objet d'une évaluation dont les résultats ont été publiés dans un document de 

travail des services de la Commission publié en 2020. Cette évaluation a identifié trois problèmes 

principaux dans le fonctionnement du règlement: 

• 

En ce qui concerne les transferts intra-UE de déchets, les différents niveaux et modes 

d'application et de mise en œuvre du RTD, souvent combinés à des interprétations divergentes 

de ses dispositions, se traduisent par une mise en œuvre sous-optimale dans toute l'UE. Des 

exemples clairs sont les différentes classifications entre les États membres des mêmes déchets, 

ou l'application différente des délais de procédure ou des moyens d'échanger des documents, 

certaines autorités compétentes autorisant l'échange électronique de manière plus clémente 

que d'autres. Cela entraîne des retards et des charges sur les expéditions de déchets à travers 

l'UE, malgré le fait que, dans de nombreux cas, les flux de déchets sont de bonne qualité et 

sont expédiés à des fins de valorisation appropriée. Cela a également un impact sur les 

exportations de l'UE vers les pays tiers. 

• 

En outre, il a été identifié que, si en 2018 une partie substantielle de l'acquis de l'UE en 

matière de déchets a été substantiellement amendée pour améliorer sa contribution à une 

économie circulaire (par exemple, des taux de recyclage plus ambitieux), le RTD ne l'a pas été. 

Le RTD tel qu'il se présente ne reflète pas clairement la nécessité de favoriser le recyclage (et 

la préparation en vue de la réutilisation) par rapport aux autres opérations de valorisation 

(comme l'incinération), de sorte qu'à cet égard, il n'est pas totalement aligné sur le reste de la 

législation européenne existante sur les déchets et sur ses autres politiques. Enfin, l'utilisation 

de systèmes de notification sur papier reste élevée et, par conséquent, n'a pas réussi à tirer 

parti des avantages de la numérisation des processus, qui à la fois réduit la charge et stimule 

l'innovation. 

• 

Les autorités compétentes des États membres de l'UE rencontrent des difficultés à vérifier que 

les déchets exportés hors de l'UE sont gérés d'une manière écologiquement rationnelle dans le 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

pays importateur. En outre, alors que le règlement (CE) n ° 1418/2007 réglementant les 

exportations de déchets non dangereux vers des pays non membres de l'UE, non membres de 

l'OCDE a contribué à la réalisation des objectifs environnementaux du RTD, dans son état 

actuel de mécanisme de mise à jour intensive. 

• 

C'est le cas notamment pour l'exportation de déchets hors de l'UE, et en particulier vers les 

pays en développement. 

• 

Les transferts illégaux de déchets et le traitement illégal des déchets légalement expédiés 

dans des pays tiers restent un problème considérable. La persistance des transferts illégaux de 

déchets est notamment due au fait que les autorités compétentes des États membres 

manquent souvent de ressources comparables et que les États membres ne coopèrent pas 

suffisamment entre eux ou de manière coordonnée au niveau paneuropéen. Les expéditions 

illégales trouvent le chemin de moindre résistance pour traverser ou quitter l'Europe. Il existe 

également des transferts illégaux de déchets au sein de l'UE, liés aux activités de réseaux 

criminels organisés. Ces difficultés persistent malgré les efforts déployés pour remédier aux 

lacunes en matière d'application et de conformité dans une révision du RTD effectuée en 2016. 

Cette étude visait à examiner les impacts potentiels des options politiques et des mesures qui y étaient 

contenues pour aborder ces trois domaines problématiques en définissant trois objectifs généraux, et 

au sein de ces trois objectifs généraux, huit objectifs spécifiques, comme indiqué ci-dessous. 

Objectif général  

Objectif spécifique 

Objectif général 1 - Assurer un 

fonctionnement plus fluide du marché 

intérieur de l'UE pour les déchets et 

soutenir la transition vers une 

économie circulaire  

Objectif spécifique 1a - Aligner les transferts sur la hiérarchie des 

déchets et la législation européenne existante 

Objectif spécifique 1b - Simplification et réduction de la charge 

administrative pour les transferts intra-UE de déchets 

Objectif spécifique 1c - harmonisation de l'interprétation, de 

l'application et de l'exécution à travers les États membres 

Objectif spécifique 1d - Mieux s'adapter au progrès technique et 

stimuler l'innovation 

Objectif général 2 - Mieux garantir 

Objectif spécifique 2a - arrêter ou restreindre l'exportation de déchets 

que les déchets transportés en dehors 

en dehors de l'UE 

de l'UE soient gérés de manière 

Objectif spécifique 2b - vérifier la Gestion Ecologique des Déchets 

écologiquement rationnelle 

(GED) dans les pays de destination 

Objectif général 3 - Mieux prévenir et 

lutter contre les transferts illégaux de 

déchets 

Objectif spécifique 3a - Renforcer les dispositions relatives à 

l'application et aux inspections 

Objectif spécifique 3b - Accroître l'efficacité de la lutte contre les 

transferts illégaux de déchets dans l'UE et au niveau national, et 

renforcer la coopération à travers l'UE et avec les partenaires 

La méthodologie appliquée peut être résumée comme suit: 

internationaux 

• 

Identification de la base de référence - identification de la trajectoire des transferts de 

déchets sur la base des politiques existantes et des mécanismes de marché. Un modèle 

quantitatif sur mesure a été développé à partir des données commerciales d'Eurostat 

examinant les expéditions de déchets spécifiques (métaux non ferreux, métaux ferreux, 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

plastique, papier et carton, verre et textiles) ainsi que des déchets à déclaration obligatoire. 

Les informations recueillies ont porté sur la période 2004-2019 afin d'examiner l'évolution à 

plus long terme des flux de déchets en poids et en valeur €. 

• 

Identifier une longue liste, puis une liste restreinte de mesures - identifier une longue liste de 

mesures qui pourraient être appliquées pour atteindre les objectifs identifiés ci-dessus, qui a 

ensuite été présélectionnée lors de discussions avec la Commission européenne. Les mesures 

présélectionnées ont fait l'objet d'une évaluation détaillée incluse dans cette étude. 

Ce rapport suppose ce qui suit: 

• 

Les données fournies dans Eurostat sont exactes en termes de valeur déclarée en €. Un 

contrôle de sens a été effectué à l'aide des valeurs marchandes approximatives des matériaux 

afin de déterminer l'impact des résultats économiques finaux des mesures et de les comparer 

avec les valeurs commerciales déclarées à Eurostat. 

• 

Différentes mesures sont liées à des résultats différents: à ce titre, la gamme des ambitions se 

reflète dans la variation des types de mesures déployées. 

• 

Les données disponibles concernant les transferts de déchets sont de qualité variable. Dans la 

mesure du possible, cette analyse d'impact utilise des sources publiées qui sont, de l'avis de 

l'équipe, les plus fiables, avec une préférence pour les données collectées au niveau de l'UE et 

avec la méthodologie la plus transparente. Cependant, des lacunes dans les preuves subsistent 

et, lorsque tel est le cas, elles sont expliquées dans l'évaluation détaillée. 

Les principaux résultats de l'évaluation peuvent être résumés comme suit: 

• 

Des doutes au sujet de l’impact des mesures concernant des dispositions plus strictes en 

matière de valorisation énergétique et de mise en décharge sur l’alignement des transferts sur 

la hiérarchie des déchets et la législation européenne existante ont été partagés par les parties 

prenantes. Par ailleurs, certaines parties prenantes ont également partagé leur conviction que 

la mise en décharge, l’incinération, et les activités R1 devront être maintenues dans l’avenir 

prévisible pour certains types de déchets, ainsi que pour des raisons de problèmes de capacité 

de gestion des déchets dans certains États membres. Cela devra être pris en compte lorsque 

ces mesures sont envisagées. 

• 

La réduction de la charge administrative et des autres coûts liés aux procédures de notification 

des déchets expédiés pour réutilisation ou recyclage offre la possibilité de réduire les coûts par 

rapport à l'approche actuelle du consentement. Ce serait particulièrement le cas si cette 

approche réduisait également le temps nécessaire à l'approbation d'une expédition. 

Cependant, la gestion écologiquement rationnelle (GER) devrait rester assurée à destination. 

• 

Les économies gagnées par rapport au coût de mise en œuvre d'un échange de données 

informatisé (EDI) font de l'EDI une mesure évidente à mettre en œuvre en toutes circonstances. 

• 

Il existe plusieurs alternatives pour sécuriser les fonds suffisants pour l’application de la 

garantie des envois problématiques. Cependant, plusieurs niveaux de complexités persistent.  

• 

Des mesures pourraient être introduites pour assurer une plus grande cohérence de l'approche 

en ce qui concerne la catégorisation des déchets dans la législation. Cependant, le large 

éventail de déchets concerné signifie que cela peut être mieux réalisé avec du guidage. 

• 

Le partage d'expériences via des plateformes en ligne offrirait des avantages considérables à 

peu de frais, néanmoins les efforts pourraient être mieux placés en améliorant l'utilisation des 

plateformes existantes plutôt que de créer un nouveau système de partage supplémentaire. 

vii 

 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

La limitation des exportations de déchets de l’UE vers les pays tiers se traduit par des résultats 

positifs (net) pour tous les déchets selon l’ampleur des restrictions imposées sur les matériaux 

ainsi que sur les pays tiers concernés. Alors que des coûts seraient encourus dans l'UE, en 

particulier en ce qui concerne le renforcement des capacités de gestion des déchets au sein de 

l'UE qui étaient auparavant exportés, les économies en termes de valeur économique des 

déchets conservés, les dommages environnementaux évités et l'emploi supplémentaire dans la 

gestion des déchets se traduisent par un résultat net positif pour les mesures évaluées. 

•  Une action supplémentaire visant à lutter contre la GED dans les pays tiers, à la fois par une 

clarification du règlement en ce qui concerne la GED, ainsi que par une évaluation de 

conformité supplémentaire au niveau de l'UE et en travaillant avec les parties prenantes de 

pays tiers via des groupes de travail et des organes partagés, réduirait la mauvaise gestion des 

déchets de l'UE à l'extérieur de l'UE tout en luttant davantage contre les expéditions illégales. 

viii 

 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

1  Introduction 

1.1  Purpose of this report 

Trinomics and Wood E&IS GmbH are pleased to present this report to the European Commission. The 

report constitutes the Final Report of the study ‘Exploration of potential policy options to review the 

Waste Shipment Regulation’.  

This report on waste shipments provides analysis to support the development of the European 

Commission’s Impact Assessment (IA) concerning revision to Regulation (EC) No 1013/2006 on shipments 

of waste (the WSR) as well as Commission Regulation (EC) No 1418/2007 concerning the export for 

recovery of certain waste listed in Annex III or IIIA to Regulation (EC) No 1013/2006 to certain countries 

to which the OECD Decision on the control of transboundary movements of wastes does not apply.  

The objective of the analysis is: 

“Taking into account the results of the evaluation report and other relevant information, the study 

will support the Commission in identifying options for the review of the WSR and explore their policy 

implications and potential impacts. These policy options could include a mixture of legislative 

measures (in particular amendments to the WSR) as well as non-legislative initiatives (such as 

guidance addressed to Member State authorities and stakeholders). The study is to provide as far as 

possible quantitative information to the Commission services on the potential impacts of various 

policy options compared to the business-as-usual scenario.” 

This report firstly provides an overview of the approach to the analysis (section 2). This is followed by a 

description of the existing waste shipment measures and results (section 3). Problems identified in 

relation to the legislation as it stands including a description of the baseline situation are presented 

(section 4) and, in turn, a description of why the EU should act is presented (section 5). The policy 

measures identified and examined are detailed (section 7) and the impacts of the options and measures 

are presented (section 8). The final conclusions for the draft final report are included in Section 9.  

1.2  Status of this report 

This report presents the final assessment by Trinomics and Wood E&IS GmbH of policy options to review 

the WSR.  

1.3  Taking into account the impacts of Covid-19 

The Commission has issued updated guidance on how to take into account the impact of Covid-19 in 

impact assessments. There are a number of questions to answer in relation to Covid-19 that we have 

separated from the main body of the report as addressed in the table below.  

Is the sector or policy area affected by 

The COVID 19 crisis has exposed the importance of waste shipments across the 

the COVID-19 crisis? How and to what 

EU: the measures taken by individual Member States, as a first response to the 

extent? 

crisis, to restrict the cross-border movements of commodities (including waste) 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

created difficulties for waste operators in different Member States who could 

not transfer their waste as before.  

As part of the initial response to the crisis some wastes that would, pre-crisis, 

have been shipped had to be stored prior to clarity being provided regarding the 

ability of these shipments to be completed. The threat of longer-term 

restrictions risked that such wastes would not be treated in the most effective 

manner according to the waste hierarchy and would instead be landfilled as 

there was no possibility to ship them to an alternative treatment facility in 

another Member State. 

The initial difficulties were alleviated after a few weeks, as recommended by 

the Commission in its specific guidance document1. However, the situation 

effectively demonstrated that the EU waste market is subject to a high level of 

integration in the EU – i.e. that the EU is generally the right scale for waste 

operations and that waste shipments in the EU should be treated in a manner 

which is different from waste shipments with 3rd countries. This is emphasised 

in relation to the volumes of such shipments as reflected in section 3 of this 

report that addresses the baseline for existing waste shipments. 

Few problems were reported concerning shipments to or from third countries 

due to the COVID 19 crisis. The export of textile waste to third countries was 

raised as an issue early on with some third countries retaining bans concerning 

the import of textile wastes from the EU. However, it is considered that such 

restrictions were not solely linked to the COVID-19 crisis as such measures had 

been in place in some of these countries already before the COVID-19 outbreak. 

What is the expected time span where 

In the case of those measures that increase the use of electronic systems it is 

these effects will be relevant? 

unlikely that there will be a desire for Member States to revert to paper-based 

systems. The other impacts, namely concerning volumes of health waste and 

crossing of borders are likely to remain relevant for the remainder of the Covid-

19 crisis, albeit it is expected that these issues will diminish in volume as the 

crisis is more effectively managed. 

Has the crisis affected the problem 

To a certain extent, particularly with regard to electronic procedures. 

definition? 

Which current changes will turn into 

See the points made above about electronic reporting systems, 

relevant long-lasting, structural changes 

of the ‘new normal’ in behaviour and 

economy? In addition, are these 

considered in the analysis? (e.g. 

teleworking, air traffic, e-commerce, 

health care pay, or bringing back 

overseas supply-chains and industry). 

How does the COVID-19 crisis affect the 

The expected impacts of the crisis on Electronic Data Interchange measures are 

policy options and their expected 

likely to be less positive as a result of more Member States having taken their 

impacts? 

own national initiatives. However, this does not negate the difficulties of the 

lack of interface between different Member State systems that will continue to 

be a problem under the baseline scenario. 

What measures enhance the resilience 

Provisions related to pressing public health needs requiring a temporary change 

of the sector or policy area? 

to full application of the WSR may be considered. This would be in keeping with 

the advice provided by the Commission in relation to Covid-19 already2. 

1 https://ec.europa.eu/environment/waste/shipments/pdf/waste_shipment_and_COVID19.pdf  
2 https://ec.europa.eu/environment/waste/shipments/pdf/waste_shipment_and_COVID19.pdf 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

2  Approach to the Analysis 

2.1  General approach 

The assessment presented in this report establishes the impacts of measures that may be used to 

address the challenges identified in the current EU legislative framework addressing shipments of 

waste. The method used for the analysis was as follows: 

• 

Identifying the challenges that require to be addressed through an examination of the results 

of the evaluation of the two main Regulations concerned supported by existing literature and a 

small number of interviews with stakeholders from Member States, industry and non-

governmental organisation. 

•  Defining the baseline in particular by considering: 

o 

Static aspects – the existing international framework for waste shipments, namely the 

Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and 

Their Disposal and the OECD Decision of the Council on the Control of Transboundary 

Movements of Wastes Destined for Recovery Operations (OECD/LEGAL/0266), the 

European Union framework for waste shipments (the WSR Regulation and Regulation 

1418/2007) and present indicators and trends in shipments addressing quantities of waste, 

destinations of wastes traded internationally and experiences to date in implementation 

including in relation to quality of data and illegal shipments. 

o  Dynamic aspects including scarcity of resources and environmental pressures, evolution 

and interaction of the WSR with other EU policies including circular economy policies and 

the European Green Deal as well as the measures applied in these countries concerning 

import of EU wastes. 

•  Defining policy objectives. These objectives were addressed during the inception phase of the 

study using input from the challenges identified above as well as the European Commission’s 

Inter-Service Group on this topic. 

•  Assessing the effect of possible measures to achieve the objectives. The effect of the 

objectives and measures has been assessed, using a specific modelling for those measures that 

would affect the flows of waste, and for those that cannot be modelled providing an 

explanation of the expected effects in relation to waste shipment procedures themselves. 

•  Modelling economic impacts. The effect of changes in both the nature of waste shipments and 

procedures applied to those shipments have been considered addressing the additional costs of 

applying new controls, the resulting impacts of changing waste flows from third countries to 

intra-EU movements and treatment as well as the potential savings to be made by simplifying 

existing measures. 

•  Modelling environmental impacts: In particular focussing on the environmental impacts of 

changes in waste management as a result of changes in destinations of wastes, impacts of 

reduced waste sent for disposal and impacts of reduced distance of transport of wastes. 

•  Modelling social impacts: in terms of the likely social impacts in relation to changes in waste 

flows within the EU including impacts on employment as well as the possible social impacts in 

third countries as a result of changes in flows of EU waste to those countries in terms of social 

impacts of poorly managed EU wastes abroad. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

2.2  Research methodology 

Research has been undertaken through literature reviews of existing research, public consultation, 

targeted interviews with a number of stakeholders and a stakeholder that took place on 23 and 24 

September 2020. 

In order to develop a quantitative model through which to assess the costs and benefits arising from 

some of the measures (generally those that impact on waste flow quantities) we have considered the 

approach applied by Eurostat to present waste shipment data and have tailored the approach to suit 

this study. To this effect, the model considers the broad categories of hazardous and non-hazardous 

waste in total, and then considers detailed effects for a selected number of wastes – namely plastics, 

glass, paper and cardboard, textiles, non-ferrous metals and ferrous metals. In choosing these waste 

streams the study looks to examine impacts on those wastes that generally comprise the largest 

proportion of recoverable and recyclable wastes that are currently sent from the EU to third countries. 

However, there may be other waste types for which the impacts that arise may be different.  

The baseline has been modelled to 2030, which reflects the target dates of other related legislation 

including the Waste Framework Directive, Packaging and Packaging Waste Directive and the Plastics 

Strategy. The implementation and impacts of the measures deemed relevant to address each measure 

have been modelled over the same time horizon. 

2.3  Assumptions 

This report assumes the following: 

• 

The waste shipment related aspects in the Multilateral Environmental Agreements (MEAs) that 

the Waste Shipment Regulation implements, namely the Basel Convention and OECD Decision, 

will remain largely unchanged from their present content until at least 2030. 

• 

The data held in the databases hosted on Eurostat that has been used to inform the study 

model is accurate. It is important to note that we have looked to use the most reliable data as 

part of this study and the sources used were agreed via conversation between the consultants, 

the European Commission (including the Joint Research Centre and Eurostat staff) and the 

European Environment Agency. 

Assumptions made in relation to individual policy measures are included in the description against each 

of the measures later in this report. 

2.4  Limitations 

This study is subject to the following limitations: 

• 

The report has been prepared over a limited time period and to a defined budget requiring a 

simplification of approach where necessary, including in relation to the model employed, not 

examining possible changes in waste flow at the individual ELoW code level. 

• 

There are instances when views from stakeholders seemed in contrast with hard evidence. 

Where such differences were encountered the approach taken to assessing impacts is further 

explained. 

• 

Determining the impacts of prohibiting waste shipments from the EU is not straightforward, 

with possible impacts of action at the EU level likely to intermingle with impacts of actions 

taken by third countries.  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

•  Not all changes can be monetised or quantified. In such cases changes are described 

qualitatively. 

• 

Some analysis has been undertaken at the EU27 level and not at the Member State level, which 

may increase the margin of error in results. 

2.5  Consideration of the Outermost Regions 

The outermost regions are islands, archipelagos and one land territory (French Guiana) located in the 

western Atlantic Ocean, the Caribbean basin, the Amazonian forest and the Indian Ocean with a 

combined population of 4.8 million citizens. 

The Outermost Regions face difficulties in relation to shipments of waste as a result of them being 

separated from the European Continent by thousands of kilometres. In its Communication of 20173, the 

Commission identified that waste management can be particularly challenging because of limited 

infrastructure for waste treatment, lack of economies of scale for waste collection, treatment and 

recycling. This situation is aggravated in some cases by a growing population and seasonal tourism 

peaks generating large amounts of waste. As a result, several outermost regions send waste to their 

mainland. The Communication also looked to consider introducing provisions to facilitate the shipments 

of waste from the outermost regions to neighbouring countries for treatment. 

A number of the measures foreseen under this report would assist in facilitation of shipments of waste 

from the outermost regions to neighbouring countries for treatment, including in relation to reduction 

of administrative burden, supporting reuse and recovery and addressing illegal shipments in third 

countries. However, there are also several measures included in this report under measure 2a that 

consider restricting export of EU wastes to third countries. The assessment performed has not included 

such restrictions for wastes from the Outermost Regions, recognising the difficulties such restrictions 

would have by effectively requiring the Outermost Regions to ship their wastes back to the EU. 

Consequently, whilst EU law and all the rights and duties associated with EU membership apply to the 

outermost regions in accordance with Article 349 of the Treaty of the Functioning of the European 

Union (TFEU), specific measures and derogations in EU can be applied to address the major challenges 

they face due to their remoteness, insularity, small size, difficult topography and climate, and 

economic dependence on a reduced number of products.  

3 COM(2017) 623 final https://ec.europa.eu/transparency/regdoc/rep/1/2017/EN/COM-2017-623-F1-EN-MAIN-PART-
1.PDF 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

3  Calculations performed in the analysis 

3.1  Introduction 

The analysis of policy options, particularly those relating to changes in waste flows, has required the 

analysis of several datasets. This section describes the main sources of data employed and the 

calculation applied to those sources in reaching the results contained in this report. 

3.2  Determining the weight and value of wastes subject to transboundary 

movements 

There is no single definitive source of information on waste movements both within the EU and 

between the EU and third countries. With this in mind, data has been extracted from the following 

sources: 

Notifiable waste 

According to the WSR, all hazardous waste as well as some non-hazardous but problematic waste 

streams and other kinds of waste defined in the regulation, must be notified to the authorities before 

being shipped across borders. Article 51(1) of the WSR states that, before the end of each calendar 

year, each Member State shall send the Commission a copy of the report for the previous calendar year 

which, in accordance with Article 13(3) of the Basel Convention, it has drawn up and submitted to the 

Convention Secretariat. 

The shipment notification application form used in the EU is included as Annex VII of the WSR. It asks 

for information on: 

• 

Basel Y-codes according to Annexes I and II of the Basel Convention (47 different code numbers 

are available, 45 of which concern hazardous waste); 

• 

detailed Basel codes according to Annexes VIII and IX of the Convention (120 code numbers are 

available, 60 of which concern hazardous waste); 

•  OECD codes (150 different code numbers are available, 60 of which concern hazardous waste); 

• 

European List of Waste codes (790 code numbers are available, 384 of which concern hazardous 

waste). 

The resulting dataset maintained by Eurostat is entitled env_wasship and has been used to examine the 

impacts of policy options in relation to shipments of notified wastes. Note that these impacts have 

considered changes in the tonnage of waste shipped. It has not been possible to determine a € value of 

notifiable wastes given the widespread variation in the types of waste materials addressed by this group 

of materials and no such € values are included in the calculations comprised in this report. 

Other wastes 

Not all wastes that are transported across boundaries are subject to notification. This poses problems in 

using the env_wasship dataset for determining the impacts of policy options on such wastes when 

movements of non-notifiable wastes are not addressed specifically by waste shipment data. An 

alternative approach, which has been applied in the case of this report, is to use information from the 

European international trade in goods statistics - COMEXT. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Comext is Eurostat's reference database for detailed statistics on international trade in goods. It 

provides access to: 

• 

• 

-  recent and historical data of the EU and its individual Member States 

-  statistics of a significant number of non-EU countries.  

Data is captured in two different ways within COMEXT: 

• 

Extrastat: data on trade in goods with non-EU countries collected by customs authorities and 

based on the records of trade transactions in customs declarations. The dataset on trade with 

third parties is considered particularly robust as it is based on all reported customs 

movements; 

• 

Intrastat: When the EU was created and the original member states became part of the EU 

Single Market, customs and border formalities were removed. The dismantling of customs 

clearances and controls within the EU meant it no longer was possible to obtain information 

about the movement of goods (i.e. dispatches and arrivals) between EU member states from 

customs documents. In order to address this gap in data the statistical system Intrastat was 

developed to replace the customs declarations and collect information directly from traders 

about dispatches and arrivals of goods among the Member States by collecting data directly 

from intra-EU trade operators once a month. 

There are a number of points in relation to Intrastat data in particular that may be considered 

shortcomings in the comprehensive nature of the data, albeit these shortcomings are considered minor 

in relation to the overall quality of the data available. These shortcomings include: 

• 

Businesses and private individuals that are registered for VAT purposes and that dispatch or 

receive goods are required to submit Intrastat declarations only if the dispatches or the 

arrivals exceed the relevant threshold. 

• 

The Intrastat system is based on EU Regulation No. 638/2004 (EU Regulation) and 

supplemented Commission Regulation (EC) No. 1982/2004, which implements the EU 

regulation. Since the main Intrastat rules are provided in the Regulation the rules should 

normally be applied uniformly across the EU. However, there are differences in 

implementation as some Member States provide guidelines on how the general principles in the 

Regulation should be applied in specific situations (e.g. commercial samples, return of goods, 

etc.). Consequently, these guidelines may produce different results for various situations in EU 

member states. 

• 

The authorities responsible for Intrastat reporting differ from country to country. Some 

Member States delegate oversight of Intrastat to their tax or customs authorities, others to 

their statistics office and still others to their national bank. The nature of reporting by each 

Member State may, therefore, vary in approach accordingly. 

The use of Comext data to determine shipments of waste is not without precedent. The data has been 

used by Eurostat in the development of a publication on exports of waste from the European Union. The 

publication includes a presentation of export and imports from/to the European Union of: 

• 

• 

Ferrous metal 

Paper 

•  Other wastes 

• 

• 

Plastics 

Copper, aluminium, and nickel scrap 

8 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

Textiles  

•  Wood 

• 

Animal and vegetable waste 

•  Municipal waste 

•  Glass 

• 

Precious metal scraps. 

Additionally, COMEXT not only includes information of the volume of materials traded but also their 

value. The value of the goods can be expressed in two ways: 

• 

The taxable amount or invoice value, which is the value to be determined for tax purposes in 

accordance with the EU VAT Directive (Directive 2006/112/EC); and 

• 

The statistical value, which is the value calculated at the national borders of the EU Member 

States. It is based on the taxable amount or, where applicable, the value replacing the taxable 

amount. It includes incidental expenses (freight, insurance) incurred in the case of dispatches 

for the part of the journey located in the territory of the EU member state of dispatch. In the 

case of arrivals, it is the part of the journey located outside the territory of the EU member 

state of arrival. The statistical value is said to be an FOB value (free on board) for dispatches, 

and CIF (cost, insurance, freight) for arrivals. 

Values are also allocated to the waste streams reported under Comext using these approaches. 

A challenge, in respect to the use of CN codes to identify waste shipments is that the CN categorisation 

does not sit neatly with Basel Codes, the ELoW and the Commission Notice on the ELoW as referred to 

above. The categorisation of CN codes by Eurostat has been used to develop the trade in recyclable raw 

materials by waste dataset (ENV_WASTRD). An examination of the codes used by Eurostat undertaken 

by Wood indicates that in certain cases the choice of CN codes to be used to identify wastes falling 

under the above broad categories may be difficult to justify. For example, the CN codes include a 

general category 3915 Waste, parings, and scrap of plastics. However, the category ‘plastics’ for the 

abovementioned publication includes rubber materials that fall under Chapter 40 of the CN codes and 

are typically not considered ‘plastic waste’ on the ground. Whilst the Commission Notice on ELoW 

includes single category that includes rubber and plastics, it is considered that the categories of rubber 

included in the Eurostat master file are likely to be broader and include materials that would not 

typically be considered as plastics waste in the context of the operation of the Waste Shipments 

Regulation. Consequently, for the purpose of determining the main wastes exported from the EU to 

third countries for this report a recategorisation of CN codes has taken place to ensure greater 

consistency between the categorisation of wastes under the WSR and CN codes for the following wastes 

that are the main waste flows modelled: 

• 

• 

• 

• 

Ferrous metals 

Paper 

Plastics 

Textiles 

•  Glass 

•  Non-ferrous metals (that includes copper; aluminium and nickel scrap as well as precious metal 

scraps). 

A full list of the CN codes used in the above categories is provided in Annex 4  of this report.  

9 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

An examination of the volumes of wastes exported from the EU to third countries covered by these 

categories and compared with 2014 data from DG TRADE on exports of non-hazardous waste4 the 

specific wastes identified and used in this study represent 89% of all exported non-hazardous wastes.  

How have these data been used in the assessment? 

An extract of data from both of the above datasets has been made that examines: 

• 

For notified waste the changes in waste flows by weight between 2010 and 2018 (taken from 

env_wasship). 

• 

For other wastes the change in waste flows by both weight and reported € value between 2004 

and 2019 (taken from Comext). 

In order to consider future changes in the wastes examined, a linear regression was applied with a 95% 

confidence interval up to 2030. Applying this, in particular in relation to plastic waste, leads to a 

potential miscalculation as a result of the recent dramatic changes in plastic waste flows from the EU 

to third countries, starting with the ban in China of imports of most plastic wastes that was followed by 

restrictions in other countries of the same or similar wastes. This impacted not only on the volume of 

plastic wastes shipped by weight but also by value. Whether this trend will continue is unclear, but it is 

apparent that stricter measures on plastic wastes are gathering momentum globally. To counter this 

possible miscalculation on waste values, for plastic as well as for other wastes, an alternative approach 

to considering changes in waste values from Comext is to consider secondary raw material or virgin 

market costs of those materials, recognising that trade in recyclable raw materials by waste reflects 

recyclables that should ultimately replace virgin materials in manufacturing processes.  

Virgin and secondary raw material prices used in these alternative calculations are shown in Table 1 

below. 

Table 1 Virgin and secondary material prices used in calculations of waste value 

Waste type 

Value applied €/t 

Source of value 

Plastic 

743 (primary) 

environmental and economic potential of plastic 

Extended producer responsibility: How to unlock the 

Glass 

52 (secondary) 

Paper and cardboard 

114 (secondary) 

packaging waste?5 

Eurostat recycling secondary raw material price 

indicator6 

Eurostat recycling secondary raw material price 

indicator7 

Textiles 

560 (secondary) 

Letsrecycle.com used textile prices 2019 

Non-ferrous metals 

• 

• 

• 

Copper 

Aluminium  

Brass 

5 368 (primary) 

1 603 (primary) 

2 300 (primary) 

World Bank Commodity Prices (January 2021) using 

2019 average market value 

Lapin Metallikierratys Oy market purchasing rates 

Ferrous metals 

140 (secondary) 

Letsrecycle.com ferrous metal prices 2019 

4 https://ec.europa.eu/trade/import-and-export-rules/export-from-eu/waste-shipment/  
5 Bassi et al. (2020) 
6 Eurostat (2020) https://ec.europa.eu/eurostat/statistics-explained/pdfscache/10844.pdf  
7 Eurostat (2020) https://ec.europa.eu/eurostat/statistics-explained/pdfscache/10844.pdf  

10 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

It should be noted that the predictions of volumes by weight have been retained from the Comext 

analysis. The only change is in relation to the value of the waste materials used in the report 

calculations, the results of what are shown alongside the results of the regression analysis described 

above. 

Furthermore, the use of virgin prices will overestimate the price of waste materials as the market value 

of wastes will not be equal to that of virgin materials.  

3.3  Determining economic costs and benefits 

Measures that change waste flows carry costs for complying with the changed regulatory regime. In 

these cases, the costs address administrative costs and waste management costs. 

Administrative costs have been calculated according to certain administrative burdens that either exist 

in the present WSR and would be reduced (for example in relation to the simplification or digitisation of 

notification procedures) or would be added to new types of shipments to improve their level of control 

(for example in relation to the addition of the PIC procedure for wastes that are currently not subject 

to such a provision). 

The costs of applying PIC have been applied as indicated in the table below. 

Table 2 Assessment of PIC costs based on the standard cost model 

Type of 

obligation 

Description of 

requested 

Target group 

action(s) 

Application of 

Paper based 

Member State 

Tariff € per 

hour 

Time (hour) 

Price per 

action 

individual 

assessment of 

competent 

20 

16.5 

330 

authorisation1 

PIC 

authorities 

Application of 

Electronic 

Member State 

individual 

assessment of 

competent 

20 

10.8 

216 

authorisation1 

PIC 

authorities 

Application of 

individual 

authorisation2 

Application of 

individual 

authorisation2 

Paper based 

completion of 

PIC 

documentation 

Electronic 

completion of 

PIC 

documentation 

Operators 

20 

24 

480 

Operators 

20 

16 

320 

1 Taken from the results of data collection in relation to Objective 1B – see Section Error! Reference source not found. for more details on the data used to determine these value 

2 Taken from the study supporting the Evaluation of the Waste Shipment Regulation, Trinomics 2019 

11 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Assumptions as to the size of shipments that would be subject to PIC have had to be made. IMPEL has 

previously considered that the average shipment size is 20 tonnes8. However, for some of the materials 

addressed by this assessment (ferrous and non-ferrous metals in particular) this value may be too low. 

Consequently, an alternative calculation using an average shipment size of 100 tonnes has also been 

included. In both cases, the assumption has been that each shipment is subject to PIC. For the purpose 

of determining the number of PIC notifications that would be required for wastes for which it is 

presently not the case, the calculation of costs constitutes the following: 

Using the 20-tonne shipment threshold - (Total tonnes of waste / 20) x administrative costs 

Using the 100-tonne shipment threshold – (Total tonnes of waste / 100) x administrative costs 

Waste management costs  

Changes to flows in waste that would previously have been shipped to third countries but would under 

new measures require treatment in the European Union have impacts in relation to waste management 

within the EU, predominantly in relation to the need for additional treatment capacity. 

Wastes that are subject to waste shipment are already subject to collection and source separation / 

material sorting prior to their shipment. It would, therefore, be inappropriate to include all of these 

costs in this assessment as those costs are already present in the baseline. However,  

further to material sorting, treatment costs for the wastes to transform them into usable products are 

relevant to be included. These are additional costs within the EU relating to the additional treatment 

capacity that would be required to treat those wastes compared to the baseline.  

The costs need to consider the capital expenditure and operational expenditure related to material 

sorting and treatment costs. Using calculations included in studies performed by the JRC, COWI, 

Eunomia and the European reference model on MSW these costs have been calculated on an annual 

basis per tonne. These costs are shown in Error! Reference source not found. below. 

Table 3 Material sorting and treatment costs applied in this study for determining  

Waste type 

Plastic 

Textiles 

Non-ferrous metals 

Ferrous metals 

Other 

Treatment cost per tonne 

121.91 

6503 

1181.54 

138.634 

135 

Sources of values 

1JRC, 2018, Sorting of co-mingled light packaging waste to maximise recycling yields for high quality 

output 

2The COWI, Eunomia 2019 - Study on investment needs in the waste sector and on the financing of 

municipal waste management in Member States gives a figure of €175 tonne for use in its modelling 

8 This is based on 15 million tonnes from 750 000 shipments of green-listed waste shipped from the UK (on average, 
20 tonnes per shipment). IEEP and IMPEL (2011) “Practicability and enforceability of the Waste Shipment 
Regulation”. https://ieep.eu/uploads/articles/attachments/8f937c27-86e2-47f0-8e9b-00e4b261b848/Final-WSR-
report.pdf?=63664509783  

12 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

whereas the European reference model on MSW management offers values for €100-105 tonne. A mid-

point value of €140 tonne has been applied for the purpose of this study. 

3COWI, Eunomia 2019 - Study on investment needs in the waste sector and on the financing of municipal 

waste management in Member States. The costs consider a textile reuse/recycling process based 

including sorting and grading, preparation for reuse for high and low value clothes/other items that 

require no further treatment, mechanical recycling to low quality recycled fibres and chemical 

recycling for high quality recycled fibres.  

4The European reference model on MSW provides treatment costs for non-ferrous metals (-€379/tonne) 

and ferrous metals (-€96 to –€177 tonne depending on the ferrous metal concerned (iron vs steel) – 

negative values indicating income from treatment. In order to determine the true treatment costs for 

this project the values indicated in the European reference model on MSW have been subtracted from 

the average ferrous metal (€275.13 tonne) and non-ferrous metal values (€1560.5 tonne (average of 

copper and aluminium prices)) reported using Comext data and as predicted for the period 2020-2030. 

5 The European reference model on MSW 

Waste transport costs  

Waste subject to shipment between countries are already transported and, therefore, transport costs 

exist under a business-as-usual approach. Some of the measures considered under this report would 

retain some of those wastes within the EU, thereby changing those transport costs.  

The most recent data from UNCTAD on sea transport provide an average cost of €466 per TEU9 for 

shipment to Asia from the EU (present prices are not representative of the average as a result of a 

present global shortage of shipping containers and so an average of the period 2010-2017 has been 

used). A 2015 Commission study on road rail shipping contain costs of between €176 and €630 per TEU 

shipped across the EU10. Determining what waste would go where within the EU is not possible with 

present data – some Member States may continue to ship wastes to more distant Member States, some 

may ship to neighbouring countries and some may retain wastes within their own territory. For the 

purpose of this assessment we have considered that future shipment under these measures would most 

likely take them form of transport between neighbouring countries. On average, compared to the costs 

of shipping wastes to third countries we have estimated savings of around €290 per TEU - equivalent to 

€24 per tonne of waste. 

3.4  Determining social costs and benefits 

There are two large social impacts stemming from some of the measures foreseen under this report: 

• 

those related to additional employment within the EU as a result of wastes formerly exported 

to third countries being retained within the EU. 

• 

those related to the social impacts, including both employment and impacts on standards of 

living for people living in the third countries to which EU waste is presently shipped. 

In order to calculate the employment impacts of retaining wastes within the EU an assessment of 

existing data has been undertaken. A report published by the Scottish Government provided an 

9 UNCTAD (2018) https://unctad.org/system/files/official-document/rmt2018ch3_en.pdf  
10 European Commission (20150 
https://ec.europa.eu/transport/sites/transport/files/themes/strategies/studies/doc/2015-01-freight-logistics-lot2-
combined-transport.pdf  

13 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

estimation of waste industry employment using four main sources, the results of which for wastes 

assessed under this specific objective are provided below. 

Table 4 Calculation of full time equivalent (FTE) employment related to waste management within the EU for 
certain categories of waste 

 Sources11 12 13 14   

Calculation of the employment impacts resulting from the retention of wastes have used the FTE/tonne 

figure in the right-hand column. 

The social impacts, including both employment and impacts on standards of living for people living in 

the third countries to which EU waste is presently shipped are difficult to calculate. It is assumed that 

the impacts on third country employment in the countries that presently receive EU wastes is likely to 

be much higher in FTE terms than the benefits shown for the EU in terms of additional employment. 

This is as a result of the more efficient waste management and more automated systems employed in 

the EU in comparison to a majority of the third countries to which waste is exported. 

The negative social impacts in terms of living conditions impacted by EU wastes in third countries would 

generally be reduced where EU wastes are no longer exported to those countries. By way of example, 

the Greenpeace report ‘The Recycling Myth 2.0 – the toxic after effects of imported plastic waste in 

Malaysia15’ noted that visits to one dumpsite contained large amounts of plastic waste piles from 

numerous countries including waste from Germany, Spain and Scandinavia with an examination of the 

waste revealing mainly non-recyclable plastic, in addition to other scraps including e-waste (e.g. plastic 

cases or circuit boards from electronic devices). Signs of open burning indicated attempts to dispose of 

evidence of the type of wastes discarded at the dumpsite by burning them. A restriction of wastes sent 

to such third countries would undoubtedly reduce the volumes of materials dumped and open-burned in 

such a manner, having a positive impact on the social wellbeing on people in proximity to such waste 

sites. It is not, however, possible to determine the quantitative value of those changes. 

3.5  Determining environmental benefits 

There are a number of environmental benefits that are likely to stem from some of the measures 

considered in this report. These are further explained below. 

11 Gray et al. (2004)  
12 Cascadia (2009) https://kingcounty.gov/~/media/depts/dnrp/solid-waste/linkup/documents/recycling-economic-
development-review.ashx?la=en  
13 Friends of the Earth (2010) 
https://www.foeeurope.org/sites/default/files/publications/foee_more_jobs_less_waste_0910.pdf 
14 Eunomia (2014)  
15 Greenpeace (2020) https://www.greenpeace.org/static/planet4-southeastasia-stateless/2020/06/4dbab0db-the-
recycling-myth-2.0-the-toxic-after-effects-of-imported-plastic-waste-in-malaysia.pdf  

14 

Gray et al. 2004Cascadia (2009)FOTE (2010)Eunomia (2014)AverageFTEs/tonnePaper3518181822.30.002225Textiles5085505058.80.005875Plastic156939393108.80.010875Glass7.5267.57.512.10.0012125Aluminium110110110110.00.011Iron&steel54544350.30.005033333SourceFTEs/10,000 tonnes of waste per annum 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Environmental impacts of landfill and incineration in the EU and in third countries 

Waste shipments are made for a variety of reasons but are predominantly made in relation to material 

reuse and recovery. However, not all wastes that are shipped for such purposes are able to be reused or 

recycled and a proportion of the materials shipped will fall lower down the waste hierarchy. In such 

cases these materials will either be sent for recovery through incineration or uncontrolled disposal, 

mainly consisting of open dumps and open burning. For the purpose of the calculations made in this 

report, we assume that 1) the quantity of material recycled and the corresponding process losses would 

be the same if the waste was retained within the EU (i.e. no differences in efficiency between EU and 

third countries); we also assume that 2) the environmental impact (burdens and savings of primary 

virgin materials) of such recycling operations would be the same in EU and third countries (i.e. no 

differences in environmental control of emissions between EU and third countries). This means that 

ultimately, we only account for the different impacts associated with the management of the rejects 

generated during the recycling operations. On this basis, in calculating the environmental benefits 

stemming from management of the rejects within the EU in comparison to third countries, the 

performance of EU treatment facilities in comparison to third country management (e.g. open dumps 

and open burning) has been quantified using the available scientific literature and datasets.  

The first part of the calculation requires an estimation of rejection rates for the different wastes 

shipped. These vary by material. The rejection rates for the main wastes assessed under this study are 

shown in Table 5, including the source of the figures concerned. 

Table 5 Rejection rates for certain types of waste used in calculations 

Waste type 

Residue 

Source of value 

percentage 

Glass 

8% 

Eunomia 2019 - Study to support the implementation of reporting obligations 

resulting from the new waste legislation adopted in 2018 

Plastic 

30% 

Eunomia 2019 - Study to support the implementation of reporting obligations 

resulting from the new waste legislation adopted in 2018 

Paper and 

10% 

Eunomia 2019 - Study to support the implementation of reporting obligations 

cardboard 

resulting from the new waste legislation adopted in 2018 

Textiles 

10% 

Norup et al 2019 - Evaluation of a European textile sorting centre: Material flow 

analysis and life cycle inventory 

Non-ferrous 

19% 

Eunomia 2019 - Study to support the implementation of reporting obligations 

metals 

Ferrous 

metals 

resulting from the new waste legislation adopted in 2018 

19% 

Eunomia 2019 - Study to support the implementation of reporting obligations 

resulting from the new waste legislation adopted in 2018 

With the above rejection rates applied a comparison or reject management in third countries in 

comparison to the EU needs to be considered. In this case the impacts of the open dumping or open 

burning in third countries of those rejects in comparison with energy recovery in the EU (except for 

glass and metals that have been calculated according to landfilling in the EU as incineration would not 

be applied to these materials. To identify these differences, the dedicated waste LCA-model 

EASETECH16 used, among the others by JRC has been used applying the datasets describing open dump 

and open burning activities for individual waste materials (plastic, glass and similar inert, and 

16 Clavreul et al. (2014) https://www.sciencedirect.com/science/article/pii/S1364815214001728  

15 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

paper/cardboard) as provided by the latest ecoinvent 3.7 database17. In the absence of specific dataset 

for textile, the impact of textile waste has been approximated as a mix of plastic (15%) and 

paper/cardboard (85%) based on the assumption that ca. 15% of the textile is composed of biological 

fibres while the rest is synthetic (Riber et al., 200918). The impact of open dump and burning of metals 

has been approximated with that of glass, both being inert materials, in the absence of specific 

datasets.  

The impact of landfilling and incineration in EU has been obtained using the same tool but applying 

typical datasets for EU landfills and incineration (Manfredi & Christensen (2009); Manfredi et al. (2010); 

Manfredi et al. (2011)19. Notice that these, on top of the environmental emissions associated to the 

treatment itself, also include the downstream environmental savings obtained through energy recovery 

(i.e. incineration generates as co-products electricity and heat that are assumed to displaced the 

average EU electricity and heat production mix). The substituted mix of electricity and heat follows the 

logic applied in similar recent studies (Tonini et al., 202120; Nessi et al., 202021) and in the Product 

Environmental Footprint and represents the current situation of the EU energy system. The pricing of 

environmental emissions is based on the CE Delft Environmental Prices Handbook EU 28 version as is the 

case of transportation externalities detailed later on. The report provides a state-of-the-art dataset of 

the shadow prices of environmental emissions, i.e. the external costs of emissions that are not 

monetised in the current market/financial prices (also known as externalities or shadow prices as 

opposite to financial prices; e.g. CO2 has a price of 57 EUR/t). 

Determining the amounts of waste that would be subject to open burning or open dumping in third 

countries 

While there is no definitive source of data that reflects on the amounts of waste subject to open 

burning or open dumping in third countries, scientific sources estimate that about 40% of the waste 

globally generated is subject to open-burning22 23, mainly in developing and populous countries (China, 

India, Brazil, Mexico, Pakistan, and Turkey). Open burning occurs for many reasons, e.g. to get rid of 

waste in residential areas/streets, in open-dump sites (e.g. to free space for dumping more waste) as 

well as because of natural firing occurring in uncontrolled open dumpsites. It is clear according to the 

materials collected during this assessment that both take place.  

An examination of the likely destination of rejects for the waste types considered under this study 

indicates that landfilling of waste represents by far the largest method of disposing of wastes. By way 

of example: 

•  With Malaysia and Turkey as the largest countries of destination of plastic waste in 2019 and 

recognising that according to the World Bank24 landfill represents the largest waste disposal 

17 https://www.ecoinvent.org/  
18 Riber et al. (2009) https://www.sciencedirect.com/science/article/abs/pii/S0956053X08003322   
19 Manfredi & Christensen (2009) https://www.sciencedirect.com/science/article/abs/pii/S0956053X08000767;  
Manfredi et al. (2010) https://www.sciencedirect.com/science/article/abs/pii/S0956053X09003717;  
Manfredi et al. (2011) https://www.sciencedirect.com/science/article/abs/pii/S0921344911000929  
20 Tonini et al. (2021) https://link.springer.com/article/10.1007/s11367-020-01853-2  
21 Nessi et al. (2020) https://eplca.jrc.ec.europa.eu/plasticLCA.html  
22 Wiedinmyer et al. (2014) https://pubmed.ncbi.nlm.nih.gov/25019173  
23 Cogut (2016) https://regions20.org/wp-content/uploads/2016/08/OPEN-BURNING-OF-WASTE-A-GLOBAL-HEALTH-
DISASTER_R20-Research-Paper_Final_29.05.2017.pdf  
24 World Bank (2020) What a Waste Global Database - Country level dataset 
https://datacatalog.worldbank.org/dataset/what-waste-global-database/resource/de74cc68-e796-4e42-9793-
f140719c91ac#{view-
graph:{graphOptions:{hooks:{processOffset:{},bindEvents:{}}}},graphOptions:{hooks:{processOffset:{},bindEvents:{}}}}  

16 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

activities in both countries, is assumed that all plastic waste is sent to landfill in third 

countries. 

•  With India, Indonesia and Turkey as the largest countries of destination of paper waste in 2019 

and recognising that according to the World Bank25 landfill represents the largest waste 

disposal activities in both countries, is assumed that all paper waste is sent to landfill in third 

countries. 

• 

Textiles are exported from the EU to a great many countries in comparison to other waste 

types. Landfill is also considered as the most likely destination of rejected textile wastes. 

•  Metal wastes generally follow the same paths of destination with the countries listed above 

playing a significant role in the receipt and management of EU metal wastes. 

To determine the ratio between open dump and open burning, we here assume that 60% of the reject 

material is subject to open dump and 40% to open burning. This ratio is applied consistently across all 

materials investigated, as dumping/burning would take place regardless of the nature of the material 

(dump sites consist of a mix of heterogeneous waste materials).  

The first calculation, therefore, relates to the emissions resulting in third countries resulting from 

waste management per tonne. The relevant extract from the JRC model is shown in Table 6. 

Table 6 Third country environmental impacts from waste management per tonne managed  

The second calculation considers the emissions resulting in the EU resulting from waste management 

per tonne. The relevant extract from the JRC model for these activities is shown in Table 7. 

Table 7 EU environmental impacts from waste management per tonne managed. 

25 World Bank (2020) What a Waste Global Database - Country level dataset 
https://datacatalog.worldbank.org/dataset/what-waste-global-database/resource/de74cc68-e796-4e42-9793-
f140719c91ac#{view-
graph:{graphOptions:{hooks:{processOffset:{},bindEvents:{}}}},graphOptions:{hooks:{processOffset:{},bindEvents:{}}}}  

17 

GHG emissionsExternalitiesAmount sent to open dumpAmount subject to open burningWaste typekg CO2-Eqeuro%%glass (inert)12913.006040ferrous metals (inert)12913.006040non-ferrous metals (inert)12913.006040paper/cardboard13452406040plastic11053776040textiles11513086040 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

By considering these two tables, a calculation of the net costs or benefits of managing rejects in the EU 

in comparison to third countries has been made. The results of this are shown in Table 8 below and 

have been used in calculating environmental externalities relating to on site waste management for the 

wastes assessed. Savings in this table are shown as positive numbers, with burdens shown as negative 

numbers.  

Table 8 Calculations applied to assess the net environmental benefits resulting from waste management 
activities in third countries in comparison to the EU (per tonne managed). 

Emissions from shipping 

A calculation of the external environmental damage resulting from GHG and other pollutants to air from 

shipping of waste to third countries has been performed. The calculation has entailed the following. 

1.  Determination of the destination of EU wastes – As noted in Section 4 of this report, in 

determining the baseline for the report the top ten destination countries for each specific 

waste type considered – ferrous metals, non-ferrous metals, plastic, glass, paper and 

cardboard and textiles has been performed. The countries identified have then been 

categorised according to the general geographic locations to determine distance travelled 

using information from the Institute of transport and maritime management Antwerp 2009 

study undertaken by Notteboom and Cariou . Antwerp represents a good measuring point for 

determining distance given the large quantity of materials, including waste, shipped from the 

port and its close proximity to Rotterdam, the largest port involved in such shipments. These 

categories take into account the average nautical miles for trips to Africa, Far East, 

India/Pakistan, Latin and South America, Near East/East Med, North America and Oceania. The 

distances include deviation distance to call at en-route ports of call on liner service. This avoid 

the use of simple straight-line distances of travel that are not reflective of actual shipping 

practices. The values used are included in the table below. 

Table 9 Distances used to determine distances travelled from the EU to third countries broken down into 
regions 

2.  Determination of the emissions resulting from ship transport – The EMEP/EEA air pollutant 

emission inventory guidebook provides emission factors for 20 pollutants for use of bunker fuel 

18 

GHG emissionsExternalitiesWaste typekg CO2-Eqeuroglass (inert)12913.00ferrous metals (inert)12913.00non-ferrous metals (inert)12913.00paper/cardboard1837.0211.0plastic38.0394.0textiles1701.0285.0Region of port of dischargeObservationsAverage one-way distance (a)Average transfer time (in days) (b)Average vessel sizeno.nmdaysTEUAfrica154731172525Far East2411183287563India / Pakistan97165213963Latin and South-America235765173700Near East / East Med173488133535North America125096173242Oceania713136432922 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

and marine diesel oil per tonne of fuel. To determine emissions based on distance rather than 

fuel use information on fuel consumption has been taken from the Notteboom and Cariou study 

to determine fuel used and, therefore, emissions resulting against the same regions indicated 

in Table 39 above. In order to determine average ship emission, recognising the two different 

types of fuels have different emissions factors, information from the Fourth IMO GHG Study 

2020 – Final report has been used that addresses the general breakdown of use of the two main 

fuel types with the emission factors applied under this study to proportion emission factors 

correctly with heavy fuel oil representing by far the largest quantity of fuel used in comparison 

to bunker fuel as shown in the Figure below. 

Figure 1 Top-down ship fuel consumption data used in two studies (million tonnes) 

3.  Determination of the damage cost functions to be applied to the emissions – The CE Delft 

Environmental Prices Handbook EU 28 version 2018 contains damage cost functions for 

seventeen of the twenty pollutants addressed in the EMEP handbook. The central values in 

EUR/kg have been applied for those seventeen pollutants26. 

4.  Combination of the above sources to provide emissions per tonne of material shipped based on 

the main regions of destination of the wastes concerned. The information sources highlighted 

above note a difference in expected emissions based on the size of vessel, generally described 

according to the twenty-foot equivalent unit (TEU) container. In order to simplify the 

calculation, and recognising that emissions for ships <8000 TEU tend to be similar, whilst larger 

8000+TEU ships generally result in lower emissions per TEU two different DCFs have been 

determined for these two different ship sizes as shown in  

26 The pollutants concerned are Zn, PM10, PM2.5, Ni, Pb, Cd, As, Cu, PCB, PCDD/F, NOx, Hg, Sox, Cr, CO and CO2. 

19 

 
  
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

5.  Table 10 below. 

20 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 10 Environment damage determined in EUR per tonne of material shipped in respect to GHG and air 
emissions by destination 

As it is not possible to determine the size of ships actually undertaking the journeys that transport EU 

waste, an average of the two costs have generally been applied and is considered to be the most 

representative approach to determining the costs of emissions by destination. In terms of categorising 

individual third countries, emissions to Turkey, by way of example, have been captured under Near East 

/ East Med, whereas emissions to China are captured under Far East. It is apparent from the figures 

under Table 47 that the further a material travels, the greater the environmental damage resulting 

from its transport. 

The results of the calculations in Table 10 have subsequently been applied in the calculation of shipping 

externalities avoided in the environmental assessment of measures 2a2 to 2a6. 

21 

<8000 TEU8000+ TEUAfrica5647Far East132111India / Pakistan8571Latin and South-America6857Near East / East Med4135North America6051Oceania155131Size of container shipDestination 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

4  What is the problem with the existing EU 
waste shipments regime and why is it a 
problem? 

4.1  What have we learned from experience to date in the implementation of 

the WSR and Regulation 1418/2007? 

The WSR must not only ensure protection of the environment in relation to shipments of waste but also 

forms the main legislative instrument through which the EU meets its commitments under multilateral 

environmental agreements. As indicated in the ex-post evaluation report of the WSR and Regulation 

1418/200727 both Regulations have generally been effective in controlling the potential negative 

impacts from uncontrolled waste shipments. However, there was also evidence of challenges in relation 

to the legislation that both hindered its effectiveness directly in terms of waste shipments but also 

hindered its effectiveness in contributing to other policies, most notably in relation to the circular 

economy. 

The Commission has issued three reports to the European Parliament and the Council as part of the 

requirements of Article 51 of the Regulation covering the implementation of the WSR28. Common 

features identified in those reports (and supported by other studies as referenced against the relevant 

problems) were: 

•  Data quality – Discrepancies have been identified in relation to quantities of waste reported by 

countries of dispatch and countries of destination. For example, in its report of 2012 to the 

Council and the Parliament the Commission noted that in 2009 the difference between 

reported exports provided by Member States of hazardous waste and reported imports from the 

Member States of receipt was about 27%. In relation to other notifiable wastes the opposite 

was the case with the reports of imported other notified wastes being 36% higher than exports 

of the same wastes; 

• 

Classification of wastes – Despite the sharing of experiences between Parties to the Basel 

Convention on the use of Basel codes for the classification of waste and similar experience 

sharing between EU Member States on the use of European Waste List Codes the classification 

of waste remains inconsistent across the EU; 

• 

Illegal shipments – Despite improvements in inspection practices across Member States, 

including those expected from 2016 as a result of Regulation (EU) No 660/2014, the level of 

shipments of waste in violation of the WSR appears to remain relatively high. In its latest 

report on the ‘Enforcement of the European Waste Shipment Regulation’29 the European Union 

Network for the Implementation and Enforcement of Environmental Law (IMPEL) found that as 

part of 3 060 waste shipments inspected in 2016, 1 020 (33.4%) were in violation of the WSR. In 

2017 of 2 766 waste-related transport inspections 853 (30.8%) were in violation of the WSR. Of 

27 SWD(2020) 27 final 
https://ec.europa.eu/environment/pdf/waste/shipments/SWD_2020_27_F1_SWD_EVALUATION_EXECUTIVE_SUMMAR
Y_EN_V3_P1_1064542.pdf  
28 COM(2012) 448 final https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2012:0448:FIN:EN:PDF  
COM(2015) 660 final https://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-660-EN-F1-1.PDF  
COM(2018) 762 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52018DC0762  
29 IMPEL (2018) https://www.impel.eu/wp-content/uploads/2019/01/FR-2018-04-Enforcement-Actions-project-2016-
2017.pdf 

23 

 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

the 2016 inspections undertaken on roads or at ports over 2014-2015 related to waste 

shipments over 16.6% were in violation of the WSR. These values show a deterioration with 

increasing violations identified in comparison to previous reports issued in 2012 and 2014-2015. 

•  Volumes of waste shipped – the volumes of waste shipments have continued to demonstrate 

an upward trend from the introduction of the WSR in 2006. The latest implementation report 

by the Commission published in 2018 indicated that the EU as a whole did not appear to be 

closer to self-sufficiency in treating either all notified waste or specifically hazardous waste 

than it was in 2001. While the percentages of both waste types shipped within the EU have 

varied over the past 15 years, in 2015 both remained slightly lower than they were in 2001 (92% 

compared with 93% for all notified waste and 91% compared with 95% for hazardous waste). 

• 

Reporting by Member States – Compliance with reporting deadlines continues to demonstrate 

differing performance by Member States. Given that the reporting has consequences in relation 

to submissions to the Basel Convention Secretariat the implications fall beyond the European 

Union’s borders, potentially affecting the EU’s reputation with international partners. 

However, such reporting also carries important administrative burdens for operators, 

competent authorities, national administrations and the Commission in terms of the collection 

of documentation. 

4.2  What problems did the evaluation of the WSR and Regulation identify? 

The results of the evaluation of the WSR and Regulation 1418/2007 are addressed in the Commission 

Staff Working document issued in January 202030. The evaluation noted that the WSR has been 

successful in establishing a robust legal framework for both intra- and extra-EU shipments of waste, 

that it has been generally well implemented by Member States and has led to a better control of 

shipments of waste and the environmentally sound management of shipped wastes. However, the 

evaluation identified that various problems remain, predominantly under three main themes: 

With regard to intra-EU shipments of waste, different levels and manners of applying and enforcing 

the WSR, often combined with diverging interpretations of its provisions, result in suboptimal 

implementation throughout the EU. Clear examples are the different classifications across Member 

States of the same waste, or the different application of procedural delays or means of interchanging 

documents, with some competent authorities allowing for electronic exchange more leniently than 

others. This results in delays in and burdens on shipments of wastes across the EU, despite the fact that 

in many cases waste flows are of good quality and are being shipped for the purpose of proper 

recovery. This also impacts on exports from the EU to third countries.  

Additionally, it was identified that whilst in 2018 a substantial part of EU waste acquis was substantially 

amended to enhance its contribution to a circular economy (e.g. more ambitious recycling rates), the 

WSR was not. The WSR as it stands does not clearly reflect the need to favour recycling (and 

preparation for re-use) over other recovery operations (like incineration), so that in this respect it is 

not fully aligned with the rest of the existing EU waste legislation and other policy. Finally, the use of 

paper-based systems of notifications remains high and, thereby, has failed to capitalise on the benefits 

of digitalisation of processes that both reduces burden as well as stimulating innovation. 

30 SWD(2020) 26 final 
https://ec.europa.eu/environment/pdf/waste/shipments/SWD_2020_26_F1_SWD_EVALUATION_EN_V4_P1_1064541.
pdf  

24 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

Difficulties for competent authorities of the EU Member States to verify that waste exported 

outside the EU is managed in an environmentally sound manner in the importing country. 

Furthermore, while Regulation (EC) No 1418/2007 regulating exports of non-hazardous wastes 

to non-EU, non-OECD countries has contributed to the achievement of the WSR’s environmental 

objectives, in its current from it suffers from a slow and very resource intensive update 

mechanism.  

This is the case especially for export of wastes outside the EU, in particular to developing 

countries.  

• 

Illegal shipments of waste and illegal treatment of legally shipped waste in third countries 

remain a considerable problem. The persistence of illegal waste shipments is inter alia due to 

the fact that competent authorities in Member States often lack comparable resources and 

that Member States do not cooperate sufficiently with each other, or in a coordinated way pan-

European. Illegal shipments find the path of least resistance to get through or leave Europe. 

There are also illegal shipments of wastes within the EU, linked to activities of organised 

criminal networks. These difficulties remain despite the efforts to address enforcement and 

compliance shortcomings in a revision to the WSR that was made in 2016. 

These problems are expanded upon further in section 4.4 below. 

4.3  Summarising the current challenges and translating them into objectives 

The ex-post evaluation sits alongside a number of other earlier studies and reports that identified 

challenges in the functioning of the WSR. This includes two Commission Reports issued to the European 

Parliament and Council as part of the requirements of Article 51 of the Regulation covering the 

implementation of the Regulation overall31, as well as a report on “The efficient functioning of waste 

markets in the European Union - legislative and policy options32”. The latter report has several 

conclusions of relevance to this project.  

Furthermore, interactions with the correspondents for the implementation of the WSR (commonly 

referred to as the Waste Correspondents) fed into both guidance that has assisted in the 

implementation of the Regulation as well as identifying aspects of the Regulation that are problematic. 

Finally, a number of initial targeted interviews with stakeholders under this study has looked to confirm 

the scope of this study and the challenges to assess in more detail. 

31 COM(2012) 448 final https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=COM:2012:0448:FIN:EN:PDF  
COM(2015) 660 final https://ec.europa.eu/transparency/regdoc/rep/1/2015/EN/1-2015-660-EN-F1-1.PDF  
COM(2018) 762 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=CELEX%3A52018DC0762 
32 European Commission (2016) https://op.europa.eu/en/publication-detail/-/publication/8bc74556-433c-11e6-
9c64-01aa75ed71a1 

25 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The resulting list of challenges and resulting objectives to be achieved in relation to the review of the Regulation are as follows: 

Challenge One – Shortcomings in Intra-EU shipments of waste 

General Objective One - Ensuring a smoother functioning of the EU 

internal market for waste and supporting the transition to a circular 

economy 

• 

Heavy administrative burden – in particular, concerning long and often paper-based 

administrative procedures related to notifications, the burden related to financial guarantees as 

Specific objective – simplify and reduce administrative burden for intra-

well as in relation to pre-consented facilities. 

EU shipments of waste 

• 

Lack of harmonisation of interpretation, application and enforcement across Member States - 

including a lack harmonisation of waste definitions, inconsistency of approaches with regard to 

end-of-waste criteria across the EU and the subsequent application of WSR provisions to those 

materials that are dependent on those approaches, as well as some lack of clarity in some of the 

terminology used in the Regulation. 

Specific objective – harmonise interpretation, application and 

enforcement across Member States 

• 

Lack of coherence with other EU legislation – with a particular concern resting on the issue of 

controls for mixed wastes and classifications across several pieces of legislation (most notably 

concerning the ELoW, customs codes, the Basel Convention and OECD Decision codes). 

• 

Poor alignment of the WSR with the waste hierarchy – there is no particular incentive in the WSR 

to promote shipment of waste destined to operations up in the waste hierarchy (like preparation 

for re-use or recycling), compared to other operations (like incineration or landfilling).There are 

Specific objective – Align shipments with the waste hierarchy and 

regular tensions around shipments of waste for landfilling or incineration from one Member State 

existing EU legislation 

to another one, with complaints in the importing country that this is not a sustainable practice 

and is not consistent with the proximity and self-sufficiency principles.  

Failure of the WSR and Regulation 1418/2007 to better adapt to technical progress and stimulation of 

Specific objective – Better adapt to technical progress and stimulation 

innovation. 

of innovation 

Challenge Two –Poor application of environmentally sound management of EU waste shipped to 

General objective Two – Better guarantee waste shipped outside the EU 

third countries 

are managed in an environmentally sound manner 

26 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

Export of waste from the EU to third countries leading to detrimental environmental and public 

health consequences in the importing countries, whilst representing a loss of resources and 

Specific objective – ensure ESM of wastes by reducing or stopping the 

making EU operators dependent on the import policies of third countries.  

export of wastes to countries where ESM cannot be guaranteed  

• 

The ability to verify that wastes exported to Third Countries are subject to environmentally sound 

management under the WSR is subject to a jurisdictional boundary that lies at the EU’s borders. 

The reliance on the provisions concerning environmentally sound management in third countries 

Specific objective 2b – verify ESM in destination countries 

without the ability to verify that this has actually been the case is problematic and relies heavily 

on goodwill on both the exporters and importers side. 

• 

Better classify shipped waste as hazardous or mixed/ contaminated – linked to the issue of 

harmonisation of interpretation and coherence under Challenge One above, it is considered that 

See challenge one above and specifically harmonisation of 

presently the classification of waste as hazardous, particularly in the case of mixed or 

interpretation, application and enforcement across Member States 

contaminated wastes leads to different decisions being made across the EU affecting shipments 

both extra-EU and intra-EU.  

Challenge Three – Illegal shipments of waste 

General objective 3 – Better prevent and address illegal shipments of 

• 

Despite the previous amendments to strengthen provisions on enforcement and inspections in the 

waste 

WSR in 2016 there remain challenges in respect to such activities within the EU that hamper the 

Specific objective – Improve enforcement and inspections within the EU 

fight against illegal waste shipments (as reflected in the latest IMPEL figures on illegal shipments 

reflected earlier in this report). 

• 

A perceived lack of prioritising efforts to address illegal shipments of waste at the EU and 

Specific objective– Increase efficiency in the fight against illegal 

national level and a lack of coordinated efforts with third countries concerning such shipments. 

shipments of waste at EU and national levels and Improve enforcement 

and inspections in third countries 

27 

 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

5  Existing Waste Shipment measures – defining 

the baseline 

5.1  Introduction to the existing waste shipment policies  

  Rationale for controlling waste shipments 

Shipments of waste have been a concern to society for decades. However, their potential harm was 

first highlighted as a result of several high-profile events, particularly in the 1970s and 1980s including 

mislabelled waste ending up in unsuitable destinations and being left to deteriorate, thereby polluting 

the environment and threatening human health as well as several examples of wastes moving from port 

to port without seeking permission for exports of waste in the first place. 

Action in relation to waste shipments in the context of multilateral environmental agreements has 

taken three forms: 

The Basel Convention  

Following on from the United Nations Environment Programme prioritising the control of waste 

shipments to mitigate their environmental impacts in 1981, the negotiations for the elaboration of a 

global convention on the control of transboundary movements of hazardous wastes commenced. 

Negotiations concluded in March 1989 with the adoption of the Basel Convention on the Control of 

Transboundary Movements of Hazardous Wastes and their Disposal (the Basel Convention). The 

Convention entered into force on 5th May 1992. Covering a wide range of wastes defined as “hazardous 

wastes” based on their origin and/or composition and their characteristics, as well as three types of 

wastes defined as “other wastes” - household waste, some plastic waste and incinerator ash, the 

Convention has the following three main aims: 

1.  Reducing hazardous waste generation and the promotion of environmentally sound 

management of hazardous wastes, wherever the place of disposal. In the context of the Basel 

Convention environmentally sound management means taking all practicable steps to ensure 

that […] wastes are managed in a manner which will protect human health and the 

environment against the adverse effects which may result from such wastes; 

2.  Restriction of transboundary movements of wastes except where it is perceived to be in 

accordance with the principles of environmentally sound management; 

3.  A regulatory system applicable where transboundary movements are allowed. The regulatory 

system is based on the concept of prior informed consent. It requires that, before export may 

take place, the authorities of the State of export notify the authorities of the prospective 

States of import and transit, providing them with detailed information on the intended 

movement. The movement may only proceed if all States concerned have given their written 

consent. In the event of a transboundary movement of hazardous wastes having been carried 

out illegally, or where it cannot be completed as foreseen, the Convention attributes 

responsibility to one or more of the States involved, and imposes the duty to ensure safe 

disposal, either by re-import into the State of generation or otherwise. 

Most recently, the Basel Ban Amendment entered into force (05 December 2019). The Ban Amendment 

prohibits the export of hazardous wastes from Member States of the European Union, OECD and 

Liechtenstein to all other countries. For the purpose of data on hazardous waste shipments, the most 

29 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

recent reported year of which is 2018, the impact of this amendment has not been reflected in Member 

State reports.  

Finally, the Basel Convention also provides for cooperation between Parties, ranging from exchange of 

information on issues relevant to the implementation of the Convention to technical assistance, 

particularly to developing countries. 

The OECD Decision  

OECD Council Decision C(92)39/FINAL on the Control of Transfrontier Movements of Wastes Destined for 

Recovery Operations addresses transboundary movements of wastes destined for recovery operations 

between member countries of the Organisation for Economic Co-operation and Development (OECD) 

with a mind to ensuring their environmentally sound and economically efficient management. 

Importantly, and arguably the main reason for its continued existence, the Decision applies to 

transboundary movements of wastes between OECD member countries in the case where an OECD 

member country is not a Party to the Basel Convention. This is particularly important for the US as a 

non-Party to the Basel Convention. 

The OECD system, which has been amended over time to address developments in the Basel 

Convention, is based on two control procedures: 

1.  Green Control Procedure: for wastes presenting low risk for human health and the environment 

and, therefore, not subject to any other controls than those normally applied in commercial 

transactions; 

2.  Amber Control Procedure: for wastes presenting sufficient risk to justify their control. 

The principal differences procedurally from the Basel Convention under the OECD include time limits 

for approval processes, tacit consents and pre-consent procedures. 

The EU Waste Shipments Regulation 

The European Community originally introduced measures on the supervision and control of shipments of 

waste in 1984 under Council Directive 84/631/EEC. The Directive took effect from 1 October 1985 and 

covered shipments of hazardous waste; it required prior notification to the countries involved, thereby 

allowing them to object to a specific shipment. The Directive was amended by Council Directive 

86/279/EEC of 12 June 1986, which introduced additional provisions in order to improve the monitoring 

of exports of waste out of the Community. These initial legislative instruments were significantly 

hampered by delayed, incomplete or failure to transpose the legislation at all in some Member States. 

In 1990, following international developments in the context of the Basel Convention and the OECD, the 

Commission put forward a proposal for a Waste Shipment Regulation with the Basel Convention and, 

latterly, the 1992 OECD Decision forming the main pillars of the resulting 1993 Regulation. The 1993 

Regulation entered into force on 9 February 1993 and was applicable as of 6 May 1994. The move to a 

Regulation rather than a Directive was aimed specifically at addressing transposition and 

implementation issues encountered in the original 1984 Directive. 

As both the Basel Convention and OECD Decision have evolved over time, it has been necessary for the 

Regulation to be amended to take into account such developments. Furthermore, problems with the 

30 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Regulation identified in its operation within the EU have also led to changes. The most significant 

change arose in 2006 with the adoption of Regulation (EC) No 1013/2006 on shipments of waste that 

replaced the 1993 Regulation. The Regulation applies to shipments of waste: 

• 

• 

• 

• 

Between EU countries within the EU or transiting via non-EU countries; 

Imported into the EU from non-EU countries; 

Exported from the EU to non-EU countries; 

In transit through the EU, on the way from or to non-EU countries. 

There are two control procedures for the shipment of waste: 

1.  general information requirements - applicable to shipments for recovery of wastes, listed in 

Annex III (‘green’ listed wastes - non-hazardous, such as paper or plastics) or IIIA; and 

2.  prior written notification and consent - for other types of shipments of wastes, including: 

a. 

shipments of wastes listed in Annex IV (‘amber’ listed wastes containing both hazardous 

and non-hazardous parts) or in Part 2 of Annex V (European list of wastes, e.g. wastes 

from mining, quarrying and physical and chemical treatment of minerals); and 

b.  shipments for disposal of wastes listed in Annex III (‘green’ listed wastes). 

In applying the Regulation all parties involved must ensure that waste is managed in an environmentally 

sound manner, respecting EU and international rules, throughout the shipment process and when it is 

recovered or disposed of. Exports to non-EU countries of waste for disposal are prohibited, except to 

EFTA countries that are party to the Basel Convention and exports for recovery of hazardous waste (i.e. 

that pose a risk to human health and the environment) are prohibited, except those directed to 

countries to which the OECD decision applies. Finally, imports from non-EU countries of waste for 

disposal or recovery are prohibited, except for imports from countries to which the OECD decision 

applies, from non-EU countries that are party to the Basel Convention, from countries that have 

concluded a bilateral agreement with the EU or EU countries or other areas during situations of crisis. 

The relationship between the EU Waste Shipments Regulation and Regulation 1418/2007 

concerning export for recovery of certain listed wastes 

As noted above, exports of certain wastes to OECD countries are permitted under that Decision and are 

generally captured under Section 2 of Chapter 2 of the WSR concerning exports of waste for recovery. 

However, Section 1 of Chapter 2 addresses exports for recovery to non-OECD Decision countries. Article 

36 of the Regulation sets the lists of wastes that are prohibited for export. However, Article 36 

addresses exports of wastes for recovery to non-OECD Decision countries for green listed wastes and 

certain mixtures of two or more green listed wastes. 

Procedurally under Article 37, the Commission is required to send a written request to each country to 

which the OECD Decision does not apply addressing: 

1.  Confirmation in writing that such waste may be exported from the Community for recovery in 

that country; and 

2.  An indication as to which control procedure, if any, would be followed in the country of 

destination. 

Each country is given the following options: 

• 

A prohibition; or 

31 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

A procedure of prior written notification and consent as addressed in Article 35 of the WSR 

(thereby applying the same provisions as for exports of waste for disposal to EFTA countries); 

or 

•  No control in the country of destination. 

The Commission is also required under Article 37 to adopt a Regulation that takes into account all 

replies received and issues a default position of option (b) where a country has not responded or has 

not been contacted. The Commission is required to periodically update the Regulation. This specific 

part of the WSR is addressed by Regulation 1418/2007. Accordingly, Regulation 1418/2007 has been 

updated following further rounds of written requests to countries over its lifetime. All but one of those 

amendments has been in relation to updating of country responses, with the single amendment not 

related to such matters concerning the accession of Croatia to the European Union. The most recent 

update is prepared as this study is being developed and is expected by end 2020. 

5.2  Shipments of waste from a quantitative perspective 

  Introduction to the numerical baseline 

Section 4.1 above describes the baseline in relation to the existing policy provisions that apply to 

shipments of waste within the European Union. However, it is also important in defining the baseline to 

consider: 

• 

Trends in waste shipments in terms of volumes and values as well as to understand the 

destination countries of waste traded internationally, and 

• 

Emerging developments that will impact on waste shipments in the future and, thereby, 

change waste shipments regardless of any of the specific options considered in this study. 

Trends in waste shipments have been identified by examining past waste shipments – between 2010 and 

2018 for hazardous waste33 (with 2018 being the most recent reported data at the time of this study) 

and between 2010 and 2019 for plastic, paper and cardboard, glass, non-ferrous metal, ferrous metal 

and textiles wastes34. An analysis of changes in the volume in tonnes and value in € over the periods 

indicated above has then been subject to forecasting up to 2030 using a linear regression with a 95% 

confidence interval. The results of the application of this approach are presented in the following 

section. 

In considering emerging developments that will have an impact on waste shipments in the future these 

can be separated as: 

• 

Developments that will have an impact on shipments within the EU. The most obvious 

development at the EU level that may impact on shipments of waste is the Commission’s 

Circular Economy Action Plan For a cleaner and more competitive Europe35. Published in March 

2020, the Plan builds on work undertaken since 2015, and focuses on the design and production 

for a circular economy, with the aim to ensure that the resources used are kept in the EU 

economy for as long as possible. Whilst the plan includes the aim to ensure less waste, the 

exact impacts expected in terms or reducing waste have not been defined. Consequently, the 

baseline for this report does not include a specific reduction figure in waste shipment terms 

33 This includes waste shipments in the Outermost Regions 
34 This does not include waste shipments in the Outermost Regions 
35 COM (2020) 98 final https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=COM:2020:98:FIN&WT.mc_id=Twitter  

32 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

likely to stem from the Plan as there is insufficient information to set such a figure. However, 

in undertaking this approach it is acknowledged that the circular economy action plan will have 

an impact on the nature and volumes of wastes produced that, in turn, will likely affect the 

shipments of waste made both within the EU and between the EU and third countries. 

Estimates of the baseline are considered, therefore, to provide figures for the period 2021-

2030 that will be higher in export terms than will actually be the case in the case of full 

implementation of the Circular Economy Action Plan. 

• 

Developments that will have an impact on shipments from the EU to third countries. The Basel 

Ban Amendment and repeatedly revised controls on imports of wastes applied by third 

countries are considered to be the main developments that are likely to change flows of wastes 

to such countries. Our analysis captures the impacts of import restrictions that have already 

been applied, such as the import bans applied by China with respect to certain wastes 

including plastic wastes, as well as considering more recent policy changes in third countries 

identified in the Commission Study ‘Update to Waste Shipment Regulation 1418/200736’. 

  Trends in waste shipments by volumes and values including countries of export and destination 

Waste generation compared to waste shipped across country borders 

An important first comparison to be made is in relation to the total amount of waste generated within 

the European Union compared to the volumes of waste shipped across country borders and, therefore, 

of relevance for this report. 

36 http://wastetradesurvey.eu/  

33 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 2 Baseline prediction of total EU-27 waste generation versus total EU-27 waste export 2004 - 2030 

Baseline prediction of total EU waste 
generation versus total EU waste export 
2004 - 2030

3,000

2,500

s
e
n
n
o
t

f
o

s
n
o

i
l
l
i

M

2,000

1,500

1,000

500

0

2004 2006 2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030

Year

Total waste generated

Total waste exported

Total waste imported intra-EU

Total waste generated lower confidence bound

Total waste exported lower confidence bound

Total waste imported intra-EU lower confidence bound

Total waste generated upper confidence bound

Total waste exported upper confidence bound

Total waste imported intra-EU upper confidence bound

34 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 2 compares total waste generated within the EU as derived from Eurostat Generation of waste-

by-waste category, hazardousness and NACE Rev. 2 activity (was_gen), with Eurostat data concerning 

trade in recyclable raw materials by waste (env_wastrd) that addresses exports of waste from the 

European Union using the CN approach and imports of waste into the EU using the same CN approach. 

Reported data from 2004-2018 have then been used to forecast changes up to 2030 using linear 

regression with a 95% confidence interval, with the lower and upper confidence bounds shown in dashed 

lines. It is apparent that up to 2018, total EU waste generation far outweighs the amounts of waste 

being shipped from the EU to third countries or between EU Member States. Trends to 2030 indicate a 

fairly stable picture in comparison to 2004-2018, with shipments of waste continuing to be a small 

proportion of total EU waste generation. 

Total EU imports and exports of waste 

The European Union is not only one of the largest exporters of waste globally, but it also imports 

considerable amounts of waste from third countries for treatment within the Union. Error! Reference 

source not found. below considers Eurostat data concerning trade in recyclable raw materials by waste 

(env_wastrd) that addresses exports of waste from the European Union using the CN approach and 

imports of waste from third countries using the same CN approach37. The trend between 2004 and 2018 

in terms or reported data shows a general upward trend in EU27 exports whilst imports show a general 

decrease over time. Reported data from 2004-2018 have then been used to forecast changes up to 2030 

using linear regression with a 95% confidence interval, with the lower and upper confidence bounds 

shown in dashed lines. Even taking into account the lower and upper confidence bounds of the forecast, 

it is apparent that imports of waste for the EU-27 are expected to see a downward trend that is the 

opposite to exports, which show a generally upward trend – in keeping with the reported data up to 

2018. 

Figure 3 Baseline prediction of imports and exports of waste for the Eu-27 for the period 2004-2030 

37 For a full list of the wastes considered in this analysis 
https://ec.europa.eu/eurostat/documents/8105938/8465062/cei_srm020_esmsip_CN-codes.pdf  

35 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Baseline prediction of imports and exports of waste for 
the EU-27 for the period 2004-2030

s
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50,000,000

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40,000,000

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2004 2006 2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030

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EU 27 exports in tonnes forecast

EU 27 imports in tonnes lower confidence bound

EU 27 exports in tonnes lower confidence bound

EU 27 imports in tonnes upper confidence bound

EU 27 exports in tonnes upper confidence bound

Wastes subject to the notification procedure 

Recognising that different waste types are subject to different requirements in relation to their 

treatments under existing waste shipment rules, it is important to consider waste subject to the 

notification procedure separately from those, which are not given the stricter rules that apply to such 

wastes as addressed in the data immediately above. Most wastes subject to the notification procedure 

laid down in the WSR (mainly hazardous wastes and mixed municipal waste) are mainly treated within 

the EU Member State they are generated.  

Considering hazardous waste in the first instance, the volume of hazardous waste generated varies 

greatly between Member States. Figure 4 below considers the generation of hazardous waste for the 

period 2004-2018 for the EU-27. 

Figure 4 Generation of hazardous waste by the EU-27 for the period 2004-2018 

36 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Total hazardous waste generated by Member State 2004-
2018

30,000,000

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Whilst the general trend of size of economy equalling a greater volume of hazardous waste generated 

can be seen, Bulgaria stands out as a Member State that generates a considerable amount of hazardous 

waste in comparison to the size of the country. An examination of the reporting of hazardous waste 

generation by Bulgaria over the same period indicates that a vast majority of the waste is comprised of 

mineral waste, in keeping with the nature of the extractive sector in Bulgaria which, according to 

Eurostat data of Business economy by sector, is the most specialised country when it comes to mining 

and quarrying of metal ores and is the likely source of the main volume reported by Bulgaria against the 

above figure. 

Reflecting on the general trend in hazardous waste generation within the European Union, Figure 5 

below considers data from the Eurostat env_wasgen dataset for the period 2004 – 2018 and reflects 

projected changes in generation up to 2030 using a linear regression with a 95% confidence interval. 

37 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 5 Baseline prediction of hazardous waste generation to 2030 

Baseline prediction of hazardous waste generation by the 
EU-27 covering the period 2004 - 2030

s
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140000000

120000000

100000000

80000000

60000000

40000000

20000000

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2004 2006 2008 2010 2012 2014 2016 2018 2020 2022 2024 2026 2028 2030

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

As can be seen from the above figure, the expected trend is a general increase in generation of 

hazardous waste in the years to come based on trends up to 2018. 

The destination of hazardous waste shipped is presented in Error! Reference source not found. below. 

Table 11 Destination of hazardous waste shipped transboundary from EU Member States 2001-2018 

38 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Eurostat noted in its assessment of the above data that ‘the exports from the EU Member States to 

EFTA countries decreased from 151 000 tonnes in 2001 to a low of 59 000 tonnes in 2005. In 2018, 461 

000 tonnes were shipped to EFTA countries, down from the peak of 550 000 registered in 2017. A small 

amount of hazardous waste was exported to non-OECD countries from 2001 to 2009. This conclusion is 

based on the reporting from Member States that have used the classification "national classified 

hazardous waste" for all waste that could not be classified under one of the Basel Convention’s Y-codes 

(Y1 to Y47).’ 

Not all hazardous waste generated is shipped across borders. In fact, the volumes shipped within the EU 

represent a relatively small percentage of hazardous waste generated. The exception to this is in 

relation to the Outermost Regions where the capacity to manage hazardous wastes generated is limited 

and exports are a necessity.  

Using a linear regression, a comparison of the data that forms the abovementioned figure and the data 

from reported under Article 51(1) of the WSR as shown in Figure 6 below shows that whilst 

approximately 9% of EU hazardous waste generated within the EU was shipped to another Member State 

in 2010, by 2030 that value is expected to be less than 8%. 

Figure 6 Baseline comparison of EU hazardous waste generation with EU hazardous waste shipped within the EU 
to 2030 

Baseline comparison of EU hazardous waste generation 
with EU hazardous waste shipped within the EU to 2030

120000000

100000000

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Hazardous waste generated but not shipped within the EU forecast

Hazardous waste generated and shipped within the EU forecast

Regarding mixed municipal waste, as per hazardous wastes above, the volume of waste varies across 

the EU-27. Taking data from Eurostat env_wasmun, volumes of municipal waste generation for each 

Member State from 2009-2018 are shown in Figure 7 below. 

39 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 7 Generation of municipal waste by EU Member State for the period 2009-2018 

Municipal waste generated by EU Member State 2009-
2018

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In keeping with a general trend of larger economies, levels of affluence and sizes of population 

generating larger volumes of municipal waste the figure above demonstrates that these trends are true 

for the EU-27. 

Examining trends in generation of municipal waste for the EU-27 for the period up to 2030, the general 

trend using a linear regression with a 95% confidence interval indicates a generally downward trend in 

municipal waste generation in the years to come as shown in Figure 8 below. 

40 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 8 Baseline prediction of municipal waste generation for the EU-27 to 2030 

Municipal solid waste generation baseline 2009-2030

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Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

Year

The quantity of notified mixed municipal waste subject to shipments across borders represents a small 

proportion of municipal waste generated as shown in Figure 9 below that uses data from reporting 

under Article 51(1) of the WSR and held by Eurostat for the period 2010-2018 and applies a linear 

regression with 95% confidence to predict changes to 2030. 

Figure 9 Baseline prediction of shipments of municipal waste for the EU-27 to 2030  

Baseline prediction of shipments of municipal waste for 
the EU-27 to 2030

2500000

2000000

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500000

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Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

Year

41 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Furthermore, mixed municipal waste represents a relatively small proportion of all waste subject to the 

notification procedure within the EU. Figure 8 below provides this comparison, alongside other types of 

waste that are likely to be derived from municipal waste types (191210 combustible waste (refuse 

derived fuel) and 191212 other wastes(including mixing of materials) from mechanical treatment of 

wastes) indicating that 2014 has the highest reported proportion of municipal waste subject to the 

notification procedure compared to all such wastes, with the forecast using a linear regression for 2030 

indicating that the proportion may rise to approximately 17% of all wastes subject to the notification 

procedure by that time. 

Figure 10 Baseline forecast of wastes subject to notification separate by hazardous wastes, 200301 wastes, 
191210 wastes, 191212 wastes and all other notifiable wastes for the EU-27 for the period 2010-2030 

Baseline prediction of notified waste shipments for the 
EU-27 for the period 2010-2030

20000

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Non hazardous notified waste

200301 mixed municipal waste

191210 combustible waste (refuse derived fuel)

191212 other wastes (including mixing of materials ) from mechanical treatment of wastes

Total generation of hazardous waste by the EU-27 has risen from 80.7 million tonnes in 2004 to 94.6 

million tonnes in 2016. However, as can be seen from the figure below, exports of hazardous waste out 

of the EU are exceedingly limited in comparison to the total generated representing approximately 

0.62% of those totals in 2016. 

42 

 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 11 Export of Hazardous Waste of out of the EU (all treatments), 2001-2017 in tonnes 

In comparison to exports of hazardous waste out of the EU, shipments of waste between EU Member 

States totalled 8.5 million tonnes in 2017. There are however important differences between the 

Member States, with some Member States (Ireland and Luxembourg especially, and Malta, Slovenia and 

Belgium to a lesser extent) shipping a considerable share of their hazardous waste abroad. The volume 

of shipments of hazardous wastes has been relatively steady since 2007, fluctuating between 5 and 8,7 

million tonnes/year. 

Non-hazardous wastes 

The EU generates a significant quantity of non-hazardous waste, typically classified as so-called “green-

listed” wastes.  

The majority of wastes exported from the EU are such wastes, which are not subject to the notification 

procedure. Metal, paper, cardboard and plastic waste represent the largest share of these wastes.  

43 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 12 Exports and imports of certain waste from/to the European Union 

Source: Eurostat 202038 

Turkey is presently the largest destination for waste exported from the EU, with a volume of around 

11.4 million tonnes shipped in 2019. This was almost three times as much as in 2004. The second largest 

destination is India, which received almost 2.9 million tonnes of waste from the EU in 2019, followed by 

the United Kingdom (1.9 million tonnes), Switzerland (1.6 million tonnes) and Norway (1.5 million 

tonnes). 

In contrast to exports, EU imports of waste from non-EU countries have fallen both in the long and short 

term. In 2019, these imports stood at 16.7 million tonnes in 2019, down 2% on 2018 and -6% in 2004. 

The waste imported from non-EU countries amounted to approximately €12.8 billion in 201939. 

Defining non-hazardous wastes for the purpose of this study 

In order to set boundaries for an examination of potential controls on specific non-hazardous wastes 

this study has focussed on several non-hazardous wastes, generally considered as recyclable raw 

materials. Using data held in Comext - Eurostat's reference database for detailed statistics on 

international trade in goods - the study examines data in relation to the following recyclable raw 

materials / waste streams: 

• 

• 

Plastic waste 

Ferrous metal waste 

•  Glass waste 

•  Non-ferrous metal waste (including precious metals) 

• 

• 

Paper and cardboard waste 

Textile waste 

A summary of export data in relation to each of these waste categories since 2010 that comprise the 

baseline for this study is provided below. 

38 https://ec.europa.eu/eurostat/web/products-eurostat-news/-/DDN-20200416-1  
39 Note that as a result of the UK leaving the EU the value for imports of waste to the EU has risen substantially than 
when the UK was a Member State, with 4 million tonnes of waste having been imported from the UK into the EU in 
2019 

44 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Plastic waste 

Exports of plastic waste have fallen over the period 2010-2019 as shown in the data in Figure 13 below. 

The rather dramatic change between 2017 and 2019 has been largely driven by bans in third countries 

for the import of plastic wastes, most notably in China that was, prior to that date a major destination 

of EU plastic waste. 

Figure 13 Baseline forecast of plastic exports in tonnes from the EU to third countries for the period 2004-2030 

Baseline forecast of plastic exports in tonnes from the EU 
to third countries for the period 2004-2030

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4000000

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Using a linear regression with a 95% confidence rate the prediction is that plastic exports will likely 

stabilise in comparison to the dramatic drops seen since 2016, with a gradual rise seen to the period to 

2030. 

An examination of the total economic value of the plastic waste exported shows a similar picture, as 

shown in Figure 14 below. 

45 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 14 Baseline forecast of plastic exports values in EUR from the EU to third countries for the period 2004-
2030 

Furthermore, the fluctuation of the value of plastic waste is an important aspect of the baseline and 

has been plotted in Figure 15 below that generally shows a relatively stable value moving forward to 

2030. 

Figure 15 Baseline forecast of the EUR/tonne value of plastic waste exports from the EU to 2030 

Baseline forecast in EUR/tonne of plastic exported from 
the EU to third countries for the period 2004-2030

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The destination of plastic wastes has shifted over the years. Examining destination countries for the last 

four full reporting years in Comext the following data has been extracted. 

Table 12 Top 10 third-country destinations of EU plastic waste for the years 2016-2019 by weight 

46 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 13 Top 10 third-country destinations of EU plastic waste for the years 2016-2019 by value 

Effectively, the ban of imports of plastic waste by China has led to a general reduction in total exports 

as presented in Table 12 above, but more specifically imports to Malaysia and Turkey of those wastes 

have increased, nonetheless. Approximately 86% of all exports from the EU end up in one of the top ten 

countries. However, there is an apparent difference between the volumes of plastics exported to third 

countries and their value as noted in Table 13. A good example of this is Turkey that is the second 

highest country of destination of plastic wastes in 2019 by weight, but only fourth by value of plastic 

waste. This indicates that the types of plastic wastes sent to third countries vary in quality and, 

therefore, value. 

Finally, and not forgetting that plastic waste is also shipped between EU Member States, contextual 

information as to which Member States are exporting plastic waste and to where has been analysed and 

is presented in Figure 16 for the year 2019. 

47 

CountryTonnesCountryTonnesCountryTonnesCountryTonnesMalaysia364155.3Malaysia302649.1China892713.2China1361245Turkey255982.2Turkey189806.9Hong Kong332219.2Hong Kong598721.6Hong Kong210767.3Hong Kong172069.6Viet Nam195584.9United Kingdom143060.9United Kingdom134579.3Viet Nam163765.4Malaysia158061.4Viet Nam103979Indonesia99169.8India139554.3United Kingdom136915.5India95425.1India91088.3Indonesia119003.8India88259.5Malaysia83987Switzerland51935.8United Kingdom113190.5Turkey85894.2Switzerland39786Viet Nam43848Switzerland56197.1Switzerland53093.9United States33966.5Ukraine36399.5China50337.1United States36465.8Turkey22178.3United States28870.1Taiwan48996.2Ukraine26180.9Ukraine14601.1Rest of the world216565.8Rest of the world249119.6Rest of the world161421.6Rest of the world123614.32019201820172016YearCountryEUR valueCountryEUR valueCountryEUR valueCountryEUR valueMalaysia69,787,797United Kingdom61,288,491China265,319,947China389,427,982United Kingdom68,930,161Hong Kong56,373,687Hong Kong102,511,074Hong Kong150,657,858Hong Kong54,050,463Malaysia54,674,734United Kingdom46,808,156United Kingdom46,263,161Turkey38,977,721Turkey35,953,148Viet Nam43,713,840India38,841,617India24,964,910Viet Nam34,756,465India32,862,065Viet Nam23,057,341Indonesia23,067,640India34,609,867Malaysia22,560,203Malaysia10,919,313United States13,115,820Indonesia22,972,456Turkey20,941,343United States10,907,133Ukraine9,263,851China18,925,756United States10,042,666Turkey7,252,527Viet Nam8,432,708Taiwan12,818,746Ukraine8,263,249Ukraine5,207,496Korea, Republic of5,630,224United States12,155,892Switzerland6,564,105Switzerland5,077,725Rest of the world58,492,779Rest of the world59,519,138Rest of the world42,406,648Rest of the world35,910,038Year2016201720182019 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 16 Exports of plastic waste from EU Member States split by intra- and extra-EU destination for 2019 

Chart showing the scale of exports of plastic waste from 
EU Member States by intra- and extra-EU destination for 
2019

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It is apparent that BE, DE, FR and NL, with large seaports on their territories, are the largest exporters 

of plastic waste. For BE, DE and NL approximately half of the plastic waste shipped goes to other 

Member States and the other half is exported to third countries. For FR, more than 75% of shipments 

are made to other EU Member States. 

Ferrous metal waste 

Despite some fluctuation in volume, exports of ferrous metal wastes have generally remained somewhat 

stable over the period 2004 to 2019. By far the largest volume of waste exported in terms of tonnes 

value, the expectation using a linear regression forecast is that exports will likely rise gradually to 2030 

as demonstrated in Figure 17 below. 

48 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 17 Baseline forecast of ferrous metal waste exports in tonnes from the EU to third countries for the 
period 2010-2030 

Baseline forecast of ferrous metal waste exports in tonnes 
from the EU to third countries for the period 2004-2030

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Upper Confidence Bound

The total value of ferrous metal waste exports to third countries shows a similar growth as exports by 

weight as shown in Figure 18 below. 

Figure 18 Baseline forecast of ferrous metal waste exports values in total EUR from the EU to third countries for 
the period 20042030 

Baseline forecast of ferrous metal waste exports in total 
EUR value from the EU to third countries for the period 
2004-2030

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o

i
l
l
i

M

12000

10000

8000

6000

4000

2000

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Year

Total

Forecast(Total)

Lower Confidence Bound(Total)

Upper Confidence Bound(Total)

49 

 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

This prediction of price per tonne of ferrous metals shows a generally similar pattern of stability as 

shown in Error! Reference source not found. below. 

Figure 19 Baseline forecast of ferrous metal waste EUR / tonne value for exports to third countries for the 
period 2004-2030 

Baseline forecast in EUR/tonne of ferrous metal waste 
exported from the EU to third countries for the period 
2004-2030

e
n
n
o
t

/
R
U
E

600

500

400

300

200

100

0

4
0
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7
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8
0
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2

9
0
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0
1
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1
1
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2
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2

3
1
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1
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1
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8
1
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9
1
0
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0
2
0
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1
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0
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2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

The destination of ferrous metal wastes shows a relatively stable pattern in terms of destination 

countries with Turkey the country of destination for a significant proportion of ferrous metal waste 

from the EU. This is keeping with global import data on ferrous metal wastes where it is clear that 

Turkey imports 2.5 times more ferrous metal waste from the rest of the world than the second largest 

importer - India40. Examining third country destinations of EU ferrous metal wastes for the last four full 

reporting years under Comext the following data has been extracted. 

Table 14 Top ten destination countries of EU ferrous metal wastes for the period 2016-2019 by weigh 

40 https://www.statista.com/statistics/281050/major-target-countries-for-steel-scrap-imports/  

50 

CountryTonnesCountryTonnesCountryTonnesCountryTonnesTurkey9805866.3Turkey9615352.3Turkey9516391Turkey7825185.7India1090160.8India848118.8Egypt567612India740408.3Egypt1057780.9Egypt766444.3Switzerland522432.4United States502171.5Pakistan648999.7Pakistan567275.4United States414473.7Pakistan480117.8United Kingdom435938.1United States561286.2Pakistan402320Switzerland450555.5United States392632.6Switzerland492774.8India391712.2China318336.4Switzerland387557.5United Kingdom441416.8Morocco383289.5Egypt301442.2Norway338682.4Norway333677.2United Kingdom290858.4Norway265544.7Morocco240334.7Morocco325138.1Norway273334.8United Kingdom262381.4Bangladesh216517.9Viet Nam198397.6China226050Morocco196023.6Rest of the world942326.5Rest of the world945442.3Rest of the world421318.8Rest of the world1366757.32019201820172016Year 
 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 15 Top ten destination countries of EU ferrous metal wastes for the period 2016-2019 by value 

Approximately 94% of all third country exports by weight end up in one of the top ten countries. 

Examining the split of exports of ferrous metal waste by Member State split by intra-and extra-EU 

destination for 2019 provides the following data.  

Figure 20 Exports of ferrous metal waste from EU Member States split by intra- and extra-EU destination for 
2019 

Chart showing the scale of exports of ferrous metal waste 
from EU Member States by intra- and extra-EU destination

s
e
n
n
o
T

9000000

8000000

7000000

6000000

5000000

4000000

3000000

2000000

1000000

0

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

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Member State

EU27

Extra-EU

Despite the large tonnage of ferrous metal scrap exported to third countries, a significantly larger 

volume of such wastes is exported to other EU Member States. Whilst patterns vary by Member State, it 

is apparent that the internal market for EU ferrous metal scrap remains an important destination for 

such wastes generated within the EU. 

Glass waste 

The volume of waste glass exported from the EU to third countries was relatively stable for the first 

half of the last decade. However, the period 2016-2019 has been subject to a significant increase in 

exports as shown in  

51 

CountryEUR valueCountryEUR valueCountryEUR valueCountryEUR valueTurkey2,377,293,768Turkey2,533,676,468Turkey2,289,036,114Turkey1,446,306,647India524,361,713India404,901,182India200,521,620India210,206,880Egypt258,865,963Egypt199,833,896China181,098,079China204,454,847Pakistan196,197,852United States195,887,591Switzerland130,065,741Pakistan111,269,025United Kingdom155,291,956Pakistan185,780,137United States126,335,322United States100,867,813United States108,984,699United Kingdom173,879,226Pakistan123,941,557Switzerland81,639,030Switzerland93,929,206Switzerland134,918,954Egypt123,087,587United Kingdom69,792,284Taiwan85,990,414Slovakia91,783,860United Kingdom92,204,752Egypt55,399,059Norway66,690,281Morocco85,027,255Morocco91,378,576Norway40,171,275Morocco56,432,607Norway67,113,702Taiwan54,962,071Morocco39,600,738Rest of the world386,526,577Rest of the world426,343,200Rest of the world152,051,498Rest of the world95,183,490Year2019201820172016 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 21 below.  
Figure 21 Baseline forecast of glass waste exports in tonnes from the EU to third countries 2004-2030 

Baseline forecast of glass waste exports in tonnes from the 
EU to third countries for the period 2004-2030

s
e
n
n
o
t

f
o
s
d
n
a
s
u
o
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T

600

500

400

300

200

100

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
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0
2

2
2
0
2

3
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0
2

4
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0
2

5
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0
2

6
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0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

YEar

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

Similarly, the total EUR value of waste glass exported to third countries has seen an increase over the 

last few years as shown in Figure 22 below. 

Figure 22 Baseline forecast of glass waste exports in EUR from the EU to third countries for the period 2004-
2030 

Baseline forecast of glass waste exports in Euros from the 
EU to third countries for the period 2004-2030

s
o
r
u
E
f
o

s
n
o

i
l
l
i

M

80

70

60

50

40

30

20

10

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Year

Total

Forecast(Total)

Lower Confidence Bound(Total)

Upper Confidence Bound(Total)

52 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The nature of the types of waste glass exported has a significant impact of the value per tonne. Waste 

glass cullet is the least expensive type of waste glass exported, whilst optical glass is the most 

expensive. Allocating a single EUR/tonne glass value is, therefore, a poor marker of reflecting the value 

of waste exports and has not been included in this report accordingly. 

An examination of the third countries of destination of waste glass for the period 2016 to 2019 provides 

the following list of top ten countries for each year. 

Table 16 Top ten third country destinations for waste glass for the years 2016-2019 by weight 

Table 17 Top ten third country destinations for waste glass for the years 2016-2019 by EUR value 

Since its departure from the EU, the UK is by far the largest destination of glass exported from the EU, 

equal by weight to almost all of the other countries of destination put together. However, the 

assessment of exports by EUR value indicates a much more different split with the value of Glass Waste 

sent to the UK apparently less per tonne than for some other countries. 

Glass waste is notable for the limited quantities of waste shipped beyond continental Europe in 

comparison to other wastes considered in this study. This is confirmed by an examination of the split of 

exports of glass waste by Member State split by intra- and extra-EU destination for 2019 as shown in the 

Figure below. 

53 

CountryTonnesCountryTonnesCountryTonnesCountryTonnesUnited Kingdom198576.7United Kingdom191454.8United Kingdom167361.9United Kingdom187153.6Switzerland33325.7Norway24456.2Norway19982.4Norway16724.5Norway23053.3Switzerland22613.9Switzerland17733.4Switzerland13128.2Turkey22925.2South Africa15185.9Turkey14868.3South Africa11118.3Ukraine17451Turkey11368.1South Africa10647.3Chile7062.1South Africa11283.7Russian Federation (Russia)7244.6Morocco6129.3Israel5896.1Russian Federation (Russia)10496.6Moldova, Republic of6329.8Ukraine6037Russian Federation (Russia)5038Brazil8143.6Ukraine6252.4Israel5632.7Moldova, Republic of4346.6Morocco7161.5Chile3960Moldova, Republic of5457.7Malaysia3764.7Moldova, Republic of5428.2Morocco3838.3Russian Federation (Russia)4971United States3681.2Rest of the world15578.3Rest of the world16281.8Rest of the world17570.1Rest of the world10372.5Year2019201820172016CountryEUR valueCountryEUR valueCountryEUR valueCountryEUR valueUnited Kingdom13,930,213United Kingdom12,603,311United Kingdom10,850,673United Kingdom11,738,361Turkey9,211,987Switzerland4,065,966United States6,481,045United States4,507,556United States5,619,823United States3,430,311Switzerland3,806,306Switzerland3,345,928Switzerland4,671,461Russian Federation1,671,670Russian Federation1,796,840Russian Federation1,796,187Bahrain1,803,700Norway1,441,023Israel1,532,216Israel1,626,973Russian Federation1,777,206Bahrain1,432,800Bahrain1,423,770Bahrain1,371,100Norway1,270,277Israel1,018,154Norway1,223,212Norway1,098,854Israel1,161,720China655,388China662,297Angola921,065Ukraine779,616South Africa445,244Chile447,131Chile694,265Brazil674,585Chile403,337South Africa370,900China516,200Rest of the world2,719,815Rest of the world1,933,880Rest of the world2,030,311Rest of the world1,705,757Year2019201820172016 
 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 23 Exports of waste glass from EU Member States split by intra- and extra EU destination for 2019 

Chart showing the scale of exports of glass waste from EU 
Member States by intra- and extra-EU destination

s
e
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600000

500000

400000

300000

200000

100000

0

T
A

E
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G
B

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C

E
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K
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Member State

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Extra-EU

Consequently, it is clear that glass waste is generally retained within the EU or neighbouring countries 

following shipment from an EU Member State. 

Non-ferrous metal waste (including precious metals) 

Non-ferrous metal wastes for the purpose of this study comprise a large number of different non-ferrous 

metal waste types. As a general trend for all of these wastes combined, exports from the EU to third 

countries have been gradually increasing. This is shown in  

54 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 24 below. 

55 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 24 Baseline forecast of non-ferrous metal waste exports in tonnes from the EU to third countries for the 
period 2004-2030 

Baseline forecast of ferrous metal waste exports in tonnes 
from the EU to third countries for the period 2004-2030

s
e
n
n
o
t

f
o
s
d
n
a
s
u
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T

4000

3500

3000

2500

2000

1500

1000

500

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
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6
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0
2

7
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0
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8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
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0
2

6
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0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

However, the underlying trend masks a large degree of variation in the quantities of different non-

ferrous metals being exported as shown in Figure 25.  

Figure 25 Exports of non-ferrous metal wastes from the EU to third countries by combined nomenclature code 
for the period 2004-2019 

Total tonnes by CN code 2010-2019

700000

600000

500000

400000

300000

200000

100000

0

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

56 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

As can be seen in the above figure, aluminium scrap (76020090) waste and scrap of copper alloys 

(74040099), waste and scrap of copper-zinc base alloys (74040091), waste aluminium (76020019) and 

waste and scrap of refined copper (74040010) are by far the largest non-ferrous metals exported in 

terms of tonnage. 

The total Euro value of exports of non-ferrous metal wastes shows a large degree of stability over the 

last sixteen, that is predicted to continue to rise slowly for the next ten years as shown in Figure 26 

Figure 26 Baseline forecast of total EUR value of non-ferrous metal exports from the EU to third countries for 
the period 2010-2030 

Baseline forecast of non-ferrous metal waste exports in 
total EUR value from the EU to third countries for the 
period 2010-2030

s
o
r
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o

s
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o

i
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16000

14000

12000

10000

8000

6000

4000

2000

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
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0
2

5
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2

6
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2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
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0
2

2
2
0
2

3
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0
2

4
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0
2

5
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0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

The variety of non-ferrous metals included in this category, particularly as a result of precious metals 

also being grouped together with other non-ferrous wastes, means that a EUR/tonne value offers little 

value. To demonstrate the large variability in prices the values for the last nine years for each non-

ferrous metal type have been extracted and are included in  

57 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 27 below. 

58 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 27 EUR/tonne value of non-ferrous metal wastes for the period 2010-2019 split by CN code 

EUR/tonne by CN code 2010-2019

10000000

9000000

8000000

7000000

6000000

5000000

4000000

3000000

2000000

1000000

0

2010

2011

2012

2013

2014

2015

2016

2017

2018

2019

Gold wastes (71129100) and hafnium wastes (81129210) are, by far, the most valuable non-ferrous 

metals exported by the EU in terms of EUR/tonne. However as the volumes of gold waste exported are 

generally small (a maximum of 1192 tonnes was exported in a single year in 2019 taking into account 

exports over the last decade), and hafnium waste even smaller (a maximum of 53.8 tonnes was 

recorded in 2016), they represent overall a small volume of waste by tonnage (0.06% of EU total non-

ferrous metal waste exports in 2019) whilst representing, in the case of gold, 13.5% of the total EUR 

value of all non-ferrous metal exports in 2019. 

The third country destinations of non-ferrous metal wastes from the EU are the most consistent of all of 

the non-hazardous wastes addressed in this study, as shown in Table 18 below. 

Table 18 top ten destination third countries of non-ferrous metal wastes exported from the EU by weight 

China, India and the UK are the largest destination countries by weight, with the top ten destination 

countries covering 85% of all EU exports of non-ferrous metal wastes, the remaining 15% being other 

countries around the world. 

59 

CountryTonnesCountryTonnesCountryTonnesCountryTonnesChina472036.8China550208.8China881657.9China864892.9India300368.8India249345.8India242214.6India207863United Kingdom185082.5United Kingdom157156.6United Kingdom164886United Kingdom145278.1Norway160156.3Pakistan110714.4Norway101541.1Norway82379Pakistan140451.5Switzerland79641Pakistan72466.2Pakistan80663.8Hong Kong92707.5Norway77953.3Switzerland59673.2Hong Kong55502.4Switzerland85419.6United States61675.4United States59228.9Switzerland54665.1Turkey67544.3Japan50661.6Hong Kong49979.5United States41386.1Malaysia67098.3Hong Kong47518Korea, Republic of (South Korea)40499Korea, Republic of (South Korea)40021United States59835.4Turkey35035.2Turkey32257.4Japan29762.9Rest of the world281140.1Rest of the world193256.3Rest of the world155591.9Rest of the world121739.62019201820172016Year 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 19 top ten destination third countries of non-ferrous metal wastes exported from the EU by EUR value 

In examining the top ten destination countries of EU non-ferrous metal waste by value the list changes 

somewhat, indicating that for some countries the value of waste per tonne shipped (for example to 

India, Pakistan and Turkey) is less than for others such as the United States and Switzerland. 

73% of non-ferrous metal waste shipments are made intra-EU, meaning that a large majority of non-

ferrous metal wastes are not exported to third countries. However, the percentages of export vary by 

Member State as shown in Figure 28 below for the year 2019. 

Figure 28 Exports of non-ferrous metal waste from EU Member States split by intra- and extra-EU destination for 
2019 

Scale of exports of non-ferrous metal waste from EU 
Member States by intra- and extra-EU destination in 2019

s
e
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1800000

1600000

1400000

1200000

1000000

800000

600000

400000

200000

0

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
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S
E

I
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I
S

K
S

Member State

EU27

Extra-EU

Proportionally, Ireland, Spain, Sweden and Belgium export the largest proportion of their transboundary 

shipments to third countries. However, of these countries Sweden and Belgium still export more non-

ferrous metal wastes to other Member States than to third countries. 

60 

CountryEUR valueCountryEUR valueCountryEUR valueCountryEUR valueChina1,201,145,329China1,542,469,317China1,961,752,155China1,410,523,012United States1,038,977,703United States778,016,808United States776,373,596United Kingdom646,349,037Switzerland894,900,583United Kingdom714,946,912United Kingdom551,492,118United States547,724,398United Kingdom691,576,729Switzerland689,424,430Switzerland450,213,860India297,796,467India433,825,216India428,383,466India397,661,792Switzerland297,069,800Japan430,556,842Japan278,422,045Norway256,385,762Norway191,989,176Norway307,084,484Norway230,624,498Japan195,199,699Japan161,558,382Russian Federation188,857,886Singapore160,158,060Singapore123,031,858Singapore117,571,731Hong Kong172,751,244Korea, Republic of92,003,906Korea, Republic of98,907,724Hong Kong68,145,751Singapore166,964,492Hong Kong82,640,368Hong Kong81,229,220Korea, Republic of54,900,190Rest of the world779,934,357Rest of the world497,633,547Rest of the world343,253,214Rest of the world249,200,382Year2019201820172016 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Paper and cardboard waste 

Paper and cardboard waste exports have shown a general trend of a small decline in exports from the 

EU to third countries over the period 2010 to 2019. For the purpose of defining the baseline for this 

study the export tonnage has been predicted to stabilise, with exports in 2030 remaining slightly higher 

than in 2019 as shown in Figure 29 below. 

Figure 29 Baseline forecast of paper waste exports in tonnes from the EU to third countries for the period 2004-
2030 

Baseline forecast of paper waste exports in tonnes from 
the EU to third countries for the period 2004-2030

s
e
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14

12

10

8

6

4

2

0

4
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5
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7
0
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1
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8
2
0
2

9
2
0
2

0
3
0
2

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

The total Euro value of paper waste exports from the EU to third countries has shown a similar 

fluctuation to total tonnage over the period (see  

61 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 30). The total value is expected to climb to 2030. 

62 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 30 Baseline forecast of paper waste exports values in total EUR from the EU to third countries for the 
period 2004-2030 

Baseline forecast of paper waste exports in total EUR value from the EU to 
third countries for the period 2004-2030

s
o
r
u
E
f
o

s
n
o

i
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l
i

M

2500

2000

1500

1000

500

0

4
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5
0
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6
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3
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4
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5
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7
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8
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2
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7
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8
2
0
2

9
2
0
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0
3
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2

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

The change in EUR / tonne value is shown in Figure 31 below with the forecast value expected to 

remain fairly constant over the period to 2030. 

Figure 31 Baseline forecast of paper waste EUR / tonne value for exports to third countries for the period 2004-
2030 

Baseline forecast in EUR/tonne of paper waste exported from the EU to 
third countries for the period 2004-2030

e
n
n
o
t
/
R
U
E

250

200

150

100

50

0

4
0
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5
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6
0
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7
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9
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2
0
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1
2
0
2

2
2
0
2

3
2
0
2

4
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0
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0
2

7
2
0
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8
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9
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0
3
0
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Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

63 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The tope 10 destination third countries of paper and cardboard waste from the EU are shown in the 

Table below. 

Table 20 Top ten destination countries of EU paper and cardboard wastes for the period 2016-2019 by weight 

Table 21 Top ten destination countries of EU paper and cardboard wastes for the period 2016-2019 by EUR 
value 

Third country export destinations are somewhat dominated by East and South Asia, with India, China 

and Indonesia as significant importers of EU paper and cardboard waste. Approximately 91% of all paper 

and cardboard waste goes to the top ten countries. Furthermore, the fluctuation in values per tonne 

appear more stable than for other wastes as notable by the similarity of the top ten countries by weight 

and be EUR value of paper and cardboard wastes. 

Examination of the split of transboundary shipments of paper and cardboard waste between intra- and 

extra-EU destination, these vary by Member State – in some cases rather substantially as shown in  

64 

CountryTonnesCountryTonnesCountryTonnesCountryTonnesIndia1108822.2China2246038.9China4063375China5080710.4Indonesia966838.1India1178776.1India519829.6Switzerland381745.9Turkey720965.6Indonesia839012.4Indonesia511632.3India358925.9China689467.1Thailand477523.4Turkey476178Indonesia354571.9Viet Nam617347.4Viet Nam437732.4Switzerland388160.9Turkey234483.5Thailand597471.8Turkey402311.9Viet Nam242859.3Korea, Republic of (South Korea)196655.8Switzerland238386.2Switzerland217440.2Thailand232833.2United Kingdom170901.9Ukraine139004.3Ukraine176509.1Korea, Republic of (South Korea)171670.5Ukraine116852.3Malaysia114888.5Norway135260.4Taiwan141591Norway92058.5United Kingdom110186.2United Kingdom114460.3United Kingdom137257.3Thailand89984.7Rest of the world528440.9Rest of the world604105.5Rest of the world502534.8Rest of the world361144.5Year2019201820172016CountryEUR valueCountryEUR valueCountryEUR valueCountryEUR valueIndia105,702,397China401,207,254China683,061,308China688,160,569China101,092,850India135,775,482India82,244,114Switzerland52,383,319Indonesia90,853,422Indonesia91,403,164Indonesia76,305,236India50,930,847Turkey58,840,348Thailand49,616,415Turkey74,202,120Indonesia49,085,411Viet Nam53,567,696Viet Nam46,351,669Switzerland56,591,699Turkey32,679,869Thailand48,008,498Turkey42,914,290Viet Nam40,835,282Korea, Republic of29,755,564Switzerland31,329,375Switzerland28,639,331Thailand36,943,842United Kingdom28,890,952United Kingdom18,170,202United Kingdom24,913,341Korea, Republic of 29,421,991Ukraine17,302,873Ukraine16,494,870Ukraine24,808,246United Kingdom25,367,022Norway14,961,003Serbia11,308,431Norway20,181,612Taiwan24,633,485Serbia12,576,146Rest of the World65,268,986Rest of the World82,519,207Rest of the World87,992,816Rest of the World57,798,332Year2019201820172016 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 32 below. 

65 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 32 Exports of paper and cardboard waste from EU Member States split by intra- and extra-EU destination 
for 2019 

Chart showing the scale of exports of paper and cardboard waste from EU 
Member States by intra- and extra-EU destination

3000000

s
e
n
n
o
T

2000000

1000000

0

AT

BG

CZ

DK

EL

FI

HR

IE

LT

LV

NL

PT

SE

SK

Member State

EU27

Extra-EU

As shown in the above figure, for some Member States shipments of paper and cardboard waste are 

almost exclusively made to other EU Member States – this is the case for larger exporters such as AT, 

CZ, DK, PL, SE and SK. DE and FR, whilst exporting two of the top three volumes of paper and 

cardboard waste of all Member States in 2019, export a majority of those wastes intra-EU. NL and IT 

are largely dependent on exports to third countries whilst, IE and ES almost entirely dependent on third 

country exports. 

Textile wastes 

Exports of textile wastes by volume have seen a steady climb over the period 2010-2019, with an 

expectation that the trend will continue to 2030 as shown in Error! Reference source not found.Figure 

33 below. 

Figure 33 Baseline forecast of textile waste exports in tonnes from the EU to third countries for the period 
2004-2030 

Baseline forecast of textile waste exports in tonnes from the EU to 
third countries for the period 2004-2030

s
e
n
n
o
t

f
o
s
d
n
a
s
u
o
h
T

2500

2000

1500

1000

500

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
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8
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0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
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4
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2

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0
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6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

66 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Textile wastes are generally a high value waste. In keeping with the trend of total tonnes of exports, 

the total EUR value of textile waste exports has risen since 2004 and is expected to maintain a similar 

trajectory to 2030 as shown in Figure 34. 

Figure 34 Baseline forecast of textile waste exports values in total EUR from the EU to third countries for the 
period 2004-2030 

Baseline forecast of textile waste exports in total EUR value from the 
EU to third countries for the period 2004-2030

s
o
r
u
E

f
o

s
n
o

i
l
l
i

M

2000

1800

1600

1400

1200

1000

800

600

400

200

0

4
0
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Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

In keeping with the trends in terms of total tonnage and EUR value of textile wastes being exported to 

third countries, the EUR/tonne value of textile wastes as shown in Error! Reference source not found. 

shows an increase, albeit more gradual than the two former metrics, between 2010 and 2019 that is 

forecast to continue to 2030, albeit the 2030 value would be somewhat commensurate with the peak in 

value in 2014. 

67 

 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 35 Baseline forecast of textile waste EUR / tonne value for exports to third countries for the period 
2004-2030 

Baseline forecast in EUR/tonne of textile waste exported from the 
EU to third countries for the period 2004-2030

e
n
n
o
t
/
R
U
E

1200

1000

800

600

400

200

0

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
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8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

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0
2

7
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0
2

8
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Year

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

Textile wastes from the EU are made to a far more diverse set of countries than the other specific 

wastes considered in this study, as shown in Table 22 below. 

Table 22 Top ten destination countries of EU textile wastes for the period 2016-2019 by weight 

Whilst the names of the top 10 countries of destination by weight are relatively stable, these top 10 

countries address between 55 and 58% of all exports, indicating that the waste market for EU textile 

waste is subject to a broad geographic spread. 

A similar picture is found when considering the top ten destination countries for EU textile waste by 

value. 

68 

CountryTonnesCountryTonnesCountryTonnesCountryTonnesPakistan184932.9Pakistan160833.1Pakistan120443.6Pakistan115910.8Tunisia111767.9Tunisia100253.6Tunisia117727.3Tunisia113845.5United Arab Emirates110632.1India91160.7India94991.4India89962.3India98744United Arab Emirates89146.4Ukraine73765.2Cameroon68714.3Turkey80779.8Turkey71440.3Turkey68596.1Ukraine64652.3Ukraine68421.3Cameroon67307.7United Arab Emirates68432.3United Arab Emirates51104.8Cameroon67692.6Ukraine66155.4Cameroon66209.1Turkey50665.8Togo55309.1Togo51537.1Togo51126.3Togo44115.1Russian Federation (Russia)48083.5Russian Federation (Russia)46281.7Russian Federation (Russia)47075United Kingdom42434.5Ghana37692.5United Kingdom35387.3United Kingdom37596.5Russian Federation (Russia)40570.6Rest of the world635706.7Rest of the world631236.9Rest of the world620539.2Rest of the world585974.42019201820172016Year 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 23 Top ten destination countries of EU textile wastes for the period 2016-2019 by EUR value 

Finally, an examination of the intra- versus extra-EU nature of shipments of textile waste, 

approximately 55% of all such shipments are made to third countries. 

Figure 36 Exports of textile waste from EU Member States split by intra- and extra-EU destination for 2019 

Chart showing the scale of exports of textiles waste from EU 
Member States by intra- and extra-EU destination

s
e
n
n
o
T

600000

500000

400000

300000

200000

100000

0

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

I
F

R
F

R
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U I
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T
I

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M

L
N

L
P

T
P

O
R

E
S

I
S

K
S

Member State

EU27

Extra-EU

As can be seen in Figure 36 above, DE, FR, BE, NL, IT, PL and ES represent the greatest exporters of 

textile waste. Proportionally, BE, ES, IT, LT and PT are heavily reliant on export of textile wastes to 

third countries in comparison to intra-EU shipments. 

How do the specific waste categories compare to one another overall? 

An examination of each waste type on its own provides important information on the predicted changes 

in exports of those wastes for the purpose of defining the baseline for this study to 2030. However, it is 

also important to consider the wastes alongside one another. 

Error! Reference source not found. below compares intra- and extra-EU shipments of waste by volume 

for paper and cardboard, textiles, plastics, glass, non-ferrous metals and ferrous metals. A general 

trend that can be identified is that intra-EU shipments form the largest quantity by volume of nearly all 

69 

CountryEUR valueCountryEUR valueCountryEUR valueCountryEUR valueRussian Federation101,188,599Russian Federation100,293,567Ukraine106,944,381Ukraine94,224,233Ukraine91,376,796Ukraine95,095,725Russian Federation105,143,596Russian Federation81,651,707Cameroon67,463,632Cameroon69,125,649Cameroon69,491,962Cameroon71,797,565Tunisia49,657,500Tunisia50,432,770Tunisia60,527,290Tunisia57,126,188United Arab Emirates41,720,282Turkey39,451,116Turkey43,415,998United Kingdom34,488,604Turkey38,472,533United Arab Emirates35,210,871United Kingdom32,009,628Turkey32,567,803Belarus36,830,383United Kingdom31,704,002Melilla30,414,256Melilla30,983,861Melilla36,169,069China28,614,360Guinea29,363,796Guinea29,657,899Ghana32,920,196Melilla28,243,011United Arab Emirates28,764,605Ghana28,599,064Pakistan29,650,929Belarus28,195,157Togo27,384,697Kenya25,244,761Rest566,990,044Rest575,616,743Rest571,335,010Rest533,858,713Year2019201820172016 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

waste types, except for textiles where the split is slightly towards extra-EU destinations compared to 

intra-EU. However, by weight, ferrous metal shipments dominate the market by weight, followed by 

paper and cardboard and non-ferrous metals. 

Figure 37 Examination of intra- and extra-EU exports of selected wastes in tonnes for the period 2016-2019 

2016-2019 intra vs extra-EU shipments of different 
categories of waste for the EU27 in tonnes

30000000

25000000

s
e
n
n
o
T

20000000

15000000

10000000

5000000

0

Waste type and destination

2016

2017

2018

2019

To set the context of those Member States that are most heavily involved in exporting these wastes to 

third countries, figures for 2019 have been extracted and are shown below. 

70 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 38 Comparison of intra- and extra-EU exports of paper and cardboard, textile, plastic, glass, non-ferrous 
metals and ferrous metals wastes for 2019 for the EU-27. 

Scale of exports of all modelled waste from EU Member States by 
intra- and extra-EU destination for the year 2019

s
e
n
n
o
T

16000000

14000000

12000000

10000000

8000000

6000000

4000000

2000000

0

T
A

E
B

G
B

Y
C

Z
C

E
D

K
D

E
E

L
E

S
E

I
F

R
F

R
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U I
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H

T
I

T
L

U
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V
L

T
M

L
N

L
P

T
P

O
R

E
S

I
S

K
S

Member State

EU27

Extra-EU

It is clear from the above figure, that some Member States are generally more reliant on exports of 

wastes to third countries than others. Proportionally, BE, DK, EE, ES, IE, IT, LT, LV, NL, RO and SE are 

involved in shipments to third countries that is either larger than or generally comparable in size to 

intra-EU shipments. This is important in the context of some to the objectives and measures examined 

later in this assessment. 

OECD vs non-OECD country trends 

As noted at the start of this section, there are two main multilateral environmental agreements that 

address transboundary shipments of waste – the Basel Convention and OECD Decision. In order to 

consider the impacts in relation to these existing agreements on potential measures under this study an 

examination of trends in waste shipments to third countries split by OECD and non-OECD member 

countries has been performed. The results of this analysis are presented in the following tables and 

figures. 

Plastic wastes 

Until relatively recently, OECD countries had been a relatively smaller proportion of destination of EU 

plastic wastes than non-OECD third countries. This changed around 2017, likely as a result of the bans 

on imports implemented by China, whereby OECD countries became much more important countries of 

destination for such waste. This is demonstrated in Figure 39 below. 

71 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 39 Plastic waste OECD exports from the EU as a percentage of all third country exports 

Plastic waste OECD exports in tonnes as a percentage of all third 
country exports

e
g
a
t
n
e
c
r
e
P

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
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0
2

4
2
0
2

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2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
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2

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

According to the forecast, OECD countries will remain an important country of destination in the 

coming years, slowly increasing in the years to come. 

Ferrous metal wastes 

OECD countries, and in particular Turkey, have been important countries of destination for ferrous 

metal wastes for well over a decade. This is apparent from  

72 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 40 below. 

73 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 40 Ferrous metal waste OECD exports from the EU as a percentage of all third country exports 

Ferrous metal waste OECD exports in tonnes as a percentage of all 
third country exports

e
g
a
t
n
e
c
r
e
P

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
0
2

2
1
0
2

3
1
0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

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1
0
2

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2
0
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1
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2

2
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0
2

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8
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Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

There is an apparent fluctuation in shipment trends by weight that is expected to continue in the 

future. However, OECD countries will likely continue to receive over 75% of all EU ferrous metal wastes 

in the future under the baseline. 

Glass wastes 

As is the case for ferrous metal wastes, OECD countries are by far the largest countries of destination 

by weight of EU waste glass. 

74 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 41 Glass waste OECD exports from the EU as a percentage of all third country exports 

Glass waste OECD exports in tonnes as a percentage of all third 
country exports

e
g
a
t
n
e
c
r
e
P

100%

90%

80%

70%

60%

50%

40%

30%

20%

10%

0%

4
0
0
2

5
0
0
2

6
0
0
2

7
0
0
2

8
0
0
2

9
0
0
2

0
1
0
2

1
1
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2

2
1
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2

3
1
0
2

4
1
0
2

5
1
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2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
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6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

The trends to date indicate that the OECD would likely become even more important as a source of EU 

glass waste in the future. 

Non-ferrous metal waste 

OECD countries have become an increasing important destination for non-ferrous metal wastes as shown 

in Figure 42 below. 

Figure 42 Non-ferrous metal waste OECD exports from the EU as a percentage of all third country exports 

Non-ferrous metal waste OECD exports in tonnes as a percentage of 
all third country exports

e
g
a
t
n
e
c
r
e
P

100%
90%
80%
70%
60%
50%
40%
30%
20%
10%
0%

4
0
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2

5
0
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6
0
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7
0
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8
0
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9
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2

0
1
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1
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2

2
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2

3
1
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2

4
1
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5
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1
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2

7
1
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2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

75 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

It is predicted that the trend in shipments of non-ferrous metal wastes will continue with an increasing 

proportion of EU wastes to be sent to OECD countries in the future. 

Paper and cardboard 

OECD countries have traditionally received a relatively small proportion of EU paper and cardboard 

waste. This is shown in the figure below. 

Figure 43 Paper and cardboard waste OECD exports from the EU as a percentage of all third country exports 

Paper and cardboard waste OECD exports in tonnes as a percentage 
of all third country exports

e
g
a
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P

100%
90%
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10%
0%

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0
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Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

It is expected that OECD countries will continue to form the minority of third country destinations for 

EU paper and cardboard waste in the future. 

Textiles 

An absolute minority of EU textile wastes are exported to OECD countries. This is not expected to 

change dramatically in the coming years as shown in Figure 44 below. 

Figure 44 Textile waste OECD exports from the EU as a percentage of all third country exports 

Textiles waste OECD exports in tonnes as a percentage of all third 
country exports

e
g
a
t
n
e
c
r
e
P

100%

80%

60%

40%

20%

0%

4
0
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2

5
0
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2

6
0
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2

7
0
0
2

8
0
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9
0
0
2

0
1
0
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1
1
0
2

2
1
0
2

3
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0
2

4
1
0
2

5
1
0
2

6
1
0
2

7
1
0
2

8
1
0
2

9
1
0
2

0
2
0
2

1
2
0
2

2
2
0
2

3
2
0
2

4
2
0
2

5
2
0
2

6
2
0
2

7
2
0
2

8
2
0
2

9
2
0
2

0
3
0
2

Values

Forecast

Lower Confidence Bound

Upper Confidence Bound

76 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Finally, considering all wastes considered under this study and exported to OECD countries, Table 24 

below shows the quantities of plastic, ferrous metal, glass, non-ferrous metal, paper and cardboard, 

textile and wastes subject to notification sent to OECD countries. 

Table 24 Quantities of wastes sent from the EU to OECD countries for the period 2010-2018 in tonnes 

The forecast of the total number of tonnes of ferrous metal, glass, non-ferrous metals, paper and 

cardboard, plastic and textiles wastes sent to OECD countries is shown below. 

Table 25 Forecast of tonnes of exports of wastes to OECD countries for the period 2019-2030 

Total numbers of shipment notifications 

As noted earlier, a number of wastes are subject to notification under the WSR. However, one 

notification does not necessarily apply to only one shipment does not necessarily equate to one 

notification. In fact a notification can be made for a single shipment of one type of waste (single 

notification) as well as for multiple shipments of waste (under Article 13 that addresses general 

notification) to be carried out over a certain period of time, provided the waste in question has 

essentially similar physical and chemical characteristics and will regularly be shipped to the same 

recovery facility by the same exporter via the same customs offices of entry and exit. 

There is a lack of precise data on the number of shipments per notification, however it is understood 

that most notifications are “general” and can range from a few to hundreds of shipments. Based on 

data from 15 Member States, competent authorities process 10 230 notifications per year.41 This is on 

average 682 notifications per Member States, which when extrapolated to all 27 Member States equals 

18 414 notifications per annum across the EU. When applied to the volumes of notifiable wastes 

shipped, on average each notification addressed 56.642 shipments within the EU. 

41 Based on inputs provided directly by Member State competent authorities. The Member States include BE*, IT, LU, 
DK, LT, CZ, FI, AT, SI, PT, SK, IE, DE*, LV, MT. For BE and DE not all regions provided data. Furthermore, for DE, one 
regions data was omitted as it being an outlier in high number of notifications provided (one per shipment), which is 
not a usual trend across all Member States. 
42 Calculated from total 2018 shipments of notified waste (1 042 800) divided by total EU27 notifications processed in 
a year for all wastes (18 414).  

77 

Waste type201020112012201320142015201620172018Ferrous metals10,762,1869,747,03610,337,8029,338,3929,149,6437,035,7699,357,91311,041,77211,503,445Glass145,133138,650175,722175,156218,523205,880233,917236,366261,562Non-ferrous metals393,310386,941431,753390,577512,090435,826430,238507,934511,975Paper & Cardboard748,887795,224739,892739,646710,115864,5451,091,9551,306,468997,282Plastic175,079158,742169,714202,559204,179214,759257,338335,523438,921Textiles84,89997,76094,30498,459112,239118,185131,838149,405142,960Notified wastes977,613996,142942,681952,3751,225,5101,185,3991,315,4451,678,1821,677,457Total13,287,10612,320,49412,891,86911,897,16312,132,29810,060,36312,818,64315,255,65015,533,601YearTonnes forecastWaste type201920202021202220232024202520262027202820292030Ferrous metal11,414,86612,761,25412,875,57413,948,44514,338,99714,437,53015,581,52115,980,71516,063,46017,278,57217,686,40617,753,365Glass286,636278,808294,725311,046327,771344,900362,433380,371398,713417,459436,609456,163Non-ferrous metals680,446741,931833,828928,5391,026,0651,126,4061,229,5621,335,5331,444,3191,555,9201,670,3351,787,566Paper and cardboard1,237,9201,346,0351,390,2671,435,1001,480,5341,526,5691,573,2051,620,4421,668,2791,716,7181,765,7571,815,397Plastic516,418545,298574,942605,350636,520668,454701,151734,611768,834803,821839,571876,084Textiles151,722151,929151,738151,141150,138148,728146,912144,690142,062139,027135,586131,738Total14,288,00915,825,25516,121,07317,379,62017,960,02518,252,58719,594,78520,196,36220,485,66721,911,51622,534,26422,820,313Year 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

6  Why should the EU act? 

The existing legal basis of the WSR is Article 192 of the Treaty on the Functioning of the European 

Union that effectively sets the manner in which Article 191 of the Treaty should be implemented. 

Article 191 addresses EU policy on the environment that must contribute to pursuit of the following 

objectives: 

• 

• 

• 

• 

preserving, protecting and improving the quality of the environment, 

protecting human health, 

prudent and rational utilisation of natural resources, 

promoting measures at international level to deal with regional or worldwide environmental 

problems, and in particular combating climate change. 

The WSR already actively contributes to all four of these objectives, in particular concerning protection 

the environment and human health from the impacts of poorly managed transboundary shipments of 

waste and promoting measures at the international level to deal with regional or worldwide problems 

by restricting the types of waste that can be exported to Third Countries. Arguably, the contribution to 

the prudent and rational utilisation of natural resources is the weakest of the four objectives in 

relation to the WSR, but this is clearly one of the sub-challenges identified in the previous section of 

this report that the EU should look to address.  

Additionally, ensuring that waste shipments do not create detrimental impact on environment and 

public health requires the implementation and enforcement of regulations in the same way by all 

Member States to ensure a level playing field and limit unlawful shipments of waste. It is apparent 

from the assessment of the present policy that inconsistencies plague the WSR and are required to be 

addressed to ensure that Member States are implementing the regime the same way. 

The evaluation of the WSR also considered the EU added value of the WSR. It is noted in the conclusions 

of the evaluation that the WSR has provided for greater consistency of approaches across Member 

States and has offered useful extra detail and legal clarity compared to the Basel Convention and the 

OECD Decision. Throughout the consultation that formed an important part of the evaluation, Member 

States underlined the importance of the WSR being implemented consistently throughout the EU.  

Concerning Regulation 1418/2007, it is noted that the Regulation provides useful information on waste 

import regimes in third countries that would otherwise be more dispersed. This information helps to 

reduce EU exports of (non-hazardous) waste that is not wanted in those countries.  

Launching a revised EU initiative further strengthening the provisions of the Waste Shipment Regulation 

to ensure more uniform application, enhancing the links of the Regulation with the circular economy 

actions of the EU and addressing the environmental and human health consequences of the EU waste 

for Third Countries are all more effectively addressed by EU action rather than at a national level and 

point decidedly to the need for the EU to act by revising the WSR and Regulation 1418/2007. 

79 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

7  What are the measures that can contribute 
to addressing the objectives identified? 

7.1  Introduction 

For the purpose of this study we have already defined the objectives to be achieved, being generally 

targeted to address an area in which issues or concerns were raised as part of the evaluation of the 

WSR and that the Commission wishes to address in a potential review of the WSR. However, it is 

important to also be able to identify: 

•  Options to achieve the objectives; and 

•  Measures that fall within specific objectives that substantiate the different options and will 

aim to address the objectives by causing direct and indirect changes. In the case of this study, 

families of measures have been identified (e.g. measures for the harmonisation of 

interpretation, application and enforcement across Member States). 

More information on each of these is provided below. 

7.2  Choice of policy options 

A number of policy options have been identified that could be applied to achieve the three main 

objectives and eight specific objectives sitting beneath them. These options have been derived in close 

discussion with the Commission and were verified in several targeted stakeholder interviews involving a 

small number of Member State, industry and environmental NGO representatives. 

The following options have been considered that generally increase in level of ambition:  

•  Option 1 – The baseline scenario or “Business as usual”: no action at EU level i.e. present 

Regulations and guidance remains unchanged. 

•  Option 2 – “Targeted changes”: specific revisions of WSR would be introduced, building on and 

improving the current structure of the WSR, specifically amending it through changes to 

specific Articles or additional Articles included into the legal text. In addition, a range of 

policy instruments, other than regulatory, are available, such as recommendations, voluntary 

initiatives, guidance documents and best practice, etc. Such measures could be considered as 

complements to some of the measures under option 2. The exact extent of any such 

amendments may lead to a number of sub-options to be considered. 

•  Option 3 – “Structural changes (overhaul)”: the WSR is restructured and fundamental changes 

are done to ensure free circulation of waste within the EU and stop the export of waste outside 

the EU.  

In both options 2 and 3 there may be the need to empower the Commission to adopt 

delegated/implementing acts to implement specific areas of the Regulation or to develop necessary 

guidance for administrations/ competent authorities/operators in relation to the implementation of 

specific parts of the Regulations, to ensure better harmonisation throughout the EU. 

81 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

7.3  Description of the specific objectives and measures to address them 

Those measures that would effectively change the WSR and / or Regulation 1418/2007 either directly 

(through changes to the legal text) or indirectly (through the likes of the introduction of guidance), are 

described in more detail in the following sections. 

  General objective 1 – Ensuring a smoother functioning of the EU internal market for waste and 

supporting the transition to a circular economy  

Specific objective 1a – Align shipments with the waste hierarchy and existing EU legislation 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

There are currently rules allowing Member States to refuse the import of waste from other Member States in 

specific situations. This includes specific rules for shipments of waste for disposal, as well as specific rules for 

shipments of waste for recovery. However, there is no distinction within the Regulation between the types of 

recovery, i.e. between shipments intended for recycling or energy recovery. In addition, Member States have 

increasingly complained about receiving too much waste for landfilling or incineration (with or without energy 

recovery) from other Member States, with the result being that some have Member State have adopted 

restrictions on such imports. 

Short description of the measures 

This measure will address the problems raised above by amending the provisions existing in the current WSR that 

have a direct impact on the preference for treatment options of waste that are higher on the waste hierarchy. 

There are 2 sub-options that have been proposed, one targeted and one comprehensive, with the comprehensive 

option being broader in terms of the change foreseen as well as providing a higher level of environmental 

ambition. 

What is the purpose of this measure for the assessment of impacts? 

Analysing this measure allows for an assessment of the potential costs and benefits of potential changes in waste 

flows as a result of restricting shipments for landfilling and incineration. 

Description of the sub-measures and their assumptions 

Sub-Measure 1a1: A ‘lighter touch’ approach to make it more difficult for Member States to refuse waste 

imported for recycling and easier to deny waste imported for disposal. 

This sub-measure would consist of the refinement of current criteria allowing one Member State to refuse import 

of waste from another Member State in order to promote treatment options higher up the waste hierarchy. This 

can be seen as the ‘lighter touch’ approach as it grants more power to Member States to ensure their waste 

imports follow the waste hierarchy. This will be achieved by: 

• 

Narrowing Article 12 concerning objections to shipments of waste destined for recovery in relation to 

preparation for reuse and recycling activities whilst maintaining powers of objection for energy 

recovery.  

• 

Article 11 concerning objection to shipment of waste destined for disposal could be expanded allowing 

greater power to object to shipments for disposal. 

• 

Provision of guidance on the relationship between the WSR and the waste hierarchy. 

Main assumptions 

82 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 1a – Align shipments with the waste hierarchy and existing EU legislation 

• 

The provisions would be applied universally across the EU and would not result in certain Member States 

choosing lower levels of objection to shipments in their Member State for disposal, simply to 

economically benefit from charges related to such disposal. 

• 

The guidance documentation would allow Central and Southern European Member States, which are 

virtually devoid of waste-to-energy plants, to consider where they would replace landfill operations in 

keeping with the EU Communication on the role of waste-to-energy in the circular economy43. 

Sub-Measure 1a2: Stricter provisions, establishing EU-wide bans of shipments of waste for landfilling, 

decreased possibility for incineration and energy recovery shipments and increased facilitation of shipments 

for recycling / reuse 

This sub-measure goes further than 1a1 by providing stricter provisions effectively via a harmonised EU-wide ban 

on shipments of waste for landfilling, stricter provisions for incineration and energy recovery shipments, and 

whilst facilitating shipments for reuse and recycling. In this respect: 

• 

All shipments of waste for landfilling to another Member State would be prohibited by the legal text of 

the WSR, except in limited and well-justified circumstances (for example for island countries or for 

shipments to landfills in a neighbouring country where this is the closest option). 

• 

Shipments for incineration and recovery would be significantly restricted, only being allowed where 

reuse and recycling is not possible. This would be introduced via introducing a notification procedure 

for all wastes destined for energy recovery (including green listed waste). 

• 

Article 12 concerning objections of waste destined to recovery and recycling would be narrowed in 

keeping with measure 1a1. 

Main assumptions 

• 

• 

The prohibition of shipments for landfilling would not lead to an increase in landfilling activity in the 

Member States generating the wastes that typically end up being landfilled. 

The provision pushes Central and Southern European Member States, which are virtually devoid of 

waste-to-energy plants, to replace landfill operations in keeping with the EU Communication on the role 

of waste-to-energy in the circular economy44. 

Specific objective 1b – Simplification and reduction of administrative burden for intra-EU shipments of waste 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

The WSR contains a number of provisions that have been identified as being particularly burdensome in their 

approach, in particular concerning three key aspects: 

The interchange of notification requests and dossiers, information, consents, and movement documents - The 

administrative burden involved in the processing of documents and information relating to shipments of waste has 

been an ongoing concern for a long time. Back in 2010 the High-Level Group of Independent Stakeholders on 

Administrative Burden (Stoiber Group) estimated that the introduction of an appropriate e-Government system 

that would replace the manual processing of the large amounts of notification and movement documents 

throughout the Union could generate annual savings of up to €44 million. Additionally, an efficient IT solution 

would also contribute to the better implementation and enforcement of the WSR through enhanced traceability 

43 COM (2017) 34 final https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A52017DC0034  
44 COM (2017) 34 final https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX%3A52017DC0034  

83 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 1b – Simplification and reduction of administrative burden for intra-EU shipments of waste 

and transparency. This is an urgent issue and a priority of the European Commission in view of numerous illegal 

waste shipments, notably to third countries.  

In 2014 seven Member States had in place an information system supporting waste notification and/or movement-

related processes and an additional seven had local databases in place45. 14 Member States did not have any IT 

system in place at that time and whilst the number of Member States that have set up a digital interface for 

submitting the documentation necessary to accompany shipments has increased, there remain Member States with 

no digital system in place and the interoperability of Member State systems is considered to be low to non-

existent for a majority of systems in place. 

Pre-consented facilities – Article 14 of the WSR allows competent authorities of destination to issue pre-consents 

to specific recovery facilities under their jurisdiction. The theoretical advantages of attaining this status should be 

a faster delivery period for the consent and a longer lasting period in which shipments can take place. However, 

this advantage has not become a reality so far. This is owing to the fact that the specific procedures for issuing a 

pre-consent are not laid down in the WSR and there is a lack of commonly applied criteria or consistent 

interpretation between Member States of how to grant a facility the pre-consented status or how to implement 

the related shipment procedures. Moreover, the concept of pre-consented facilities is not accepted or trusted in 

all Member States, although it originates from the OECD Decision. Only 15 Member States have been making use of 

the provisions of the WSR on pre-consented facilities and have in total reported a number of 331 pre-consented 

facilities within their borders to OECD46. The other Member States have not reported any facilities and are 

considered not to apply the concept. Further, a number of Member States have been reported not to recognize 

the pre-consented status of facilities in other Member States, and thus the procedure in Art. 14 is often initiated 

but further on not applied by all involved competent authorities. 

Financial guarantees – Article 6 of the WSR requires that transboundary transports of waste, subject to prior 

written notification and consent, require a financial guarantee or that an equivalent insurance is provided. This 

reflects the obligation under the Basel Convention for (a) cases where a shipment or the recovery or disposal 

cannot be completed as intended, and (b) cases where a shipment or the recovery or disposal is illegal. In such 

circumstances the financial guarantee is set up to address: (a) costs of transport; (b) costs of recovery or disposal, 

including any necessary interim operation; and (c) costs of storage for 90 days.  

Stakeholders and competent authorities have highlighted that financial guarantees are very rarely used in order to 

meet the costs of returning waste shipments. Additionally, bank guarantees are reported as expensive, and 

administratively time-consuming. In some Member States the guarantees can be a barrier to ship waste and each 

country has its own approach on financial guarantees (including the levels required): some destination countries 

insist on having guarantees that comply with their own levels, rather than the levels set by the country of origin. 

Similarly, there are differences in the timing of when the guarantee is released: in some Member States, it is only 

released after final treatment, and the money is retained for a longer period. 

Short description of the measures 

45 Trasys (2014) 
https://ec.europa.eu/environment/pdf/waste/shipments/3a_ArchitectureOverview_EDI_for_WSR.pdf   
46 OECD (2021) database on Transboundary Movements of Wastes 
https://www.oecd.org/env/waste/theoecdcontrolsystemforwasterecovery.htm  

84 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 1b – Simplification and reduction of administrative burden for intra-EU shipments of waste 

This measure will address the problems raised above by amending the provisions existing in the current WSR. 

There are 2 sub-options that have been proposed, one targeted and one structural, with the latter being more all-

encompassing in terms of the change foreseen. 

What is the purpose of this measure for the assessment of impacts? 

 Analysing this measure allows for an assessment of the potential costs and benefits of changes to the provisions 

and whether this option would bring additional benefits. Whilst digitisation of documentation has previously been 

examined the data is now somewhat dated and the other changes proposed have not been subject to previous 

assessment. 

Description of the sub-measures to achieve the specific objective and their assumptions 

Sub-Measure 1b1: Targeted changes to the functioning of the current framework 

This sub-measure will consist of the amendment and inclusion of additional separate provisions in relation to the 

digitisation of documentation to accompany waste as well as changes to the pre-consented facility and financial 

guarantee provisions. These are not necessarily to all be applied as a single group of measures. This sub-

measures’ actions are detailed below: 

• 

Setting up and making mandatory the use of an EU-wide Electronic Data Interchange (EDI). This 

addresses the laying down conditions for this EU system and a delegation to the Commission to develop 

the system and related support, within 1 year after entry into force. It should be noted that whilst the 

focus for the purpose of this assessment is on the impacts of an EDI for intra-EU shipments of waste, in 

the longer term this measure should bring added value for extra-EU shipments. Work is ongoing in the 

framework of the Basel Convention to explore electronic approaches to notifications and an EU EDI 

system will be an important asset to bring into that global discussion.  

• 

Setting EU requirements for pre-consented facilities and streamlining the required elements to be 

included in the notification dossier in order to increase the potential of concluding the pre-consent 

procedures within the envisaged 7 working days period. This would be supplemented by an obligation for 

Member States to always take requests for pre-consent into consideration and to mutually recognize 

pre-consented facilities in other Member States. 

• 

Modification of Articles 6(1) and 6(4) on financial guarantees to include more details on how the 

provision should be applied at Member State level and streamline the procedure. Guidance on best 

practices on the use of financial guarantees might also supplement changes to the text of the WSR. 

Main assumptions 

• 

This sub-measure would require investments to develop an EU-wide EDI, training of competent 

authorities and the investments in technologies to allow access to data remotely to be accessible during 

inspection and enforcement activities. 

• 

• 

This sub-measure would lead to an increase in the number of pre-consented facilities across the EU. 

This sub-measure would lower the administrative burden in relation to financial guarantees by 

identifying best practices that offer the necessary level of protection required at the lowest cost. 

Sub-Measure 1b2: Structural change to the functioning of the current framework 

This sub-measure involves supplementing the existing procedural framework with an additional new “light-

touch” approach for shipments of waste destined for preparation for reuse and recycling within the EU. This 

would entail the application for certain waste streams destined to specific facilities of a lighter approach 

instead of the currently applicable procedures. This approach could be based on an EU-wide selection process 

(which may involve permitting/auditing/certification/standardisation) where pre-authorized receiving facilities 

are used for treatment. The measure no longer encompasses a prior informed consent step by competent 

85 

 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 1b – Simplification and reduction of administrative burden for intra-EU shipments of waste 

authorities, but rather relies on self-control by the involved private actors and a posteriori enforcement by 

Member States. 

Main assumptions 

• 

• 

• 

• 

The assumptions applicable under sub-measure 1b1 are the same for 1b2. 

Additionally, the new framework for recycling within the EU would encourage further increase in the 

number of pre-consented facilities for recycling of waste streams subject to the lighter approach. 

The lighter approach would apply to reuse and recycling only. 

The lighter touch approach would be less burdensome than the existing notification provisions. 

Specific objective 1c – harmonisation of interpretation, application and enforcement across 

Member States 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

Classification of wastes and interpretation of other provisions 

Classification of wastes listed in Annexes III and IIIA of the WSR varies across the EU. In particular, the use of 

thresholds for impurities to consider the waste as mixed waste is not applied by all Member States, and if applied, 

the levels may differ. Whilst some Member States allow for relatively high amounts of impurities, other Member 

States classify waste as ‘mixed waste’ if they detect the presence of relatively low quantities of impurities. 

Furthermore, the question of the delineation between what constitutes a “mixture of wastes” and what 

constitutes a contamination was also raised as problematic. Such differences in approaches lead to significantly 

different approaches being taken to similar waste shipments across the EU, leading to uncertainty for operators 

and potential failure to allow wastes to be transported and treated in the most efficient manner. 

More generally, the results of the evaluation of the WSR indicate that there remains a need to harmonise waste 

classification and to further reflect on the relationship between customs codes, End-of-Waste (EoW) codes and 

Basel codes. According to the evaluation the publication in April 2018 of the Commission’s technical guidance on 

the classification of waste47 does not seem to have alleviated the problems that actors face with allocating codes 

under the WSR. 

Member States also interpret, apply and enforce the WSR differently. By way of example, the manner in which 

Member States decide on what is a waste and what ceases to be waste have been repeatedly raised as an 

important problem by actors involved in the shipment and treatment of waste in the EU. General conditions on 

the status of EoW are defined in the Waste Framework Directive48. In practice, competent authorities in the 

Member States retain a large margin of manoeuvre when it comes to deciding on the status of a commodity as 

waste or non-waste. For example, a material can be considered a non-waste in the country of dispatch, but it may 

be classified as a waste in the country of the facility that is receiving the material – which may then cause the 

shipment to be sent back. Similar difficulties arise in respect to deciding whether a waste is hazardous or not. 

Divergent waste classifications and lack of mutual recognition (hazardous versus non-hazardous and waste versus 

non-waste (end-of-waste or by-product)) between Member States disrupt shipments to high quality recyclers and 

results in delays, regulatory uncertainty and unpredictability of shipments.  

47 C/2018/1447 https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv:OJ.C_.2018.124.01.0001.01.ENG  
48 Article 6 of Directive 2008/98/EC on waste and repealing certain Directives https://eur-lex.europa.eu/legal-
content/EN/TXT/?uri=CELEX%3A02008L0098-20180705  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 1c – harmonisation of interpretation, application and enforcement across 

Member States 

Other examples of differences in interpretation and application include: 

• 

• 

• 

• 

• 

the scope of the definition of transit; 

the definition of ‘under the jurisdiction’ under Article 2 and 18; 

specific provisions in Article 16(1) of the Waste framework directive (WFD) with provisions in the WSR 

(Articles 11 and 12) on conditions under which intra-EU shipments of waste can be limited; 

provisions under Article 9 regarding the validity of consents; 

the completion of Annex VII. 

Short description of the measures 

This measure will address the problems raised above by amending the provisions existing in the current WSR. 

There are 2 sub-measures that have been proposed, one targeted and one structural, with the latter being more 

all-encompassing in terms of the change foreseen. 

What is the purpose of this measure for the assessment of impacts? 

Analysing this measure allows for an assessment of the potential costs and benefits of changes to contamination 

thresholds and the impacts that such a change would have on shipments across the EU. 

Description of the sub-measures and their assumptions 

Sub-Measure 1c1: Targeted changes to the functioning of the current framework 

This sub-measure would consist of: 

• 

• 

• 

• 

Provision of guidance on setting appropriate levels of contamination / impurities / mixtures of waste by 

the Commission. 

Provision of further guidance on classification codes that are being interpreted differently across several 

pieces of legislation (notably differences between classification of waste under the EU list of waste 

based on the WFD, customs HS code, Basel Convention and the OECD Decision). 

Provision of guidance on application of end of waste criteria and implications for waste shipments. 

Provision of guidance determining whether a waste is hazardous or not. 

It is important to note that the EDI referred to under measure 1b above may significantly alleviate inconsistencies 

in allocating correct waste codes to shipments. This impact is considered under measure 1b accordingly.  

Main assumptions 

• 

• 

This sub-measure would improve on the guidance already issued by the Commission in terms of the 

classification of waste. 

This sub-measure would lead to an increase in consistency of approaches by Member States to waste 

classification issues. 

Sub-Measure 1c2: Comprehensive change in relation to determining levels of contamination 

This sub-measure includes all of the proposed measures in sub-measure 1c1 but would also supplement the 

existing procedures with a completely new approach. This incorporates a variety of separate actions. Not all 

actions are required to be implemented via one policy package, however all actions are presumed to achieve 

objective 1c. The actions with a completely new approach for sub-measure 1c2 include: 

• 

Set determining levels of contamination for deciding whether a waste is mixed or hazardous by either 

inserting contamination thresholds within the WSR itself or providing a delegation to the Commission to 

determine the correct thresholds in a Delegated Act. 

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Specific objective 1c – harmonisation of interpretation, application and enforcement across 

Member States 

• 

Introducing a new provision in the WSR, establishing a principle of mutual recognition of national EoW 

criteria. Each Member State of transit or destination would be obliged to accept that a commodity 

should be considered as a waste or a product if the Member State of dispatch has taken a formal 

decision on the status (waste or not) of the material concerned. As an alternative solution, it could be 

the decision by the Member State of destination on the status of the materials concerned which could 

prevail, so that the Member States dispatch and transit would have to respect it.  

• 

Introducing a new provision in the WSR, establishing a principle of mutual recognition of national 

decision in relation to the hazardousness nature of a shipment. Each Member State of transit or 

destination would be obliged to accept that a waste should be considered as hazardous or non-hazardous 

if the Member State of dispatch has taken a formal decision on the status of the waste concerned. This 

would be complementary to or replace Article 28 concerning disagreement on classification issues. As an 

alternative solution, it could be the decision by the Member State of destination on the hazardousness 

of the waste concerned which could prevail, so that the Member States dispatch and transit would have 

to respect it. 

Main assumptions 

• 

• 

• 

The assumptions applicable under sub-measure 1c1 are the same for 1c2. 

Additionally, the application of thresholds within a legal text would be universally applied by all Member 

States. 

This sub-measure would remain dependent on the application of end-of-waste criteria under the Waste 

Directive and would not look to amend that Directive in terms of such procedures. 

Specific objective 1d – Better adapt to technical progress and stimulation of innovation 

Why this measure? 

Where does this measure come from and why did this measure emerge? 

Most business operators consider that the WSR is not well adapted to technical and scientific progress arguing 

that too stringent controls and long administrative procedures hinder companies’ abilities to shift to circular 

economy business models. Additionally, they consider a lot of the wastes that are subject to the notification 

procedure (sometimes on the amber list, but more often unlisted mixtures of waste) aren’t actually hazardous 

and should be under green list controls. It should be noted here that the list of hazardous waste stems from the 

Basel Convention and OECD Decision, so that there is only limited margin for changes to the WSR independently 

from the international framework. 

Finally, all stakeholders have systematically reported that the WSR notification system is not adapted to technical 

progress: electronic systems (e.g. for waste movement documents) are used in some cases at the Member State 

level but are not harmonised at EU level. Cross-border procedures still require extensive paperwork, leading to 

missed opportunities to save time as well as documents not arriving or being slow to reach their destination. 

Additionally, there are few opportunities for Member States to share new approaches or best practices at the 

administration level. Whilst IMPEL provides some of this ability at the competent authority level this does not 

necessarily mean that policy makers at the administration level are made aware of new and innovative ways to 

implement the legislation that may hinder the adoption of more effective actions across the EU. 

Short description of the measures 

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Specific objective 1d – Better adapt to technical progress and stimulation of innovation 

This set of measures will address the problems raised above by providing greater delegation to the Commission to 

adapt aspects of the WSR to technical progress whilst providing the ability for Member States to actively share 

best practice in a transparent and accessible manner. 

Only one measure is considered further with these two aspects contained therein. 

What is the purpose of this measure for the assessment of impacts? 

This measure has been considered in a less comprehensive manner than the other specific measures under other 

objectives. That is because the main impacts are believed to ensure a smoother functioning of the WSR and of 

intra-EU shipments of waste, and so they should be positive both from an economic and environmental 

perspective. However, given information was collected on this measure the limited analysis is maintained in this 

report. 

Description of the sub-measure and its assumptions 

Set of sub-measures 1d1: Swifter adaptation to technical progress and sharing of best practices 

This sub-measure would consist of two actions: 

• 

• 

• 

Adapt the amount of waste in art. 3.4 of the WSR not to be subject to the notification procedure 

Providing delegations to the Commission to adapt aspects of the Regulation over time, such as those 

provisions concerning waste classification and notification procedures and related annexes.  

Development of Commission guidance and an EU wide online platform for sharing innovative practices 

and technical progress in the implementation of the WSR. The platform would rely on examples from 

Member States but could also include worldwide approaches for inspiration that would otherwise be 

inaccessible to individual Member States without active engagement on their behalf to actively seek out 

such information. 

Main assumptions 

• 

• 

• 

Small amounts of waste would be exchanged in to run test trials in new technologies to drive innovation 

and efficiency in waste recycling. 

Delegated/Implementing Acts would be used to increase the efficiency of the WSR in the future rather 

than to add unnecessary administrative burden. 

The sharing of best practices would not simply duplicate the work of IMPEL but look to capitalise and 

build on existing best practice sharing practices. 

  General objective 2 – Better guarantee waste shipped outside the EU are managed in an 

environmentally sound manner 

Specific objective 2a – stop or restrict export of waste outside of the EU 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

The current EU rules already ban the export outside of the OECD of hazardous waste, as well as other specific 

waste streams (household waste, unsorted plastic waste). For other types of waste (“green-listed” waste), the 

export outside the OECD is regulated by specific rules (Article 37 of the WSR and Regulation 1418/2007), which 

require that the Commission contacts all third-countries to find out what their domestic rules are with respect to 

import of such waste.  

Notwithstanding these rules, export of waste outside the OECD has dramatically increased since the adoption of 

the WSR in 2006, creating important environmental and public health challenges in countries of destination. 

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Specific objective 2a – stop or restrict export of waste outside of the EU 

Changes of policies in importing countries (China in the first place, followed by others, notably in South-East Asia) 

which increasingly refuse to accept waste from abroad have also exposed the vulnerability of the tendency for EU 

operators to ship waste abroad instead of treating them domestically.  

For export to OECD countries, the principle so far is that the same rules apply as for trade within the EU, although 

there are some exemptions (as in the case of plastic waste following the recent changes in the Basel Convention 

thereon, for which the rules on export of plastic waste are stricter if the waste is destined to the OECD, compared 

to intra-EU shipment). Legally speaking, shipments of waste for recovery to OECD countries are governed by the 

OECD Decision, which is implemented into EU law through the waste shipment regulation.  

Restrictions to exports of waste outside the OECD are also likely to divert exports to OECD countries. Indeed, the 

export of waste to non-EU OECD countries has also increased, in particular to Turkey which is currently the 

biggest importer of waste from the EU. While there is a presumption that waste management systems in the OECD 

are of higher quality than outside the OECD, it is questionable whether an equivalent waste management 

conditions exists throughout all OECD countries.  

In 2019, the export of waste outside the EU amounted to 31 million tonnes of waste, with a value of €13.4 billion. 

This represents a significant loss of resources for the EU circular economy.  

Finally, ‘The European Green Deal notes that the EU should stop exporting its waste outside of the EU. 

Short description of the measures 

The aim of the measures is to prohibit or restrict exports outside the EU of waste that have potentially harmful 

environmental and health impacts in third countries or can be treated domestically within the EU. This should 

help ensure Environmentally Sound Management of waste in the EU and, in the case or further restrictions, in 

third countries, by focusing on countries of destination, problematic waste streams, and types of waste operations 

that are a source of concern. 

There are five sub-measures considered that increasingly restrict exports of waste to third countries. 

What is the purpose of this measure for the assessment of impacts? 

The potential prohibition or further restriction of export of wastes to third countries would have significant 

impacts on the flows of waste from the EU as well as within the EU. It would also have led to changes in waste 

management within the EU as waste that would have been exported will have to be dealt with within the EU 

instead. Given the scale of these possible impacts, it is important that an analysis of the impacts of such 

measures is performed.  

Important assumption for all sub-measures 

• 

Illegal shipments of waste are likely to still take place under a business-as-usual approach to 

enforcement under all sub-measures below. Consequently, the success of the sub-measures is depending 

on action taken under other measures to address enforcement with simple introduction of the sub-

measures listed below unlikely to be fully successful without those other measures, notably on 

enforcement. 

Description of the sub-measures and their assumptions 

Sub-Measure 2a1: Maintain the current legal regime and facilitate its implementation 

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Specific objective 2a – stop or restrict export of waste outside of the EU 

This sub-measure would consist of maintaining the current legal regime of Regulation 1418/2007 but improving its 

operation in relation of exports to third countries outside the OECD. To this effect the measure would establish 

the mechanism by which data is collected from third-countries and provide for the information gathered to be 

placed onto an interactive web platform that can be updated without having to update the Regulation itself, 

which takes time and adds little value. 

Main assumptions 

• 

• 

The method of collecting information would remain the same i.e. timely requests to non-OECD third 

countries to update information on import rules for waste in those non-OECD third countries. 

Member States would agree to allow the Commission to upload data provided by Third Countries onto a 

web platform without their legislative oversight for every change of data provided. 

Sub-Measure 2a2: Ban export of all waste outside the OECD, except for third countries which notify the EU of 

their willingness and readiness to import such waste 

This sub-measure goes further than 2a2 by providing that the waste shipment regulation would prohibit export of 

waste outside the OECD by default. However, non-OECD countries that notify the Commission of their willingness 

to import certain green-listed wastes whilst demonstrating their ability to deal with such wastes in an 

environmentally sound manner would be able to import waste from the EU. Regulation 1418/2007 would be 

repealed and, instead an implementing or delegated power would be provided under the WSR for the Commission 

to provide and update the list of approved countries. 

Main assumptions 

• 

• 

• 

• 

• 

Third countries would need to be informed in due time of the new regime, which would not become 

effective immediately upon entry into force of the revised WSR; 

The criteria for demonstrating that 3rd countries are able to manage waste exported from the EU would 

need to be defined, either in the WSR or through delegated/implementing act by the Commission; 

The list of countries eligible to import waste from the EU could be regularly updated, depending on the 

interest by 3rd countries to be included in that list;  

All green-listed wastes can be considered to be included in this sub-measure and it would be for the 

country of import to specify which types of waste it would be willing to import; 

This would require that the Commission undertakes additional tasks and would therefore imply that 

additional resources are made available to the Commission 

Sub-Measure 2a3: Require that the export of green-listed waste outside the OECD is subject to the “prior 

written notification and consent” procedure 

Currently, under Article 37 of the WSR and Regulation 1418/2007, non-OECD countries are asked on their 

requirements as regards imports of green listed wastes. They can thereby indicate one of three options with 

regard to the import of waste being: 

a.  A prohibition; or 

b.  A procedure of prior written notification and consent as addressed in Article 35 of the WSR (thereby 

applying the same provisions as for exports of waste for disposal to EFTA countries); or 

c.  No control in the country of destination. 

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Specific objective 2a – stop or restrict export of waste outside of the EU 

Under this sub-measure, the export of green listed waste to such countries would in any case require the 

application of prior written notification and consent. 

Main assumptions 

• 

• 

• 

• 

Third countries would be willing to accept application of prior written notification and consent 

procedures for certain waste streams. 

All green-listed wastes would be subject to the changes concerned. 

This would result in additional workload for EU companies exporting waste outside the EU, as well as for 

competent authorities in the MS which would need to process additional notifications 

It would not necessarily increase legal clarity, as some importing countries may impose an import ban, 

or no rules at all, and would not be ready in case they receive notification requests. 

Sub-Measure 2a4: Restrict exports to OECD countries 

The OECD Decision C(92)39/FINAL addresses transboundary movements of wastes destined for recovery operations 

between OECD Member Countries. The Decision provides a framework for the OECD member countries to control 

transboundary movements of recoverable wastes within the OECD area in an environmentally sound and 

economically efficient manner and, compared to the Basel Convention, it provides for a simplified regime for 

controlling such movements of wastes. It also facilitated transboundary movements of recoverable wastes 

between OECD member countries in the case where an OECD member country is not a Party to the Basel 

Convention. This is particularly important in relation to the US, which is not a Party to the Basel Convention. 

This sub-measure would look to curtail exports of wastes to OECD countries by either: 

• 

• 

aligning the regime for OECD countries with the regime applying to other third countries; or 

requiring that the “prior written notification and consent” procedure be applied for some green-listed 

wastes which present particular challenges for their treatment (following the example of plastic waste).  

Main assumptions 

• 

The OECD Member Countries would be willing to accept the change proposed and either consider it in 

compliance with the OECD Decision or agree to amend the OECD Decision to allow the EU to apply these 

additional restrictions. 

• 

• 

OECD countries would be willing to accept application of prior written notification and consent 

procedures for imports of the waste types concerned. 

The sub-measures foreseen under either 2a2 or 2a3 would also be applied to ensure that movements of 

waste within the OECD are not subject to stricter provisions than those applicable to non-OECD third 

countries as this would likely cause concern for OECD Member Countries. 

Sub-Measure 2a5 – Ban export of all waste outside the OECD 

Under this measure, the Regulation would prohibit the export of waste to countries located outside the OECD. This 

would avoid that waste are shipped to the most vulnerable 3rd countries and be less extensive that the first 

option. The compatibility of this measure with WTO rules could still be challenged. In addition, it would present 

the risk of re-directing waste shipments towards some OECD countries which do not have adequate waste 

management facilities. 

Given the concerns expressed in relation to the treatment of wastes in countries outside of the EU and OECD, the 

circular economy objectives of the EU, the proximity principle in relation to waste and the wider environmental 

impacts of long-distance transport of waste, this measure looks to effectively ban export of all wastes to non-

OECD third countries from the EU. 

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Specific objective 2a – stop or restrict export of waste outside of the EU 

Under this sub-measure: 

• 

A possible transition period to phase in this prohibition could be applied (i.e. this ban would become 

effective x years after the entry into force of the publication of a revised WSR). 

• 

The ban could be targeted at specific waste types only. 

Main assumptions 

• 

Parties to Basel Convention would not consider this measure at odds with that agreement or be willing 

to accept changes to those agreements to take into account the decision of the EU to take such 

unilateral action. This is important because whilst the EU may no longer export wastes it may still wish 

to import wastes for which the controls under the Basel Convention would remain relevant.  

• 

The prohibition could apply to all waste types at the same time or to specific waste types over different 

timescales. 

Sub-measure 2a6: Ban all exports of waste from the EU to third countries 

The most straight forward measure would be to establish a complete ban on all export of waste from the EU and 

implement the Green Deal ambition. 

Given the concerns expressed in relation to the treatment of wastes in countries outside of the EU, the circular 

economy objectives of the EU, the proximity principle in relation to waste and the wider environmental impacts of 

long-distance transport of waste, this measure looks to effectively ban export of all wastes from the EU. 

Under this sub-measure: 

• 

A possible transition period to phase in this prohibition could be applied (i.e. this ban would become 

effective x years after the entry into force of the publication of a revised WSR). 

• 

The ban could be targeted at specific waste types only. 

Main assumptions 

• 

Parties to the OECD Decision and Basel Convention would not consider this measure at odds with those 

agreements or be willing to accept changes to those agreements to take into account the decision of the 

EU to take such unilateral action. This is important because whilst the EU may no longer export wastes 

it may still wish to import wastes for which the controls under the OECD Decision and Basel Convention 

would remain relevant.  

• 

The prohibition could apply to all waste types at the same time or to specific waste types over different 

timescales. 

Specific objective 2b – verify ESM in destination countries 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

The revision of the WSR in 2014 led to the strengthening of the provisions on inspection and control applying to 

green listed waste. Under those provisions, in order to ascertain whether a shipment of green-listed waste 

destined for recovery is in accordance with the requirements related to environmentally sound management, the 

inspection authorities may require the person who arranges the shipment to submit relevant documentary 

evidence, provided by the interim and non-interim recovery facility and, if necessary, approved by the competent 

authority of destination. Where the evidence has not been submitted to the authorities within the period 

specified by them, or they consider the evidence and information to be insufficient to reach a conclusion, the 

shipment concerned is considered as an illegal shipment. Experience shows, however, that the export of “green 

listed wastes” is often not controlled by national authorities as closely as the export of “notified wastes”. It is 

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Specific objective 2b – verify ESM in destination countries 

thus not always clear whether (and how) operators and authorities ensure that exported waste is treated in an 

environmentally sound manner.  

A Eunomia study issued in 201949 study was carried out to support the implementation of reporting obligations 

resulting from the new provisions on the waste framework legislation adopted in 2018. This study identified good 

practices and means of demonstrating compliance in ensuring that waste that has been exported for recycling 

outside the European Union is recycled in conditions broadly equivalent to EU standards. New rules on the 

reporting of data on waste under the Waste Framework Directive were also adopted in June 2019. These rules 

require Member States to provide a detailed description of measures to ensure that the exporter can prove that 

the shipment of waste complies with the requirements of the WSR and that the treatment of waste outside the 

Union took place under conditions that are broadly equivalent to the requirements laid down in relevant Union 

environmental law. This information, to be reported in the future by Member States, together with the further 

exploration of the findings of the before mentioned study, should help getting more elaborate views on how to 

best implement these provisions. 

Despite the actions taken above, ensuring that the treatment of EU waste by third countries is undertaken in an 

environmentally sound manner remains problematic.  

Short description of the measures 

This measure looks to give greater transparency to third-country treatment of EU waste by: 

• 

Strengthening the obligations on Member States and those involved in the shipment of waste with regard 

to their responsibilities (including Producer Responsibility Organisations) in ensuring that exported waste 

is managed in an environmentally sound manner; and 

• 

Strengthening the checks undertaken at the EU level to ensure that such environmentally sound 

management is taking place. 

There are two sub-measures considered with these mechanisms in mind. 

What is the purpose of this measure for the assessment of impacts? 

An assessment of this measure will consider the extent to which the measures concerned would actually have the 

desired effect of addressing management of EU waste in third countries given the shortcomings that have been 

identified in approaches taken to date.  

Description of the sub-measures and their assumptions 

Sub-Measure 2b1: clarify the criteria which should be taken into consideration to assess if waste treated in 

3rd countries are managed in an environmentally sound manner 

This sub-measure would consist of changes to Article 49 concerning protection of the environment by further 

restricting the language in relation to determining ESM in third-party countries. This could include: 

Short description of the measures 

• 

• 

Requiring that the provisions of Article 13 of the Waste framework Directive be respected by third 

countries in their treatment of EU waste (currently this only applies to intra-EU shipments). 

Remove the reference to broad equivalence in Article 49(2) for third-country treatment and require 

absolute equivalence or better. 

49 Eunomia et al. (2019) https://op.europa.eu/en/publication-detail/-/publication/3d72ef00-bcac-11e9-9d01-
01aa75ed71a1  

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Specific objective 2b – verify ESM in destination countries 

• 

Requiring the application of the guidelines issued under the Basel Convention in Annex VIII in all cases 

rather than stating that they may be considered. 

Main assumptions 

• 

• 

The guidelines in Annex VIII to the WSR ensure the environmentally sound management of the wastes 

within their scope. 

Member States and producers would both be required to take action under the revised Article 49 to 

ensure its success in addressing the issue of ESM in third countries. 

Sub-Measure 2b2: Creation of a dedicated body at the EU level with the task to monitor export of waste as 

well as their treatment in third countries 

This sub-measure looks to address the issue of verifying appropriate treatment of waste in third countries by 

creating a body with the responsibility to perform checks to ensure that this is the case. The body concerned 

would have the power to: 

• 

• 

• 

• 

Check the records held by producers, holders, collectors, dealers, brokers, consignees and notifiers in 

relation to shipments undertaken allowing traceability across the entire shipment process. 

Perform inspections of shipments in process. 

Perform inspection of the consignee facilities to confirm that waste is being suitably treated in keeping 

with the obligations for third-country shipments of waste from the EU. 

Notify non-compliance to the European Commission for further action to be taken through EU 

compliance processes. 

Main assumptions 

• 

• 

• 

• 

The body would be independent from those over which it would have the power of inspection. 

Third countries would be willing to allow EU inspectors to visit their waste management facilities or 

provide records upon request. 

The body would not have the power to begin prosecutions but could provide evidence of non-compliance 

for the Commission to take further with the Member State(s) concerned. 

Sufficient resources should be foreseen in order to ensure the proper functioning of this body. 

  General objective 3 – Better prevent and address illegal shipments of waste 

Specific objective 3a – Further strengthen provisions on enforcement and inspections 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

One of the underlying reasons for the persisting occurrence of illegal shipments of waste in the EU is the lack of 

uniform enforcement throughout the EU. Since 2018, following the 2014 amendments of the WSR on enforcement 

Member States must report annually on the measures they take to address illegal shipments of waste (inspection 

plans). At the moment, general information on the prevention and handling of illegal shipments is reported, with 

some details on the number of inspections and detected cases. The existence of national or regional inspection 

plans is reported, but not the plans themselves. There are furthermore no mechanisms foreseen in the current 

WSR reporting obligations to compare or otherwise assess these plans and the resulting outcome on the ground. 

The only official forum where these issues are debated at the EU level is the waste shipment correspondents 

meeting which convenes once a year. However, experience shows that enforcement issues only feature as a minor 

point on the agenda of these meetings. Moreover, the group of correspondents seems to be limited in its 

capability to serve as a body to really steer cooperation against illegal waste shipments across the EU from an 

operational point of view.  

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Specific objective 3a – Further strengthen provisions on enforcement and inspections 

Short description of the measures 

This measure looks to improve enforcement and inspections in the EU by: 

• 

• 

Improving access to data on enforcement and inspections at the EU level, in order to improve 

information on the features of illegal waste shipment operations and reinforce action to address them. 

Strengthening the provisions on enforcement and inspections, including the potential establishment of 

an EU body dedicated to waste shipment enforcement. 

There are two sub-measures considered with these mechanisms in mind. 

What is the purpose of this measure for the assessment of impacts? 

An assessment of this measure will consider the extent to which the measures concerned would actually have the 

desired effect of addressing management of EU waste in the EU given the shortcomings that have been identified 

in changes in the WSR on the same topic made to date.  

Description of the sub-measures and their assumptions 

Sub-Measure 3a1: improve reporting on inspections and enforcement and its follow-up 

This sub-measure would consist of changes to Article 50 concerning enforcement in Member States by: 

• 

Requiring that the inspection plans drawn up under that Article are made available to the Commission, 

with the assurance that confidential information is protected and remains confidential. Further 

requiring that the Commission is mandated to assess these plans and produce regular reports to the 

attention of the Member States to help steering enforcement activities, notably through a description of 

the main features and recent trends in illegal waste shipment activities. 

Main assumptions 

• 

None 

Sub-Measure 3a2: Creation of a dedicated body at the EU level with the task to monitor and improve waste 

shipment enforcement 

This sub-measure looks to address the issue of lack of coordination and oversight at the EU level of enforcement 

activities within the EU under present bodies. Under this measure: 

• 

A dedicated group would be created that would address waste shipment enforcement to share best 

practices, intelligence and activities ongoing. This group would take the form of a Commission Expert 

Group bringing together those bodies relevant for enforcement of the WSR – namely competent 

authorities, customs authorities, Europol, OLAF and the judiciary of the Member States. 

Main assumptions 

• 

• 

• 

The body would not have the power of inspection across the EU. 

The body would not be used as a compliance body for the EU to commence actions against Member 

States resulting from the meetings held or any documents shared by the group’s members. 

Sufficient resources should be foreseen in order to ensure the proper functioning of this body. 

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Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and national 

levels and strengthen cooperation across the EU and with international partners 

Why this specific objective? 

Where does this specific objective come from and why did it emerge? 

Whilst under measure 3a action would be taken to address inspection and enforcement shortcomings within the 

EUs legislative framework, many of those shortcomings are further exacerbated by a lack of priority given to 

enforcement and inspection activities in the EU. Furthermore, illegal shipments do not end at the EUs borders and 

there is a need to improve cooperation with international partners. This measure would look to address these 

shortcomings in relation to illegal waste shipment activities. 

Short description of the measures 

This measure looks to improve enforcement and inspections beyond the EUs borders by: 

• 

Sharing information on practical inspection and enforcement issues like the development of sanctions, 

prioritising inspection activities and resources. 

• 

Enhancing cooperation with inspection and enforcement bodies beyond the EUs borders. 

There are two sub-measures considered with these mechanisms in mind. 

What is the purpose of this measure for the assessment of impacts? 

An assessment of this measure will consider the extent to which the measures concerned would assist in 

addressing the governance needs of EU Member States as well as in the fight in international waste shipment 

crime.  

Description of the sub-measures and their assumptions 

Sub-Measure 3b1: develop guidance on efficient inspections and enforcement 

This sub-measure would consist of development of EU guidance addressing: 

• 

• 

• 

• 

sanctions and penalties 

intelligence led inspection activities 

prioritising action to address illegal waste shipments 

efficient use of staff to maximise impact on illegal activities 

Main assumptions 

• 

• 

Member States will be willing to share the information on the above matters freely. 

Member States will duly make use of the provided guidance. 

Sub-Measure 3b2: Enhancing cooperation with inspection and enforcement bodies beyond the EU’s borders 

This sub-measure looks to work closer with third countries to improve enforcement, including through support to 

projects and cooperation at bilateral, regional, and global levels, notably through the Basel Convention, World 

Customs Organisation, UN office on Drugs and Crime and Interpol. Support under this measure would include: 

• 

• 

Financial support from the EU to bilateral, regional and global projects. 

Advocating at the global level the setting up of a group representing the international organisations 

above and providing EU support to that group to share best practices, intelligence and activities 

ongoing. 

Main assumptions 

• 

Third countries and organisations would see value in the sub-measures proposed. 

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8  What are the impacts of the different 
options and measures and who will be 
affected? 

8.1  Introduction and initial screening 

The present chapter summarises the main impacts that could be expected from the implementation of 

individual Options and measures identified in Section 9. All of the options can have economic, social 

and environmental impacts through a variety of mechanisms. Based on desk research and interviews 

with stakeholders, the most significant impacts have been screened in more detail. The following table 

presents a synopsis of impact categories that have been screened along with the outcome of this 

screening process, the main types of expected impacts being then assessed in more detail and 

presented in the following sections.  

Table 26 Initial assessment (screening) of expected impacts 

IMPACT CATEGORY 

ASSESSMENT 

JUSTIFICATION 

FURTHER 

ECONOMIC 

(YES/NO) 

Growth and investment 

Yes 

and investment, particularly in relation to waste volumes and 

The measures would in some cases significantly impact on growth 

management capacity within the EU. 

Some options may have an effect on the cost of waste management 

of imported wastes as well as potential impacts on certain sectors 

Sectoral competitiveness 

Yes 

involved in manufacturing of products (original equipment 

Facilitating SME growth 

Yes 

manufacturers) or use of waste that are processed back into 

secondary materials. 

Particularly in relation to SMEs involved in waste transfer and 

waste management in the EU. 

development and digital 

Yes 

Some impact is expected through the digitisation of data and its 

subsequent access during inspection activities. 

Achievement of the Single 

Market 

Increased innovation and 

research 

Technological 

economy 

Increased international 

trade and investment 

Competition 

In some cases, there is expected to be a positive impact on the 

Yes 

single market through streamlined processes in relation to reuse, 

recycling and recovery . 

In relation to the development of new processes to handle EU 

Yes 

wastes that are presently sent to third countries for treatment but 

would now be treated within the EU. 

Yes 

No 

One of the impacts is a likely reduction in trade in waste and 

secondary materials with third countries 

None of the questions in the competition checklist are answered 

yes - Do proposed policy options have any of the following effects: 

i) Limit the number or range of suppliers; ii) Limit the ability of 

suppliers to compete; iii) Reduce the incentive of suppliers to 

99 

 
Exploration of potential policy responses to review the Waste Shipment Regulation 

IMPACT CATEGORY 

ASSESSMENT 

JUSTIFICATION 

FURTHER 

(YES/NO) 

compete; and iv) Limit the choices and information available to 

customers? 

No 

No 

As impact of the options on energy use will be negligible, this 

category will not be further assessed. 

There will be no effect on the monetary Union, therefore this 

category will not be further assessed. 

Energy dependence 

Deeper and fairer 

economic monetary union 

SOCIAL 

Employment 

Yes 

sectors in particular would be apparent under some of the 

Impacts on employment in the waste transfer and management 

Working conditions 

No 

significant extent. The social impacts on third countries in respect 

measures. 

Working conditions within the EU are unlikely to impacted to any 

Income distribution and 

social inclusion 

Health and safety 

Education 

Security 

Governance and good 

administration 

Preserving the cultural 

heritage/ multi-linguism 

Crime. Terrorism and 

security 

Social protection, health 

and education systems 

Cultural heritage 

ENVIRONMENTAL 

No 

No 

No 

Yes 

to working conditions are considered where relevant. 

Income distribution and social inclusion within the EU are unlikely 

to be impacted to any significant extent. 

Human health is considered in respect to the environmental 

impacts stemming from waste management activities. 

No impact identified. 

Increased enforcement and inspection measures in particular are 

likely to impact on security as a whole. 

Certain measures look to improve governance and support better 

Yes 

administration of resources in the implementation of waste 

shipment policy. 

No 

No impact identified. 

Yes 

Particularly with regard to waste crime. 

No 

No 

No impact identified. 

No impact identified. 

Fighting climate change 

Yes 

up the waste hierarchy as well as generally reducing long-distance 

A number of options that would promote waste treatment further 

Fostering the efficient use 

of resources 

Preserving the quality of 

natural resources/ 

fighting pollution 

Protecting biodiversity, 

Yes 

Yes 

flora, fauna and 

Yes 

landscapes 

transfers of waste would reduce climate emissions. 

As one of the main challenges to be addressed the policy measures 

considered would look to significantly change resource flows. 

Positive impacts would derive from several of the measures 

concerning the impact of wastes subject to waste shipments. 

Positive impacts would derive from several of the measures 

concerning the impact of wastes subject to waste shipments. 

100 

Exploration of potential policy responses to review the Waste Shipment Regulation 

IMPACT CATEGORY 

ASSESSMENT 

JUSTIFICATION 

FURTHER 

Minimizing environmental 

risks 

(YES/NO) 

Yes 

Positive impacts would derive from several of the measures 

concerning the impact of wastes subject to waste shipments, 

particularly concerning environmentally sound management of 

wastes. 

Protecting animal welfare 

No 

No impact identified. 

OTHER 

Economic and social 

cohesion 

Impact on developing 

countries 

No 

Vulnerable groups are unlikely to be specifically impacted within 

the EU through the measures identified. 

A number of the measures would have significant impacts on 

Yes 

developing countries, in particular those restricting flows of wastes 

to such countries for treatment. 

All suggested policy options will bring certain environmental 

benefits that are aligned with a sustainable development. Impacts 

Sustainable development 

Yes 

such as limiting the impacts of waste on the environment and 

promoting resource reuse will contribute to sustainable 

development. 

Fundamental rights 

No 

No impact identified 

The following sections present the results of the assessment by policy objective.  

8.2  Economic impacts of measures 

  Specific objective 1a – Align shipments with the waste hierarchy 

In regard to a lighter touch approach on waste for reuse and recovery processes, stakeholders from 

the open public consultation supported the sub-measure over all other options, however they provided 

little-no quantitative evidence to support / illustrate the environmental impacts associated with this 

measure.  

In a poll during the workshop, participants were asked how a ‘lighter touch’ procedure for certified 

waste destined for reuse or recycling would function in practice. A total of 31 stakeholders provided a 

response. 17 of these stakeholders suggested ways in which a ‘lighter touch’ could be implemented: 

• 

Pre-consented/certified facilities were outlined as an area where the lighter touch could 

apply (7 stakeholders). This should only be done for regularly audited and high-quality certified 

recovery facilities. One stakeholder suggested modelling this system on the European list in the 

Ship Recycling regulation; 

•  A focus on Annex VII was outlined as a means to apply the lighter touch approach (4 

stakeholders). Most stakeholders outlined that it should be mandatory to have this Annex 

included for shipments with a lighter touch. This assumes electronic submission and 

harmonised enforcement across MSs in the use of Annex VII. 

•  Other measures were suggested by six stakeholders. These include a variety of approaches 

including allowing free waste shipment within the internal market, solving inefficiencies of PIC 

procedure, and tacit consent. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Based on the data from the model, in 2018 there was a total of 3 775 255 tonnes of hazardous waste 50 

shipped for non-R1 recovery practices (out of a total 20 856 000 tonnes of hazardous waste shipped for 

all disposal and recovery activities). Based on the assumption that intra-EU shipments on average 

contain around 20 tonnes per shipment,51 it can be assumed that 188 763 shipments of hazardous waste 

for non-R1 recovery were made inside the EU (out of 1 042 800 shipments for all notified waste). Owing 

to its status as hazardous waste, prior informed consent forms were necessary for shipment. However, 

one shipment does not necessarily equate to one notification, as general notifications (Article 13) can 

cover multiple shipments. There is a lack of data on the number of shipments per notification, however 

it is understood that most notifications are “general” and can range from a few to hundreds of 

shipments. Based on data from 15 Member States, competent authorities process 10 230 notifications 

per year.52 This is on average 682 notifications per Member States, which when extrapolated to all 27 

Member States equals 18 414 notifications per annum across the EU. This shows that in 2018, on 

average each notification was processed per 56.653 shipments within the EU. This assessment assumes 

that under a ‘lighter touch’ a certain percentage of the total waste currently shipped will no longer 

require such prior informed consent or would require lighter notification requirements. For the 

purposes of this assessment, we assume that this could affect either 10%, 20%, or 30% of current 

hazardous waste intended for non-R1 recovery processes. The three assumptions would result in 

between 18 876 – 56 629 fewer shipments for non-R1 recovery processes. When factoring that an 

average notification equates to 56.6 shipments, this lighter touch would reduce between 333 – 1 000 

notifications per annum (1.8% - 5.4% of total notifications processed). There is a lack of data on the 

average shipment notification costs for hazardous waste intended for recovery, however these figures 

represent a relatively small economic savings for both business operators and Member State competent 

authorities. This measure is however assessed as being less beneficial than process related measures for 

reducing the number and effort to file a notification such as in specific objective 1b. This is because 

this measure would reduce the number of notifications (potentially by a small amount) that Competent 

Authorities would need to process, whereas 1b would reduce the burden of all notifications.  

Some stakeholders from the workshop warned that not applying the prior informed consent (PIC) 

procedure for hazardous waste intended for recycling would not be in line with the Basel Convention. 

Therefore, this sub-measure would need to find alternatives to be within international law, or 

international law would need to be adjusted. This view was supported by two industry stakeholders, an 

environmental NGO, and a Member State. One noted that proper regulation is required to protect 

environmental standards and one stated that a lighter touch could only be considered for non-

hazardous waste.  

On a stronger grip on waste for energy recovery, incineration and for landfilling, there was divided 

opinions on its implementation. This is clear from a poll hosted during the workshop (see Figure 45). 

The largest share of stakeholders agreed that both waste for energy recovery and landfilling should be 

50 In additional to hazardous waste, notified waste includes mixed household waste, residues from the incineration of 
household waste and certain other waste types. Eurostat data does not show the levels of exports of notified wastes 
per disposal and recovery type. Therefore, data for hazardous waste for non-R1 activities were used instead. 
51 This is based on 15 million tonnes from 750 000 shipments of green-listed waste shipped from the UK (on average, 
20 tonnes per shipment).  
IEEP and IMPEL (2011) “Practicability and enforceability of the Waste Shipment Regulation”. See here. 
52 Based on inputs provided directly by Member State competent authorities. The Member States include BE*, IT, LU, 
DK, LT, CZ, FI, AT, SI, PT, SK, IE, DE*, LV, MT. For BE and DE not all regions provided data. Furthermore, for DE, one 
regions data was omitted as it being an outlier in high number of notifications provided (one per shipment), which is 
not a usual trend across all Member States. 
53 Calculated from total 2018 shipments of notified waste (1 042 800) divided by total EU27 notifications processed in 
a year for all wastes (18 414).  

102 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

limited (22 stakeholders, 34%). However, there were a number of respondents who stated that only 

landfilling should be prohibited (16 stakeholders, 25%), or that neither should be limited or prohibited 

(16 stakeholders, 25%).  

Figure 45 – Workshop Poll: “Should shipments of waste for waste-energy recovery or landfilling be 
limited/prohibited?” (n=65) 

With regard to stricter provisions for energy recovery, this split in opinion was further noted during 

the stakeholder consultation. Four NGO interviewees agreed with restricting the shipment of waste for 

energy recovery facilities – i.e. via requiring Prior Informed Consent (PIC) procedure. Other 

stakeholders perceived that this could incentivise the creation of new recovery facilities across Europe, 

owing to the demand for treatment of the waste no longer being sent for energy recovery. This could 

be seen as leading to an increase in economic activity (energy recovery) across more Member States. 

However, during the workshop several stakeholders outlined that such restrictions and bans would not 

be possible. Two Member States outlined that limiting shipments of waste would not be possible due to 

some Member States lacking capacity to deal with the issues. It is also possible that Member States that 

depend on imports of waste to meet the capacity requirements of their recovery practices could 

become strained if wastes for such treatments were limited. This could for example be the case with 

Sweden, which requires imports to fuel its energy recovery treatment capacity – as this capacity is 

contracted to supply heat54.  

In line with the data from the model (see Error! Reference source not found.), it is possible to view 

the net-exports of waste (hazardous and non-hazardous) from different Member States for the purposes 

of different recovery practices (for the year 2018). For example, countries such as Belgium, Italy, and 

Finland have larger tonnages of export waste for energy recovery (R1). Stricter measures could create 

issues for the local treatment of such wastes. In contrast, Sweden, Slovakia and the Netherlands are 

large importers of waste for energy recovery. For the Netherlands, this is something that is likely to 

decrease following their proposed imposition of a Refuse Derived Fuel (RDF) tax aimed at limiting waste 

imports for waste for energy recovery.55 Nevertheless, with such high net importing rates, their 

facilities could struggle economically (and practically) if imports decrease. The average operational life 

of a waste to energy facility is typically 20-30 years,56 while the economic life (the time in which it is 

54 The New York Times (2018) “In Sweden, Trash Heats Homes, Powers Buses and Fuels Taxi Fleets”. 
55 Cheaper Waste (2020) “RDF Tax. What is it and how could it affect UK Businesses”. 
56 DEFRA (2014) 
https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/284612/pb141
30-energy-waste-201402.pdf  

103 

9%; 625%; 1625%; 168%; 534%; 2205101520255) Don’t know / no opinion4) No, to both3) Yes, waste for landfilling should be prohibited2) Yes, waste for energy recovery should be limited1) Yes, to both 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

profitable) ranges from 15-20 years.57 The costs of operation (OPEX) can be as high as € 52 million per 

year, including labour, equipment repair and maintenance, provisions, depreciation and other costs.58 A 

lock-in of waste-energy infrastructure in net-importing countries could therefore be seen as a 

reasonable economic loss overtime, as a result of stricter provisions for the import of waste for energy 

recovery. 

Table 27 Net-export data for EU27 countries for all wastes, by type of recovery practice (2018, in tonnes) 

Country 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

Luxembourg 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

Net exports - R1 

Net exports - R2 - R10 

Net exports - R-other 

288 621 

-27 442 

0 

-70 863 

104 697 

-66 885 

0 

-10 210 

-5 669 

4 609 

-4 584 

408 931 

0 

2 

983 

-31 160 

-73 930 

0 

-476 195 

121 125 

4 983 

-22 766 

-3 800 

-51 789 

-213 481 

146 890 

-176 180 

2 249 806 

-1 932 

0 

-33 030 

1 817 533 

-13 627 

0 

-10 755 

-233 891 

281 454 

71 696 

-97 880 

-16 196 

70 

13 996 

112 291 

-88 022 

0 

-3 654 529 

65 282 

-240 015 

10 964 

-8 497 

-25 178 

-12 811 

78 388 

19 485 

661 820 

-1 141 

0 

33 416 

-52 081 

-29 845 

0 

-127 

-46 838 

-94 776 

25 

122 074 

0 

-754 

-2 893 

75 337 

-18 145 

0 

-637 374 

-22 454 

0 

-182 

0 

0 

-620 

33 754 

-5 680 

Source: own elaboration, based on data from the Model.  
Note: Data has been conditionally formatted to show the largest exports (blue) and importers (red).  

With regard to a ban on waste shipments intended for landfill disposal, several workshops 

respondents noted that certain waste fractions cannot be recycled and require energy recovery or 

landfilling. In some cases (i.e. toxic plastics), the latter was preferred. Eurostat data shows that across 

57 Shabib & Abdallah (2020) 
https://www.tandfonline.com/doi/abs/10.1080/00207233.2019.1708146?journalCode=genv20 
58 Medina-Mijangos & Segui-Amortegui (2020) 
https://www.sciencedirect.com/science/article/abs/pii/S0956053X20305468  

104 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

the EU27, in 2018, around 833 440 000 tonnes of waste (38% of total generated waste) was landfilled59. 

Within this, Eurostat data further shows that 1 448 660 tonnes of waste was shipped between Member 

States (Intra-EU) for the purposes of landfilling.60 Though only representing 0.17% of total waste 

landfilled, this figure nonetheless represents a concern for most Member States, as discussed in the 

workshops. When viewing the net-exports of all waste for disposal types in 2018 (see Table 27Error! 

Reference source not found.), it is possible to view which Member States will see the largest effects 

from a landfill shipment ban. Portugal, and to a lesser extent France and Germany, will lose out 

economically, by not being able to import wastes for landfill. Italy and Luxembourg would have to 

develop far greater alternative disposal or recovery capacity (or find alternative facilities to export to) 

to deal with the large quantity of landfilled waste that could not be exported. Otherwise most Member 

States remain mostly unaffected. The Netherlands for example has enforced self-sufficiency for 

landfilling practices, prohibiting the export or import of D1 waste.61  

Table 28 Net-export data for EU27 countries for all wastes, by type of disposal practice (2018, in tonnes) 

Net exports - D1, D5, D12 

Net exports - D10 

Net exports - D-other 

Country 

Belgium 

Bulgaria 

Czechia 

Denmark 

Germany 

Estonia 

Ireland 

Greece 

Spain 

France 

Croatia 

Italy 

Cyprus 

Latvia 

Lithuania 

17 306 

0 

0 

3 637 

-12 883 

0 

0 

0 

335 

-13 372 

358 

412 757 

0 

0 

0 

Luxembourg 

221 469 

Hungary 

Malta 

Netherlands 

Austria 

Poland 

Portugal 

Romania 

Slovenia 

Slovakia 

Finland 

Sweden 

0 

0 

-87 

3 224 

3 413 

-46 111 

0 

0 

0 

-167 

1 682 

86 951 

1 177 

0 

2 706 

30 309 

0 

0 

0 

3 790 

21 934 

10 843 

243 764 

25 

0 

689 

-443 

59 

0 

-7 433 

19 091 

0 

1 381 

0 

0 

0 

6 093 

1 645 

9 945 

128 

0 

79 

110 331 

1 

0 

0 

579 

27 863 

1 701 

57 104 

0 

0 

0 

35 168 

0 

0 

-17 

21 

0 

0 

0 

0 

0 

222 

2 211 

59 Eurostat: ENV_WASGEN https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_wasgen&lang=en ; 
ENV_WASTRT https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_wastrt&lang=en  
60 Eurostat: WShipR https://ec.europa.eu/eurostat/statistics-explained/index.php/Waste_shipment_statistics  
61 Dutch Government (2017)  

105 

 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Source: own elaboration, based on data from the Model.  
Note: Data has been conditionally formatted to show the largest exports (blue) and importers (red).  

The implementation report on the waste shipment regulation, published in 201862, provides data on 

objections and exemptions of waste. However, this data only covers notified waste and excludes green-

listed waste (the most shipped waste in the EU). Objections to disposal were already noted by four 

Member States (Belgium, Estonia, Finland, and Spain), amounting to 377 724 tonnes of waste between 

2013 and 2015. For some this was allocated for recovery processes incorrectly and the rest for 

landfilling, incineration or photo-chemical treatment. Three Member States (Finland, Greece, UK) 

completed information on exceptions to the implementation of Article 11, in line Article 11(3). The 

majority of this was for the purpose of incineration on land (D10). Between 2013 and 2015 these 

exceptions included 37 520 tonnes of waste. For the same years, a total of 3 751 093 tonnes of 

hazardous waste for disposal was shipped within the EU. The initial objections amount to a considerable 

amount of hazardous waste. If these objections were not made, it would save Full-Time Equivalent 

(FTE) hours for Member State competent authorities. This could, in turn, save Member States 

administrative burden. Nevertheless, objections were only noted in the four above mentioned Member 

States (one of which, Finland, also providing exceptions for shipments with low tonnages). Therefore, 

there would be little to no efficiency gains for the other Member States, assuming they continued not 

to file objections. 

  Specific objective 1b - Simplification and reduction of administrative burden for intra-EU 

shipments of waste 

Stakeholders participating in the open public consultation and initial targeted interviews supported 

three main approaches to help achieve the simplification and reduction of administrative burden for 

intra-EU shipments of waste; introduction of an electronic data interchange (EDI), pre-consented 

facilities and amendment of the financial guarantee system.  

During the workshop stakeholders provided further details of how each of the approaches could be 

defined. Stakeholders agreed that establishment of an EDI would improve efficiency and transparency. 

With regards to the pre-consented facilities, stakeholders were of the opinion that their procedures 

should be clarified, as this could be helpful in the transition to circular economy. Stakeholders also 

suggested the following ways in which the financial guarantees could be amended: i) EU-wide fund, ii) 

national funds, or iii) insurance company-based system. Figure 45 below presents the support for each 

option for amending financial guarantee:  

62 SWD (2018) 468 final PART 2 https://eur-lex.europa.eu/resource.html?uri=cellar:44a84bd6-ee4e-11e8-b690-
01aa75ed71a1.0001.02/DOC_2&format=PDF  

106 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 46 Workshop poll on the preferred solution for financial guarantee (n=44) 

However, very little quantitative data were provided by stakeholders on the economic impacts of these 

approaches. These impacts have therefore been estimated on the basis of literature review, data 

provided by Member States’ Competent Authorities and a modelling exercise.  

Electronic data interchange (EDI): 

The setting up and operation of an EU-wide EDI carries both economic costs and benefits. 

Concerning costs, setting up a system that either interconnects national electronic notification systems 

or replaces those systems with an EU-wide system will generate costs both in terms of establishment 

and in terms of maintenance of the system. These costs would have to be shared between the EU and 

the Member States.  

• 

In the case of an interconnect that links national systems the costs related to the EU 

component (central routing component, EU platform) would need to be financed from the 

general budget of the EU, whereas Member States would bear the costs needed for the 

adjustment of their national systems to make them interoperable with the EU system.  

• 

In the case of an entirely new system that replaces national systems the costs related to the 

EU component would be financed from the general budget of the EU, while Member States 

would bear the costs for the adjustment of their national systems to make them interoperable 

with the EU system.63 

A previous study undertaken in 2014 that considered the feasibility for the establishment of an EDI for 

waste shipments64, concluded that there were significant differences between Competent Authorities in 

terms of WSR information systems. A large number of countries did not have any electronic system in 

place (14 worked exclusively on paper-based systems) while some countries had a system supporting 

the notification and/or movement documents procedure (7 at that time). The SITT/Lombardia region, 

EDM Austria, eANVportal from FRITZ&MACZIOL group, ZEDAL TFS and LoadIT were identified as the most 

advanced systems for WSR processes. A more detailed examination of two of the protocols highlighted 

that a critical point to consider in an EDI is the enforcement of digital signature that would not have 

been possible for most Member States at the time of the study. However, the entry into force of 

63 COM (2019) 372 final https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52019DC0372  
64 Trasys (2014)  
https://ec.europa.eu/environment/pdf/waste/shipments/4a_Annex%202_Review_of_IT_systems_EDI_for_WSR.pdf       

107 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Regulation (EU) No910/2014 on electronic identification and trust services for electronic transactions in 

the internal market (the eIDAS Regulation65) is likely to have an impact on the manner in which Member 

States can accept electronic signatures so this barrier may well now have been overcome. 

Setting up EU central systems that communicate with national systems is not unique to environmental 

data. In its report to the European Parliament and Council in 2019, the Commission examined 

approaches for setting up an interconnection of national centralised automated mechanisms (central 

registries or central electronic data retrieval systems) of the Member States on bank accounts. 

Depending on the complexity of the system, the cost of an interconnect in terms of set up is 

approximately €2 million, with annual maintenance of costs of €150 000. The cost of participation by 

countries in this system is approximately €20 000 per country.66 These values were derived from the 

associated costs of each specific existing system, summarised in the table below: 

The Commission has also looked to estimate the cost of establishing and maintaining an EDI system 

using its own in-house IT service. The cost of different EDI systems, as provided by the Commission to 

the contractors under this study are included in the table below: 

Table 29 Costs of establishment and maintenance of different EDI systems67 

System 

Establishment costs 

Maintenance costs 

Participation costs 

BRIS 

IRI 

ECRIS 

EUCARIS 

EUR 1 700 000 

EUR 450 000 

EUR 2 050 000 

n/a 

n/a 

n/a 

EUR 150 000 

n/a 

n/a 

n/a 

n/a 

EUR 20 000 

EUR 230 000 for the first two 

Commission ICT 

EUR 480 000 

years and then EUR 113 000 

n/a 

per year from then on 

Based on the table above listing the different costs of different EDI systems, an average has been 

derived to serve as an indication of the cost of setting up an EU-wide EDI for the purposes of the Waste 

Shipment Regulation. These estimated costs are outlined in the table below: 

Table 30 Indicative / approximate costs of establishment of an EDI for the WSR purposes 

Establishment costs 

Maintenance costs 

Participation costs 

EUR 1 170 000 

EUR 164 333 

EUR 20 000 

With regards to determining the savings / benefits in relation to establishment of an EDI, the estimated 

cost savings were first considered in the Commission Staff Working Document accompanying the 

Commission Communication on EU Regulatory Fitness in 201268. The Working Document anticipated 

savings of €44 million per year, with the streamlining expected through such digitisation based on the 

state of Member State electronic systems, at the time of its publication. It is expected, therefore, that 

with the introduction of additional electronic systems since its publication that the savings would now 

be smaller. 

65 Regulation (EU) No 910/2014 of the European Parliament and of the Council of 23 July 2014 on electronic 
identification and trust services for electronic transactions in the internal market and repealing Directive 
1999/93/EC https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=uriserv%3AOJ.L_.2014.257.01.0073.01.ENG   
66 COM(2019) 372 final https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52019DC0372  
67 COM(2019) 372 final https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX:52019DC0372  
68 SWD (2012) 423 final https://eur-lex.europa.eu/legal-content/en/TXT/?uri=CELEX:52012SC0423  

108 

 
 
 
 
  
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

As part of the preparation of this report Member States Competent Authorities were asked to provide 

their data in relation to EDI (as well as notifications and financial guarantees). A total of 22 Competent 

Authorities69 provided data on whether their system is paper-based or whether they make use of an 

electronic data interchange. Out of this total, 8 Competent Authorities answered that they do not make 

use of any sort of EDI. The rest rely (at least partially) on an EDI system. Competent Authorities also 

provided data on how long it takes them to process a single notification, either electronically or paper-

based. Based on this data, it was possible to calculate an EU average time spent on processing 

notifications. This indicate that it takes approximately 10.8h per electronic notification and  

19.5h per paper-based notification. The estimate time spent on electronic notifications has been 

made on several assumptions, as some Competent Authorities have provided a range rather than a 

specific number.70 

Some Competent Authorities also provided data on the total value of their financial guarantees. These 

values differ greatly between different Member States, ranging from approx. 1.5 million in one Member 

State to over 200 million in another Member State.  

Based on this data provided by Member States’ Competent Authorities the time saved when processing 

a notification as a result of an electronic system compared to the paper-based system is 5.7 hours per 

notification, almost 35% less time. Similar savings were identified in the evaluation of the WSR for 

companies completing electronic notifications in comparison to paper-based systems.  

In total, in 2018 Competent Authorities relying on the paper-based system spent 359 073 hours 

addressing notifications, while Competent Authorities who rely upon an electronic system spent 198 871 

hours addressing notifications. The total time spent addressing notifications in 2018 was calculated as 

follows: using the EU average for hours spent on addressing either paper-based or electronic 

notification71 and multiplying it with the total number of annual notifications72.Therefore, the 

introduction of an EDI would, on average, save Competent Authorities 160 202 hours. The time 

saved by introducing the EDI is the difference between time spent on addressing paper-based 

notifications and time spent addressing electronic notifications. If it is assumed that each Competent 

Authority employee is paid EUR 20/h, EUR 3 204 040 could be saved annually as a result of the 

introduction of the EDI. This total saving is calculated by multiplying the time saved as a result of 

electronic notifications systems with a presumed hourly rate of Competent Authority’s employees.  

From the figures above, it appears that the costs of establishment and maintenance of an EU-wide 

interconnection system are relatively low, compared to the benefits to the EU. Cost efficiency could be 

improved by reusing existing capacities (such as eDelivery access points, Connecting Europe Facility 

building blocks, core vocabularies of the European Commission’s Directorate-General for Informatics, 

etc.). 

69 This total also includes several Competent Authorities from different States of Germany (Bundesland) 
70 For example, the CZ Competent Authority provided a range of 8 to 40 hours, where 24 hours have been estimated, 
SK Competent Authority provided a range of 8 to 24 hours, where 16 hours were estimated and MT Competent 
Authority provided a range of 20 to 60 hours, where 40 hours were estimated.  
71 Based on data provided directly by Competent Authorities, see above (10.8h for electronic and 19.5h for paper-
based systems) 
72 As calculated under specific objective 1a, 18 414 notifications 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

The same method of calculation of savings / benefits resulting from the introduction can be used for 

business operators, as was used for Competent Authorities. As such, operators addressing paper-based 

notifications spent 441 936 hours doing so and operators addressing electronic notifications spent 294 

624 hours. These values were calculated using the average time spent addressing a notification73 

multiplied by the total number of notifications. The introduction of an EDI could therefore save 

operators 47 312 hours annually. This value is the difference between the time spent on paper-based 

and on electronic notifications. If it is presumed that operators’ employees are paid EUR 20 per hour74, 

the introduction of an EDI could therefore save business operators EUR 946 240 per year. This is 

calculated by multiplying the time saved by the presumed hourly costs of EUR 20.  

In the table below, the overall findings regarding costs and savings in relation to introduction of an EU-

wide EDI system are summarised:  

Table 31 Overall (annual) costs and savings in relation to EDI introduction75 

Costs of establishment / 

Savings 

Net savings 

participation / maintenance 

Competent authorities 

Business operators 

EUR 20 000 

EUR 20 000 

EUR 3 204 040 

EUR 3 204 020 

EUR 946 240  

EUR 946 220  

European Commission 

EUR 1 281 333 

n/a 

n/a 

Financial guarantee 

Revision of the financial guarantee system could result in harmonising the required amounts of financial 

guarantees between Member States. Some Member States hold hundreds of millions of EUR while some 

only several thousand (see section above on data provided by Competent Authorities)  

Almost all Member States report on the number of illegal shipments occurring. The latest 

implementation report of the WSR76 states that there were 2 800 illegal shipments of waste reported in 

2013-2015, with approximately 600 000 checks performed during the same period. However, in many 

cases the financial penalties imposed are low in comparison with the values of financial guarantees.77  

The disproportionality of the financial guarantee system was also highlighted by stakeholders, both 

public and private, during the initial targeted interviews. They pointed out that the amount of financial 

guarantee currently required is disproportional, and that, in practice, financial guarantees are only 

required in less than 0.1% of occurring shipments.  

One alternative system suggested was to replace the financial guarantee by a small fee paid per 

shipment and calculated based on its volume and whether the waste is hazardous, non-hazardous 

and/or recyclable, with the resulting fund being available for any casualties and events where it is 

needed to cover costs. Such a system would result in lower costs for actors involved in shipments, while 

the finances would be available to cover costs in those cases where it is needed (e.g. in case of 

shipments that cannot be completed as intended, or in case of an illegal shipments that is stopped). 

73 See Table 31 under Specific objective 2a, where operators spend 24h addressing a paper-based notification and 
16h addressing an electronic notification. 
74 See Table 31 under Specific objective 2a 
75 The conclusions have been made based on the findings regarding costs and savings in relation to the establishment 
of the EU-wide EDI system 
76 COM (2018) 762 final https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0762&from=EN  
77 As per data provided directly by Competent Authorities 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Administrative burden for public authorities would also be reduced as complex calculations and 

managing financial guarantees would no longer be required from them.  

Using the example of Belgium, which in the period of 2013-2015 reported 644 cases of illegal 

shipment78, the total value of the financial guarantee is almost EUR 52 mil. The value of the financial 

guarantee could cover all of these reported cases, even if each shipment incurred costs / damages of 

more than EUR 800 000. In 2017 the average fine issued in Belgium amounted to EUR 38 00079. If each 

shipment were accompanied with a financial guarantee of EUR 40 000, an amount a little higher than 

the average fine issued, this would save approx. EUR 35 million. Presuming that in 2017 410 shipments80 

took place, if each shipment were accompanied with a financial guarantee of EUR 40 000, the total 

value of the financial guarantee for Belgium would be EUR 16.5 million instead of EUR 52 million. This 

method could be replicated for all Member States.  

Another option could be to stipulate within the Waste Shipment Regulation that Member States have 

the option to replace the individual guarantee system and replace this with a system of Member States’ 

national funds. It has been reported by one of the stakeholders consulted that a single shipment (which 

consists of 30%-50% of metal) has a value between EUR 300 and EUR 600 per tonne and for such a 

shipment a financial guarantee between a high 6-figure and a low 7-figure is required to be paid. These 

national funds would be contributed to by those shipping ‘notified’ waste. A fee proportional to the 

value and/or volume of the shipment would have to be paid. Using further the example of this 

(partially) metal shipment, fee, even if it was made double the maximum value of the shipment per 

tonne it, would not exceed EUR 24 00081. If it is presumed that currently the high 6-figure/low 7-figure 

financial guarantee amounts to EUR 1 000 000, this would mean that a financial guarantee appropriate 

to the value of the shipment would be lower by EUR 976 000. This would amount to financial guarantee 

being 98 times lower requested to be paid for this shipment. If it is presumed that the same logic would 

apply to the financial guarantees of all shipments, then the value of national funds would be 90% 

lower and/or would require holding 90% less than they currently hold, as reported by Member 

States.  

During the open public consultation some (3) stakeholders mentioned that revision of the financial 

guarantee system would significantly reduce administrative burden and allow for smaller companies to 

insure their waste. 

During the workshop, stakeholders also raised some concerns regarding the different options for 

revision of the financial guarantee system. With regards to the insurance company-based system, a 

hazardous waste treatment association, was not in favour of such an insurance-based system, as they 

felt it could be taken advantage of by (illegal) waste traffickers (as the potential negative 

consequences of their illegal shipments would be covered by the system at no cost to them). Instead 

they suggested a yearly rolling-out system, however without providing further details on what this 

system should entail. The insurance-based system was also not favoured by another Member State‘s 

representative. One Member State also raised some concerns/reservations regarding the replacement of 

the current system of financial guarantees as Competent Authorities are currently the beneficiaries of 

78 COM (2018) 762 final https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52018DC0762&from=EN  
79 Annex IX Additional questionnaire for reports by Member States pursuant to Article 51(2), reporting for Belgium in 
2017 
80 Based on internal modelling data 
81 Presumed that a shipment is of 20 tonnes.  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

the guarantees and they had doubts about being able to access the funds if alternatives were used. 

However, most stakeholders (19 stakeholders, 43%), participating in the workshop believed that an EU-

wide fund should be created for financial guarantees. For the EU-wide fund the same method could be 

used as presented above for a small fee per shipment and/or of the national fund. However, instead of 

Member States maintaining the sums deposited into the financial guarantee, these would be paid into 

an EU-wide fund. 

Pre-consented facilities 

If it is presumed that pre-consented facilities have their consent awarded for three years (meaning that 

they would receive waste during 3 years with a single notification rather than during one year), then 

the values presented above on how much time is required annually to handle an electronic notification 

dossier could be used to make an estimate on the time required (and costs) per notification dossier in 

relation to the pre-consented facilities.  

As discussed above (see section on EDI), in 2018 Competent Authorities spent 3 500 000 million hours on 

addressing electronic notifications and 5 370 000 hours addressing paper-based notifications. If the 

facilities were introduced with a prior consent of three years, the time spent by Competent Authorities 

would amount to 1 167 000 hours per year for electronic notifications and 1 790 000 hours per year for 

paper-based notifications. Based on these values, the cost-saving resulting from pre-consented facilities 

with a three-year consent can also be calculated. If it is presumed that Competent Authority employees 

are paid EUR 20/h, then the costs saved as a result of the introduction of the pre-consented facilities 

can amount to annually saving of EUR 47 million for the electronic notifications and EUR 72 million 

for the paper-based notifications for Competent Authorities.  

The same method can be deployed when calculating the resources saved for business operators. As 

outlined above (see section on EDI), in 2018 operators 7 810 000 hours addressing paper-based 

notifications spent, while those addressing electronic notifications spent 5 200 000 hours. With pre-

consented facilities, these values would amount to 2 603 000 hours per year and 1 733 000 hours per 

year, respectively. If it is presumed that employees of business operators, too, are paid EUR 20/h, then 

the costs saved as a result of the introduction of pre-consented facilities with consent for three years 

can amount to annually saving EUR 104 million for paper-based notifications and EUR 69 million for 

electronic notifications for business operators.  

However, it has been observed by some stakeholders82 that the core of the issue regarding pre-

consented facilities is not the lack of procedure allowing for it (Art. 14). They concluded that the 

possibility for pre-consented facilities under Art. 14 WSR remains underused and stated that increasing 

its use, based on harmonised rules and procedures, could be a valuable step towards eliminating 

unnecessary barriers to the circular economy in Europe. To highlight the issue, the same stakeholders 

performed a test-run of shipping to pre-consented facilities. They concluded that effective pre-

consented facilities are closely connected to EDI and financial guarantees and also depend on transit 

approval, which would save work and money for all parties involved. However, at the same time to 

receive the status of a pre-consented facility is administratively burdensome83 and there are 

administrative fees associated with it. These can vary greatly; in Brandenburg, DE administrative fees 

82 International Green Deal (2019) 
83 http://info.gistrid.din.developpement-durable.gouv.fr/en/asking-for-a-pre-consent-a49.html  

112 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

for notification amount to EUR 1 250 while in UK they can reach £ 24 000.84 85 Therefore, an important 

issue to consider in relation to pre-consented facilities is that introduction of more facilities might not 

directly reduce the costs, it is crucial that the facilities are recognised for the benefits they can bring 

about are put to efficient use.  

  Specific objective 1c - harmonisation of interpretation, application and enforcement across 

Member States 

A study from IMPEL,86 highlighted variations between MSs in the classification/definition of waste as a 

significant implementation challenge to those implementing EU environmental legislation. A total of 63 

IMPEL members from 28 different member countries provided a response to a questionnaire for this 

study. Most saw issues between classifications of waste and non-waste (78%), and a smaller yet 

substantial group struggled between hazardous and non-hazardous classification (58%). These issues can 

lead to negative administrative and economic impacts for waste practitioners. IMPEL noted that 

guidance documents are positive measures to combat this (such as the UK government and IMPEL’s 

separate guidance documents). It is assumed therefore that guidance or mutual recognition would have 

a positive economic effect for waste shipment practitioners.  

During the Evaluation of the WSR report87, business operators indicated that though it is difficult to 

quantify number of delays per annum or waiting times of delays, on average costs could be seen as €150 

000 per delay related to misinterpretations between Member States that lead to lengthy waiting times. 

This can be viewed as a significant economic impact for business operators.  

Two stakeholders from this study’s workshop (a company/business organisation and an environmental 

NGO) noted that EU-level harmonisation (EU-level standards) is preferable, as such legislation on 

mutual recognition was perceived to create unfair competition or lead to possible instances where 

lesser environmental standards were accepted (due to either a dispatch and/or destination front-runner 

country in regard to standards, having to accept lower standards from other Member States). A waste 

recycling association outlined that mutual recognition was a key tool in improving the functioning of the 

internal market for raw materials, in the absence of EU-wide EoW criteria. They noted that this would 

facilitate cross-border secondary material shipments in Europe, as well as harmonising waste/non-

waste statuses in the EU. This could be therefore seen as a positive economic impact for the recycling 

industry. This view was supported by another industry organisation. Neither view provided quantitative 

data on the economic impacts.  

On the issues of defining contamination thresholds either via guidance documents or legally binding 

instruments, there was a wide mix of opinions from the consulted stakeholders. Overall, from the 

workshop (see Figure 47) the majority of stakeholders favoured the use of legally binding instruments 

(such as delegated acts by the Commission) (31 stakeholders, 69%). 

84 https://www.sbb-mbh.de/aufgaben-der-sbb/grenzueberschreitende-abfallverbringung/gebuehren-einer-
notifizierung.html  
85 International Green Deal (2019) 
86 IMPEL (2017)  
87 Trinomics (2018) https://op.europa.eu/en/publication-detail/-/publication/926420bc-8284-11e9-9f05-
01aa75ed71a1/language-en/format-PDF  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 47 workshop poll on “What is the best method for setting common thresholds for contaminated/mixed 
waste at an EU?” (n=45) 

Issues for this measure included difficulties in determining contamination limit values, which were 

noted as being hard to define. The main reason why stakeholders supported guidance was to aid with 

the enforcement and interpretation of the enforcement of contamination limit values. However, some 

saw legally binding instruments as a better option, as they provide further certainty and assurance for 

competent authorities and some business operators. However, stakeholders and literature do not 

provide data to quantify the economic impacts of these measures. It is assumed negative economic 

impacts would be seen in the short- and mid-term for the European Commission through creating 

guidance documents and/or creating delegated acts on contamination threshold/value decisions. 

However, in the mid- long-term for competent authorities and business operators it is assumed the 

measure would increase efficiency and lower administrative and operational costs. The end of waste 

criteria debate has been ongoing for a number of years in the waste sector, and it can be argued that 

the waste shipment regulations are not the best place to address it, as the response needs to be 

material / waste stream specific and the detailed analysis and guidance required is to detailed for the 

WSR. 

  Specific objective 1d – Better adapt to technical progress and stimulation of innovation  

The use of delegated acts aims to increase the efficiency of the WSR and reduce administrative burden 

on competent authorities by providing delegations to the Commission. The use of delegated acts allows 

for greater speed to implement decisions and can more swiftly implement harmonised procedures 

across the EU. However, according to some stakeholders delegated acts risk less scrutinous review of 

the legislation and potentially less systematic assessment of the impacts to all stakeholder groups 

compared to the ordinary legislative procedure. Delegated Acts for waste classification, notification 

procedures and related annexes are likely to impact the trade, economic operators and competent 

authorities; consequently, these stakeholders should be included in the decision-making process when 

implementing Delegated Acts.  

Most stakeholders favoured delegated acts addressing adaptation to new digital 

opportunities. The recently adopted regulation on Electronic Freight Transport 

Information (eFTI)42 uses a mixture of delegated and implementing acts. The eFTI uses delegated 

acts to provide rules for certification of eFTI platforms and service providers, these are used by 

economic operators to share information with competent authorities.  

114 

13%; 618%; 869%; 31051015202530353) Other (please specify)2) Guidance documents1) Legally binding instruments (delegated acts by the Commission 
 
 
  
  
Exploration of potential policy responses to review the Waste Shipment Regulation 

Secondly, the development of an online portal as a repository of innovative practices and technical 

progress in the implementation of the WSR has the potential to reduce efforts for notification 

procedure and decrease work for competent authorities.  

A similar collaborative platform Joinup43 was created by the Commission for sharing practices and IT 

solutions for public administrations. The tool has helped provide affordable solutions to public 

administrations across the EU and the focus on actual solutions instead of spending resources on 

building individual platforms for specific projects. In the context of the WSR, such a tool could help 

competent authorities to identify and evaluate solutions using the experience of other authorities much 

quicker than through their own investigations. Furthermore, if an increasing number of Member States 

adopt the same good practice then there will be an increased efficiency through harmonisation.  

The location of the online tool will allocate the cost to a responsible party. For instance, if the tool was 

to be located on CIRCABC44 then the costs will be borne entirely on the Commission. A recent contract 

tendered by the Commission for the European Maritime Safety Agency show costs for 

the acquisition and maintenance of an online platform to be €200,00045.  

Stakeholders identified that IMPEL is already sharing information on best practices. If the proposed tool 

is to build on the experience and work done by IMPEL then the costs will be different.  

The sub measures are not thought to cause significant impacts to employment, governance and crime or 

directly impact the environment.  

  Specific objective 2a – stop or restrict export of waste outside of the EU 

The restriction or prohibition of export of waste outside of the EU carries with it both positive and 

negative economic consequences. The economic impacts of the different sub-measures are presented 

below but effectively sit within the following types of costs and benefits: 

Economic Costs 

Economic benefits 

The economic value of the materials retained within 

the EU (taken from reported values in Comext). 

Administrative costs – primarily addressing the 

additional costs applied as stricter controls are applied 

to shipments of waste to third countries. In particular 

the cost of application of prior informed consent to 

shipments is an important cost to be considered. 

Waste management costs – primarily comprising 

additional sorting costs and treatment costs as 

increased levels of EU waste is retained within the EU 

requiring additional capacity for their management in 

comparison to present day.  

Waste material costs – a number of predominantly 

industry stakeholders have warned of the potential for 

Larger volumes of waste recycled in the EU should also 

those measures that retain wastes within the EU that 

result in larger supply of recyclates by the EU recycling 

would normally have been exported to third countries 

industry, so supporting their activities – as well as 

to cause crashes in the value of those wate materials 

lower prices for such recyclates on the market for 

as a result of under capacity in the EU market to 

secondary materials, which should increase the EU 

manage and recover value from those wastes. The 

recycling industry competitiveness (i.e. the gap 

same group of stakeholders reflected on the possibility 

between virgin materials and secondary raw materials 

115 

  
  
  
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Economic Costs 

Economic benefits 

of this having the knock-on effect of wastes then being 

would be reduced). The question will be if there is 

diverted to options that are further down the waste 

sufficient demand for these recyclates; this cannot be 

hierarchy including incineration and landfill. However, 

addressed directly by the WSR, but other policy 

this position was contested by others, including some 

measures and initiatives to encourage the uptake of 

Member States and environmental NGOs. 

recycled materials in new products should help in that 

direction (for ex. recycled plastics in PET bottles, 

maybe for other packaging when the Packaging 

directive gets revised, and for new cars when the ELV 

Directive is revised – beyond legislation, there is also 

the Circular Plastic Alliance initiative to boost the 

market for recycled products) 

Assessing the third of the three economic costs listed in EUR terms is not possible given the large 

number of variables that exist in relation to the types of materials concerned, their volumes and their 

current destinations. However, an examination of the intra-EU movements vs extra-EU movements gives 

an indication of those wastes that are likely to be most prone to capacity problems within the EU in the 

future. This comparison is shown in Figure 48, that indicates that ferrous metals, paper and cardboard 

and textiles represent those waste types for which the potential for capacity and, therefore, price are 

likely to be most problematic. 

Figure 48 Figure comparison of intra- and extra-EU shipments of waste in 2019 

For the purpose of this report, employment is considered under social impacts later in this report. 

As a reminder, the costs of applying PIC the following costs have been applied: 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 32 Assessment of PIC costs based on the standard cost model for the purpose of Objective 2a 

Type of obligation 

Description of 

requested action(s) 

Target group 

Tariff € 

Time 

Price per 

per hour 

(hour) 

action 

Application of individual 

Paper based 

Member State 

authorisation1 

assessment of PIC 

competent authorities 

Application of individual 

Electronic 

Member State 

authorisation1 

assessment of PIC 

competent authorities 

20 

20 

16.5 

330 

10.8 

216 

Application of individual 

authorisation2 

Application of individual 

authorisation2 

Paper based 

completion of PIC 

Operators 

20 

24 

480 

documentation 

Electronic 

completion of PIC 

Operators 

20 

16 

320 

documentation 

1 Taken from Objective 1B above 
2 Taken from the study supporting the Evaluation of the Waste Shipment Regulation, Trinomics 2019 

The standard cost model applies a further multiplier based on the number of expected actions. In the 

case of measures under 2a, the number of actions varies by the total quantities of waste shipped and is, 

therefore, not a fixed number. For the purpose of calculating the cost of PIC for shipments of waste, 

the costs associated with both paper and electronic based actions have been calculated. Furthermore, 

a calculation of the impacts of varying waste shipment volumes per shipment from the 20 tonnes per 

shipment identified by IEEP and referenced in objective 1a to 100 tonnes has been included to take into 

account the possibility of individual shipment sizes to increase in future, as well as to take into account 

the nature of shipments of some wastes that are more likely to take place in larger volumes per 

shipment such as ferrous metal and non-ferrous metal wastes. 

Concerning the costs of waste management, the full costs applicable to typical waste management are 

not considered appropriate for determining costs of treatment in relation to the possible changes in 

waste flows resulting from the measures considered under specific objective 2a. This is because it is 

expected that collection costs are irrelevant as collection is already required under the BAU approach – 

in order for wastes to be shipped they must already have been collected so no additional collection 

costs are foreseen under any of the measures. Furthermore, separation activities are also likely to have 

been undertaken to a certain extent. In the interests of accounting for the most likely costs the full 

costs of separation are included in the relevant calculations in this study. However, this is likely to 

result in an overestimate of the costs of treatment in comparison to the BAU approach under the 

present waste shipping rules applicable. The costs of treatment of the wastes concerned have been 

included in full as a result of the additional waste treatment capacity likely to be required within the 

EU as wastes that are presently shipped are retained within the EU for treatment. 

As a reminder, the waste management costs that have been used for the purpose of calculating costs 

for the measures foreseen under this specific objective are shown in Table 33 below. 

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Table 33 Treatment costs applied in this study for determining costs related to the retention of wastes within 
the EU under specific objective 2a 

Waste type 

Plastic 

Textiles 

Non-ferrous metals 

Ferrous metals 

Other 

Treatment cost per tonne 

121.91 

6503 

1181.54 

138.634 

135 

Sources of values 

1JRC, 2018, Sorting of co-mingled light packaging waste to maximise recycling yields for high quality 

output 

2The COWI, Eunomia 2019 - Study on investment needs in the waste sector and on the financing of 

municipal waste management in Member States gives a figure of €175 tonne for use in its modelling 

whereas the European reference model on MSW management offers values for €100-105 tonne. A mid-

point value of €140 tonne has been applied for the purpose of this study. 

3COWI, Eunomia 2019 - Study on investment needs in the waste sector and on the financing of municipal 

waste management in Member States 

4The European reference model on MSW provides treatment costs for non-ferrous metals (-€379/tonne) 

and ferrous metals (-€96 to –€177 tonne) – negative values indicating income from treatment. In order 

to determine the true treatment costs for this project the values indicated in the European reference 

model on MSW have been subtracted from the average ferrous metal (€275.13 tonne) and non-ferrous 

metal values (€1181.5 tonne) reported using Comext data and as predicted for the period 2020-2030. 

5 The European reference model on MSW 

The economic and tonnage values of the wastes retained within the EU under the various measures 

have been taken from the baseline presented in Section 4 of this report, with the values shown the 

tables below.  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 34 Forecast of tonnes of waste to be exported from the EU to third countries under the baseline scenario 

Table 35 Forecast of EUR value of waste to be exported from the EU to third countries under the baseline scenario 

Table 36 EUR / tonne value resulting from the two tables above 

119 

Waste type201920202021202220232024202520262027202820292030Ferrous metal15,322,56515,821,74016,320,89016,820,04017,319,19017,818,34018,317,49018,816,64019,315,78919,814,93920,314,08920,813,239Glass353,029336,523348,810361,097373,384385,671397,958410,245422,532434,819447,106459,393Non-ferrous metals1,864,7901,899,5511,934,3121,969,0732,003,8342,038,5952,073,3562,108,1172,142,8792,177,6402,212,4012,247,162Paper and cardboard5,830,9066,195,0506,255,4666,315,8826,376,2986,436,7146,497,1306,557,5466,617,9616,678,3776,738,7936,799,209Plastic1,521,9711,556,7631,591,5551,626,3471,661,1391,695,9321,730,7241,765,5161,800,3081,835,1001,869,8921,904,685Textiles1,476,0751,532,0741,588,1601,644,2451,700,3311,756,4171,812,5031,868,5891,924,6751,980,7612,036,8472,092,933Total26,369,33527,341,70128,039,19328,736,68529,434,17730,131,66930,829,16131,526,65232,224,14432,921,63633,619,12834,316,620YearWaste type201920202021202220232024202520262027202820292030Ferrous metal3,965,499,1854,086,682,6564,207,866,1284,329,049,5994,450,233,0714,571,416,5424,692,600,0144,813,783,4854,934,966,9575,056,150,4285,177,333,9005,298,517,371Glass43,590,56538,403,50639,415,29540,427,08441,438,87442,450,66343,462,45244,474,24145,486,03046,497,81947,509,60948,521,398Non-ferrous metals6,230,466,5376,449,147,0926,667,827,6476,886,508,2027,105,188,7577,323,869,3137,542,549,8687,761,230,4237,979,910,9788,198,591,5338,417,272,0888,635,952,643Paper and cardboard599,621,255667,374,085694,700,224722,026,362749,352,501776,678,640804,004,778831,330,917858,657,055885,983,194913,309,333940,635,471Plastic375,500,180384,726,420393,952,660403,178,900412,405,140421,631,379430,857,619440,083,859449,310,099458,536,339467,762,579476,988,819Textiles1,087,757,6961,235,196,7201,283,509,0951,331,821,4691,380,133,8441,428,446,2191,476,758,5931,525,070,9681,573,383,3421,621,695,7171,670,008,0921,718,320,466Total12,302,435,41812,861,530,48013,287,271,04813,713,011,61714,138,752,18614,564,492,75514,990,233,32415,415,973,89315,841,714,46216,267,455,03116,693,195,60017,118,936,168YearWaste type201920202021202220232024202520262027202820292030Ferrous metal259258258257257257256256255255255255Glass123114113112111110109108108107106106Non-ferrous metals3,3413,3953,4473,4973,5463,5933,6383,6823,7243,7653,8053,843Paper and cardboard103108111114118121124127130133136138Plastic247247248248248249249249250250250250Textiles737806808810812813815816817819820821Year 
 
  
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Sub-Measure 2a1: Maintain the current legal regime and facilitate its implementation is unlikely to 

carry significant economic costs in comparison to the present regime that already relies on a somewhat 

heavy burden of questionnaires sent to third countries for completion and subsequent assessment and 

follow-up communication by the European Commission, the latest results of which can be found on the 

website http://wastetradesurvey.eu/. Furthermore, the updating of the Regulation resulting from this 

procedure also requires effort with regard to the legislative procedure to be applied in its update as 

well as the economic costs of delays in the information collected being made officially available in the 

Regulation, a subject of criticism by a majority of stakeholders that commented on this measure. It is 

expected that the economic benefit to Member States and operators of having access to more timely 

information would be positive, although a calculation of the true value is not possible based on the 

evidence gathered during this assessment. It is considered that this measure is unlikely to have a 

significant impact on the actual flow of wastes as it is generally a Regulation that simply captures 

decisions taken by third parties and not the EU. Consequently, waste flows are likely to remain in 

keeping with the baseline predictions provided in Section 4 of this report. 

Sub-measure 2a2: Ban export of all waste outside the OECD, except for third countries which notify 

the EU of their willingness and readiness to import such waste would carry economic costs and 

benefits that vary somewhat dependent upon the response of non-OECD third countries. In this respect 

three main scenarios have been costed (these values have been used as examples only to show the 

potential different scale of impacts) reflecting a change in flows of 75%, 50% and 20% of wastes 

formerly exported to non-OECD third countries being retained within the EU. The results of the 

calculations of the economic costs in respect to waste management and benefits in respect to the EUR 

value of materials retained resulting from these scenarios are presented in Error! Reference source 

not found.9 and Error! Reference source not found.0 below. It is expected that the waste 

management costs would generally fall on those involved in the production of the wastes concerned i.e. 

those producing the wastes would be required to pay a higher price for the management of their wastes 

within the EU in comparison to the likely lower prices charged by non-OECD third countries. The costs 

of such management would also likely be shared with Member States that would need to invest in their 

own waste management facilities to manage these wastes. 

Additionally, it is expected that changes in the waste flows would carry economic impacts for those 

involved in the shipping process to non-OECD third countries, whereby the quantities shipped would be 

reduced and the income for operators involved in such shipments would fall. However, as the amount of 

waste generated would remain the same the shipping would likely shift to either other non-OECD third 

countries or would remain within the EU. Consequently, there is likely to be a shift in the flows of 

materials that will be met with a shift in the efforts involved in such shipments whereby the total 

economic effort involved in such shipments will likely reduce in total as a result in the reduction of the 

total distance that waste is shipped. It has not been possible to calculate the total change in value as a 

result of these changes. 

120 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 37 Results of the economic cost calculations for sub-measure 2a2 comprising waste management costs resulting from extra EU waste management capacity needs 

121 

EUR value costs for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal406,293,193318,206,463358,218,183298,566,945309,858,087351,511,242284,465,456294,858,191338,152,782263,712,447273,206,776318,142,801Glass647,326562,723527,333488,002444,731397,519346,366291,273232,238169,263102,34831,491Non-ferrous metals1,049,476,6501,025,795,592975,166,625922,043,291866,425,591808,313,524747,707,090684,606,290619,011,124550,921,591480,337,691407,259,425Paper and cardboard44,781,61147,277,90447,435,69247,587,62247,733,69447,873,90748,008,26348,136,76048,259,39948,376,18048,487,10348,592,167Plastic91,932,68392,473,13892,943,81393,344,71093,675,82793,937,16594,128,72394,250,50394,302,50394,284,72494,197,16594,039,828Textiles645,622,234672,820,649700,255,490727,888,401755,719,383783,748,434811,975,556840,400,748869,024,010897,845,342926,864,745956,082,218Total2,238,753,6962,157,136,4692,174,547,1362,089,918,9712,073,857,3122,085,781,7911,986,631,4541,962,543,7641,968,982,0551,855,309,5471,823,195,8271,824,147,929EUR value costs for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal270,862,128212,137,642238,812,122199,044,630206,572,058234,340,828189,643,637196,572,127225,435,188175,808,298182,137,851212,095,201Glass431,551375,149351,555325,335296,487265,013230,911194,182154,826112,84268,23220,994Non-ferrous metals699,651,100683,863,728650,111,083614,695,527577,617,061538,875,683498,471,394456,404,193412,674,082367,281,060320,225,127271,506,283Paper and cardboard29,854,40731,518,60231,623,79531,725,08131,822,46231,915,93832,005,50932,091,17332,172,93332,250,78732,324,73532,394,778Plastic61,288,45561,648,75961,962,54262,229,80762,450,55162,624,77662,752,48262,833,66862,868,33562,856,48262,798,11062,693,218Textiles430,414,823448,547,100466,836,993485,258,934503,812,922522,498,956541,317,037560,267,165579,349,340598,563,561617,909,830637,388,145Total1,492,502,4641,438,090,9791,449,698,0911,393,279,3141,382,571,5411,390,521,1941,324,420,9701,308,362,5101,312,654,7031,236,873,0311,215,463,8851,216,098,620EUR value costs for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal108,344,85184,855,05795,524,84979,617,85282,628,82393,736,33175,857,45578,628,85190,174,07570,323,31972,855,14084,838,080Glass172,620150,059140,622130,134118,595106,00592,36477,67361,93045,13727,2938,398Non-ferrous metals279,860,440273,545,491260,044,433245,878,211231,046,824215,550,273199,388,557182,561,677165,069,633146,912,424128,090,051108,602,513Paper and cardboard11,941,76312,607,44112,649,51812,690,03212,728,98512,766,37512,802,20312,836,46912,869,17312,900,31512,929,89412,957,911Plastic24,515,38224,659,50324,785,01724,891,92324,980,22025,049,91125,100,99325,133,46725,147,33425,142,59325,119,24425,077,287Textiles172,165,929179,418,840186,734,797194,103,574201,525,169208,999,582216,526,815224,106,866231,739,736239,425,425247,163,932254,955,258Total597,000,986575,236,392579,879,236557,311,726553,028,616556,208,478529,768,388523,345,004525,061,881494,749,213486,185,554486,439,448YearYearYear 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 38 EUR retained value of materials retained within the EU for sub-measure 2a2 

122 

EUR value of materials retained within the EU forecast for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal851,100,696581,491,140696,763,163816,044,971564,342,723686,208,633811,946,891535,940,724664,400,520796,595,230496,285,143631,338,825Glass5,412,9154,601,8814,509,1634,405,4604,290,7724,165,0994,028,4423,880,8003,722,1733,552,5623,371,9653,180,384Non-ferrous metals1,919,897,0992,029,182,3872,066,962,6462,102,707,8132,136,417,8892,168,092,8742,197,732,7682,225,337,5712,250,907,2832,274,441,9032,295,941,4332,315,405,871Paper and cardboard353,522,424384,654,736391,156,946396,931,631401,978,791406,298,426409,890,537412,755,122414,892,183416,301,718416,983,729416,938,215Plastic173,537,176174,505,281175,315,312175,967,268176,461,149176,796,955176,974,686176,994,342176,855,923176,559,430176,104,861175,492,218Textiles729,481,187831,923,587868,167,766904,690,868941,492,894978,573,8441,015,933,7181,053,572,5161,091,490,2371,129,686,8821,168,162,4501,206,916,943Total4,032,951,4974,006,359,0124,202,874,9954,400,748,0104,224,984,2194,420,135,8324,616,507,0424,408,481,0754,602,268,3194,797,137,7244,556,849,5824,749,272,456EUR value of materials retained within the EU forecast for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal567,400,464387,660,760464,508,775544,029,980376,228,482457,472,422541,297,928357,293,816442,933,680531,063,486330,856,762420,892,550Glass3,608,6103,067,9213,006,1092,936,9732,860,5152,776,7332,685,6282,587,2002,481,4492,368,3742,247,9772,120,256Non-ferrous metals1,279,931,4001,352,788,2581,377,975,0971,401,805,2091,424,278,5931,445,395,2501,465,155,1791,483,558,3811,500,604,8551,516,294,6021,530,627,6221,543,603,914Paper and cardboard235,681,616256,436,491260,771,297264,621,087267,985,861270,865,617273,260,358275,170,081276,594,788277,534,479277,989,153277,958,810Plastic115,691,451116,336,854116,876,875117,311,512117,640,766117,864,637117,983,124117,996,228117,903,949117,706,287117,403,241116,994,812Textiles486,320,792554,615,725578,778,510603,127,245627,661,930652,382,563677,289,145702,381,677727,660,158753,124,588778,774,967804,611,295Total2,688,634,3322,670,906,0082,801,916,6632,933,832,0072,816,656,1462,946,757,2213,077,671,3612,938,987,3833,068,178,8793,198,091,8163,037,899,7213,166,181,637EUR value of materials retained within the EU forecast for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal226,960,186155,064,304185,803,510217,611,992150,491,393182,988,969216,519,171142,917,527177,173,472212,425,395132,342,705168,357,020Glass1,443,4441,227,1681,202,4431,174,7891,144,2061,110,6931,074,2511,034,880992,579947,350899,191848,103Non-ferrous metals511,972,560541,115,303551,190,039560,722,083569,711,437578,158,100586,062,072593,423,352600,241,942606,517,841612,251,049617,441,566Paper and cardboard94,272,646102,574,596104,308,519105,848,435107,194,344108,346,247109,304,143110,068,033110,637,915111,013,792111,195,661111,183,524Plastic46,276,58046,534,74246,750,75046,924,60547,056,30647,145,85547,193,25047,198,49147,161,58047,082,51546,961,29646,797,925Textiles194,528,317221,846,290231,511,404241,250,898251,064,772260,953,025270,915,658280,952,671291,064,063301,249,835311,509,987321,844,518Total1,075,453,7331,068,362,4031,120,766,6651,173,532,8031,126,662,4581,178,702,8891,231,068,5451,175,594,9531,227,271,5521,279,236,7271,215,159,8881,266,472,655YearYearYearBenefitsExploration of potential policy responses to review the Waste Shipment Regulation 

Additionally, savings in terms of the costs of shipping are expected as shown in Table 38 below. 

Table 39 Transport cost savings in EUR under measure 2a2 

A comparison of the economic costs and benefits using the data from these tables indicates that for a 

majority of the waste streams, increased retention of EU wastes within the EU as a result of this 

measure results in economic benefits outweighing the costs. The overall economic benefits or costs for 

all wastes are shown in Error! Reference source not found.11 below. Negative values in the table 

indicate the additional economic costs incurred as a result of the measure. Positive values indicate the 

additional net economic benefits incurred in EU. As can be seen in the table, for all of the wastes 

considered except glass and paper and cardboard the economic value of materials retained and the 

transport costs saved mean that the benefits outweigh the costs of their management within the EU. 

123 

EUR value of materials retained within the EU forecast for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal70,338,57555,088,76262,015,69951,688,71653,643,46960,854,57649,247,42851,046,64658,541,92345,654,61147,298,29555,077,741Glass1,195,0631,038,873973,538900,927821,042733,881639,445537,734428,748312,486188,94958,137Non-ferrous metals21,318,18820,837,15119,808,71718,729,61417,599,84316,419,40315,188,29513,906,51812,574,07311,190,9599,757,1778,272,726Paper and cardboard82,673,74387,282,28387,573,58587,854,07188,123,74288,382,59888,630,63988,867,86589,094,27589,309,87189,514,65189,708,616Plastic18,099,95418,206,36018,299,02818,377,95818,443,14918,494,60218,532,31618,556,29318,566,53018,563,03018,545,79118,514,814Textiles23,838,35924,842,60925,855,58726,875,87927,903,48528,938,40429,980,63631,030,18132,087,04033,151,21334,222,69835,301,497Total217,463,882207,296,039214,526,154204,427,166206,534,729213,823,463202,218,759203,945,237211,292,589198,182,170199,527,562206,933,533EUR value of materials retained within the EU forecast for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal46,892,38336,725,84141,343,80034,459,14435,762,31340,569,71732,831,61934,031,09839,027,94930,436,40731,532,19736,718,494Glass796,709692,582649,025600,618547,361489,254426,297358,489285,832208,324125,96638,758Non-ferrous metals14,212,12613,891,43413,205,81112,486,40911,733,22810,946,26910,125,5309,271,0128,382,7157,460,6396,504,7855,515,151Paper and cardboard55,115,82858,188,18958,382,39058,569,38158,749,16158,921,73259,087,09359,245,24359,396,18459,539,91459,676,43459,805,744Plastic12,066,63612,137,57312,199,35212,251,97212,295,43312,329,73412,354,87812,370,86212,377,68712,375,35312,363,86112,343,210Textiles15,892,24016,561,73917,237,05817,917,25318,602,32319,292,26919,987,09120,686,78821,391,36022,100,80822,815,13223,534,332Total144,975,922138,197,359143,017,436136,284,777137,689,820142,548,975134,812,506135,963,491140,861,726132,121,446133,018,375137,955,688EUR value of materials retained within the EU forecast for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal18,756,95314,690,33716,537,52013,783,65814,304,92516,227,88713,132,64713,612,43915,611,17912,174,56312,612,87914,687,398Glass318,684277,033259,610240,247218,945195,702170,519143,396114,33383,33050,38615,503Non-ferrous metals5,684,8505,556,5745,282,3254,994,5644,693,2914,378,5074,050,2123,708,4053,353,0862,984,2562,601,9142,206,060Paper and cardboard22,046,33123,275,27623,352,95623,427,75223,499,66523,568,69323,634,83723,698,09723,758,47323,815,96623,870,57423,922,298Plastic4,826,6544,855,0294,879,7414,900,7894,918,1734,931,8944,941,9514,948,3454,951,0754,950,1414,945,5444,937,284Textiles6,356,8966,624,6966,894,8237,166,9017,440,9297,716,9087,994,8368,274,7158,556,5448,840,3239,126,0539,413,733Total57,990,36955,278,94457,206,97454,513,91155,075,92857,019,59053,925,00254,385,39756,344,69052,848,57953,207,35055,182,275Transport savingsYearYearYear 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 40 Balance of economic costs and benefits under measure 2a2 

124 

EUR value of materials retained within the EU forecast for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal515,146,078318,373,440400,560,679569,166,741308,128,105395,551,966576,728,863292,129,180384,789,661578,537,393270,376,662368,273,765Glass5,960,6525,078,0314,955,3684,818,3854,667,0834,501,4614,321,5214,127,2613,918,6823,695,7843,458,5673,207,031Non-ferrous metals891,738,6381,024,223,9461,111,604,7371,199,394,1361,287,592,1411,376,198,7531,465,213,9731,554,637,7991,644,470,2321,734,711,2721,825,360,9191,916,419,173Paper and cardboard391,414,556424,659,116431,294,839437,198,080442,368,839446,807,117450,512,913453,486,227455,727,059457,235,409458,011,277458,054,664Plastic99,704,447100,238,504100,670,527101,000,516101,228,471101,354,392101,378,279101,300,132101,119,951100,837,736100,453,48799,967,204Textiles107,697,313183,945,546193,767,863203,678,346213,676,997223,763,814233,938,798244,201,949254,553,267264,992,752275,520,404286,136,223Total2,011,661,6842,056,518,5832,242,854,0132,515,256,2042,357,661,6362,548,177,5042,832,094,3472,649,882,5482,844,578,8533,140,010,3472,933,181,3173,132,058,059EUR value of materials retained within the EU forecast for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal343,430,719212,248,960267,040,453379,444,494205,418,737263,701,311384,485,909194,752,786256,526,441385,691,596180,251,108245,515,843Glass3,973,7683,385,3543,303,5783,212,2573,111,3883,000,9742,881,0142,751,5082,612,4552,463,8562,305,7112,138,021Non-ferrous metals594,492,425682,815,964741,069,825799,596,091858,394,761917,465,836976,809,3151,036,425,1991,096,313,4881,156,474,1811,216,907,2791,277,612,782Paper and cardboard260,943,037283,106,077287,529,893291,465,387294,912,560297,871,411300,341,942302,324,151303,818,039304,823,606305,340,852305,369,776Plastic66,469,63166,825,66967,113,68567,333,67767,485,64767,569,59567,585,51967,533,42167,413,30167,225,15866,968,99266,644,803Textiles71,798,209122,630,364129,178,575135,785,564142,451,331149,175,876155,959,199162,801,300169,702,178176,661,835183,680,269190,757,482Total1,341,107,7891,371,012,3881,495,236,0091,676,837,4691,571,774,4241,698,785,0031,888,062,8981,766,588,3651,896,385,9022,093,340,2311,955,454,2112,088,038,706EUR value of materials retained within the EU forecast for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal137,372,28784,899,584106,816,181151,777,79882,167,495105,480,524153,794,36477,901,115102,610,576154,276,63872,100,44398,206,337Glass1,589,5071,354,1421,321,4311,284,9031,244,5551,200,3901,152,4061,100,6031,044,982985,543922,285855,208Non-ferrous metals237,796,970273,126,386296,427,930319,838,436343,357,904366,986,334390,723,726414,570,080438,525,395462,589,673486,762,912511,045,113Paper and cardboard104,377,215113,242,431115,011,957116,586,155117,965,024119,148,565120,136,777120,929,660121,527,216121,929,442122,136,341122,147,910Plastic26,587,85226,730,26826,845,47426,933,47126,994,25927,027,83827,034,20827,013,36926,965,32026,890,06326,787,59726,657,921Textiles28,719,28349,052,14651,671,43054,314,22656,980,53259,670,35062,383,68065,120,52067,880,87170,664,73473,472,10876,302,993Total536,443,116548,404,955598,094,403670,734,988628,709,770679,514,001755,225,159706,635,346758,554,361837,336,093782,181,684835,215,482Balance of costs and benefitsYearYearYearExploration of potential policy responses to review the Waste Shipment Regulation 

The above tables use the Comext values for the value of the wastes exported. If the market value of the materials is applied then the results change as indicated in 

the table below. In general, the results maintain their positive status, except for textiles where the values become negative. 

Table 41 balance of costs and benefits using market value of primary and secondary materials 

125 

75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal74,353,73558,233,41265,555,76254,639,28056,705,61764,328,35852,058,63553,960,55961,883,69148,260,72849,998,23958,221,762Glass3,137,0412,727,0422,555,5372,364,9352,155,2351,926,4381,678,5441,411,5521,125,463820,276495,992152,611Non-ferrous metals2,563,068,0262,505,233,3322,381,585,5242,251,845,8882,116,014,4241,974,091,1321,826,076,0131,671,969,0651,511,770,2901,345,479,6861,173,097,255994,622,996Paper and cardboard430,592,409454,595,226456,112,421457,573,287458,977,824460,326,032461,617,911462,853,462464,032,684465,155,577466,222,141467,232,376Plastic486,511,680489,371,790491,862,625493,984,186495,736,472497,119,483498,133,219498,777,681499,052,867498,958,779498,495,417497,662,779Textiles-65,555,488-68,317,174-71,102,865-73,908,668-76,734,583-79,580,610-82,446,749-85,332,999-88,239,361-91,165,835-94,112,420-97,079,117Total3,492,107,4033,441,843,6303,326,569,0053,186,498,9073,052,854,9882,918,210,8322,757,117,5732,603,639,3192,449,625,6332,267,509,2122,094,196,6241,920,813,40750% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal49,569,15738,822,27543,703,84136,426,18737,803,74542,885,57234,705,75735,973,70641,255,79432,173,81933,332,15938,814,508Glass2,091,3611,818,0281,703,6911,576,6231,436,8231,284,2921,119,029941,034750,308546,851330,661101,741Non-ferrous metals1,708,712,0171,670,155,5551,587,723,6831,501,230,5921,410,676,2831,316,060,7551,217,384,0081,114,646,0431,007,846,860896,986,458782,064,837663,081,997Paper and cardboard287,061,606303,063,484304,074,947305,048,858305,985,216306,884,021307,745,274308,568,975309,355,122310,103,718310,814,761311,488,251Plastic324,341,120326,247,860327,908,417329,322,791330,490,981331,412,989332,088,813332,518,454332,701,912332,639,186332,330,278331,775,186Textiles-43,703,659-45,544,782-47,401,910-49,272,446-51,156,389-53,053,740-54,964,499-56,888,666-58,826,241-60,777,223-62,741,613-64,719,412Total2,328,071,6022,294,562,4202,217,712,6702,124,332,6052,035,236,6591,945,473,8881,838,078,3821,735,759,5461,633,083,7551,511,672,8081,396,131,0821,280,542,27120% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal19,827,66315,528,91017,481,53714,570,47515,121,49817,154,22913,882,30314,389,48216,502,31812,869,52813,332,86415,525,803Glass836,544727,211681,477630,649574,729513,717447,612376,414300,123218,740132,26540,696Non-ferrous metals683,484,807668,062,222635,089,473600,492,237564,270,513526,424,302486,953,603445,858,417403,138,744358,794,583312,825,935265,232,799Paper and cardboard114,824,642121,225,394121,629,979122,019,543122,394,086122,753,609123,098,110123,427,590123,742,049124,041,487124,325,904124,595,300Plastic129,736,448130,499,144131,163,367131,729,116132,196,392132,565,195132,835,525133,007,381133,080,765133,055,674132,932,111132,710,074Textiles-17,481,464-18,217,913-18,960,764-19,708,978-20,462,556-21,221,496-21,985,800-22,755,466-23,530,496-24,310,889-25,096,645-25,887,765Total931,228,641917,824,968887,085,068849,733,042814,094,663778,189,555735,231,353694,303,819653,233,502604,669,123558,452,433512,216,908YearYearYearBalance of costs and benefits using market values 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Any diversion of EU wastes from non-OECD third countries is likely to have an economic impact on the 

non-OECD third countries themselves, primarily in relation to a reduction in feedstock to recycling 

activities. Given the EUR values of wastes that would be retained under the scenarios laid down it is 

apparent that the EUR economic impact to non-OECD third countries in total is likely to be similar to 

the value of wastes no longer exported. So, for example, a diversion of 20% of non-ferrous metal 

exports in 2030 would reduce the economic income to non-OECD third countries of between €607M and 

€1.35B per annum. China and India, as the two largest importers of non-ferrous metal waste at present, 

would be affected to the largest extent, but Pakistan, Hong Kong and Malaysia would also be affected. 

Finally, additional administrative costs would fall upon the Commission in respect to updating the list of 

country authorisations, in a similar manner to that addressed under 2a1. The cost of such 

administration is likely to be more burdensome than that provided for under the existing application of 

Regulation 1418/2007 given the additional requirements placed on non-OECD third countries and, 

therefore, the additional information that would be required to be gathered and synthesised by the 

Commission. It is estimated that one new additional FTE would be required to administer this 

procedure. 

Sub-measure 2a3: Require that the export of green-listed waste outside the OECD is subject to the 

“prior written notification and consent” (PIC) procedure where it is allowed has the potential to 

carry similar economic costs to sub-measure 2a2 with regard to the potential level of changes of flows 

of wastes formerly exported to non-OECD third countries retained within the EU. The majority of the 

costs under this measure are reflected under 2a2 above and are not duplicated in this section – the 

reader is encouraged to refer directly to the tables included in 2a2. 

An additional economic cost under 2a3 in comparison to 2a2 is the application of the PIC procedure. As 

PIC would apply to all such shipments economic costs of its application have been calculated on the 

basis of the totals of the wastes concerned exported to non-OECD countries over the period 2020-2030 

and using the 20 tonne and 100 tonne threshold per PIC shipment described earlier in this assessment. 

All non-OECD countries that currently apply PIC to the wastes addressed under this assessment have 

been removed from the cost of PIC calculations as this measure would have no impact on those 

countries. The information used to determine where PIC is currently applied has been taken from 

Regulation 1418/2007 and the latest study88 to update that Regulation with the assumption made that 

those countries will retain PIC over the time period used for this assessment. 

The results of the assessment of the total number of PICs that would be required per waste type are 

shown in the table below. 

88 http://wastetradesurvey.eu/  

126 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 42Assessment of the total number of shipments that would be required to be covered by prior informed 
consents that would be required by waste type for the period 2019-2030 for shipments to non-0ECD third 
countries based on 20t and 100t shipment size 

The costs of application of PIC vary by the nature of the PIC concerned, with electronic PIC less costly 

than paper-based PIC as a result of the time required for completion and transmission. However, a 

majority of PIC address multiple shipments (on average 56 shipments per notification). The costs 

resulting from applying PIC against the different wastes are shown in Error! Reference source not 

found. below. 

127 

Total number of shipments that would require to be covered by a PIC based on 20t shipmentsWaste type201920202021202220232024202520262027202820292030Ferrous metal195,385153,024172,266143,580149,010169,040136,798141,796162,616126,818131,384152,994Glass3,3202,8862,7042,5032,2812,0391,7761,4941,191868525161Non-ferrous metals59,21757,88155,02452,02748,88845,60942,19038,62934,92831,08627,10322,980Paper and cardboard229,649242,451243,260244,039244,788245,507246,196246,855247,484248,083248,652249,191Plastic50,27850,57350,83151,05051,23151,37451,47951,54551,57451,56451,51651,430Textiles66,21869,00771,82174,65577,51080,38483,28086,19589,13192,08795,06398,060Total604,066575,822595,906567,853573,708593,954561,719566,515586,924550,506554,243574,815Total number of shipments that would require to be covered by a PIC based on 100t shipmentsWaste type201920202021202220232024202520262027202820292030Ferrous metal39,07730,60534,45328,71629,80233,80827,36028,35932,52325,36426,27730,599Glass66457754150145640835529923817410532Non-ferrous metals11,84311,57611,00510,4059,7789,1228,4387,7266,9866,2175,4214,596Paper and cardboard45,93048,49048,65248,80848,95849,10149,23949,37149,49749,61749,73049,838Plastic10,05610,11510,16610,21010,24610,27510,29610,30910,31510,31310,30310,286Textiles13,24413,80114,36414,93115,50216,07716,65617,23917,82618,41719,01319,612Total120,813115,164119,181113,571114,742118,791112,344113,303117,385110,101110,849114,963YearYear 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 43 Total EUR cost for production of PIC documentation under measure 2a3 based on 20t and 100t shipping averages, paper and electronic based procedures. 

The split of costs in the tables below between Member State Competent Authorities and Operators is approximately 40% of the cost falling on Member State Competent 

Authorities and 60% falling on operators for both electronic and paper-based PIC.

128 

Waste type201920202021202220232024202520262027202820292030Waste type201920202021202220232024202520262027202820292030Ferrous metal1,870,1131,464,6621,648,8301,374,2631,426,2351,617,9591,309,3561,357,1931,556,4721,213,8331,257,5341,464,369Ferrous metal2,826,1032,213,3882,491,7022,076,7792,155,3182,445,0501,978,6912,050,9812,352,1311,834,3371,900,3782,212,945Glass31,77427,62125,88423,95321,82919,51217,00114,29711,3998,3085,0241,546Glass48,01641,74039,11536,19832,98829,48625,69221,60517,22612,5557,5922,336Non-ferrous metals566,793554,004526,660497,970467,932436,548403,816369,737334,311297,537259,417219,949Non-ferrous metals856,534837,207795,886752,529707,137659,708610,244558,744505,208449,637392,029332,386Paper and cardboard2,198,0722,320,6002,328,3452,335,8032,342,9732,349,8552,356,4502,362,7572,368,7762,374,5082,379,9532,385,110Paper and cardboard3,321,7133,506,8773,518,5823,529,8513,540,6863,551,0873,561,0523,570,5843,579,6813,588,3433,596,5713,604,364Plastic481,229484,058486,522488,620490,354491,722492,724493,362493,634493,541493,083492,259Plastic727,230731,506735,229738,400741,019743,087744,602745,565745,977745,836745,143743,899Textiles633,798660,498687,430714,557741,878769,394797,104825,009853,108881,401909,889938,572Textiles957,791998,1411,038,8411,079,8341,121,1221,162,7041,204,5791,246,7481,289,2111,331,9681,375,0191,418,364Total5,781,7785,511,4425,703,6725,435,1675,491,2015,684,9895,376,4515,422,3545,617,7005,269,1295,304,8995,501,804Total8,737,3888,328,8598,619,3548,213,5918,298,2708,591,1218,124,8618,194,2288,489,4347,962,6768,016,7328,314,294Waste type201920202021202220232024202520262027202820292030Waste type201920202021202220232024202520262027202820292030Ferrous metal374,023292,932329,766274,853285,247323,592261,871271,439311,294242,767251,507292,874Ferrous metal565,221442,678498,340415,356431,064489,010395,738410,196470,426366,867380,076442,589Glass6,3555,5245,1774,7914,3663,9023,4002,8592,2801,6621,005309Glass9,6038,3487,8237,2406,5985,8975,1384,3213,4452,5111,518467Non-ferrous metals113,359110,801105,33299,59493,58687,31080,76373,94766,86259,50751,88343,990Non-ferrous metals171,307167,441159,177150,506141,427131,942122,049111,749101,04289,92778,40666,477Paper and cardboard439,614464,120465,669467,161468,595469,971471,290472,551473,755474,902475,991477,022Paper and cardboard664,343701,375703,716705,970708,137710,217712,210714,117715,936717,669719,314720,873Plastic96,24696,81297,30497,72498,07198,34498,54598,67298,72798,70898,61798,452Plastic145,446146,301147,046147,680148,204148,617148,920149,113149,195149,167149,029148,780Textiles126,760132,100137,486142,911148,376153,879159,421165,002170,622176,280181,978187,714Textiles191,558199,628207,768215,967224,224232,541240,916249,350257,842266,394275,004283,673Total1,156,3561,102,2881,140,7341,087,0331,098,2401,136,9981,075,2901,084,4711,123,5401,053,8261,060,9801,100,361Total1,747,4781,665,7721,723,8711,642,7181,659,6541,718,2241,624,9721,638,8461,697,8871,592,5351,603,3461,662,859YearYearYearPIC electronic EUR cost based on 20 tonne shipments EU forecastPIC paper based EUR cost based on 20 tonne shipments EU forecastPIC electronic EUR cost based on 100 tonne shipments EU forecastPIC paper based EUR cost based on 100 tonne shipments EU forecastYear 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The extent to which the application of PIC may lead to alternative routing of EU waste to either OECD 

countries or being re-routed within the EU itself is likely to be influenced by the additional costs of 

applying PIC in comparison to the economic benefit of its export (essentially the reported Comext value 

of the wastes concerned). The effect of re-routing waste would generally more pronounced where PIC 

costs represent a higher proportion of the total value of those wastes. A calculation of this deterrence 

effect is shown in the table below. 

Table 44 Cost of PIC as a percentage of the EUR value of the wastes being exported to non-OECD third countries 
for 20t shipments 

The percentages for 100t shipments are 20% of the values shown in the table above. By way of example, 

for ferrous metals a 100t electronic PIC percentage in 2030 would be 0.04%. 

A further cost of the application of PIC would be in relation to the delay in shipments taking place as 

the timescales for application of PIC will generally lead to longer periods prior to waste being shipped 

and the need for those materials to be stored accordingly. As part of the evaluation of the Waste 

Shipment Regulation the storage costs resulting from the application of PIC were considered to be 

particularly burdensome, with business operators indicating the delays in shipments and associated 

costs averaging €150 00089. However, it is noted that these costs were generally related to hazardous 

wastes, the storage of which will be more expensive than for non-hazardous wastes addressed in the 

tables above. It has not been possible to gather information on the likely additional storage costs 

resulting from the application of PIC but it is clear that higher costs would be involved. 

Under Measure 2a4: Restrict exports to OECD countries the primary action that would lead to 

restriction in exports of wastes to OECD countries would be the application of PIC. In keeping with the 

assessment of costs and benefits of 2a3 the economic costs of application have been calculated on the 

basis of the totals of the wastes concerned exported to OECD countries over the period 2019-2030 and 

using the 20 tonne and 100 tonne threshold per PIC shipment described earlier in this assessment. 

89 Trinomics (2019) 

129 

Waste type201920202021202220232024202520262027202820292030Ferrous metal0.16%0.19%0.18%0.13%0.19%0.18%0.12%0.19%0.18%0.11%0.19%0.17%Glass0.44%0.45%0.43%0.41%0.38%0.35%0.32%0.28%0.23%0.18%0.11%0.04%Non-ferrous metals0.02%0.02%0.02%0.02%0.02%0.02%0.01%0.01%0.01%0.01%0.01%0.01%Paper and cardboard0.47%0.45%0.45%0.44%0.44%0.43%0.43%0.43%0.43%0.43%0.43%0.43%Plastic0.21%0.21%0.21%0.21%0.21%0.21%0.21%0.21%0.00%0.00%0.00%0.00%Textiles0.07%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%Total0.11%0.10%0.10%0.09%0.10%0.10%0.09%0.09%0.09%0.08%0.09%0.09%Waste type201920202021202220232024202520262027202820292030Ferrous metal0.25%0.29%0.27%0.19%0.29%0.27%0.18%0.29%0.27%0.17%0.29%0.26%Glass0.67%0.68%0.65%0.62%0.58%0.53%0.48%0.42%0.35%0.27%0.17%0.06%Non-ferrous metals0.03%0.03%0.03%0.03%0.02%0.02%0.02%0.02%0.02%0.01%0.01%0.01%Paper and cardboard0.70%0.68%0.67%0.67%0.66%0.66%0.65%0.65%0.65%0.65%0.65%0.65%Plastic0.31%0.31%0.31%0.31%0.31%0.32%0.32%0.32%0.00%0.00%0.00%0.00%Textiles0.10%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%Total0.16%0.16%0.15%0.14%0.15%0.15%0.13%0.14%0.14%0.12%0.13%0.13%PIC electronic EUR cost based on 20 tonne shipments EU forecast as percentage of value of shipmentsPIC paper EUR cost based on 20 tonne shipments EU forecast as percentage of value of shipmentsYearYear 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The results of the assessment of the total number of shipments that would require to be covered by 

PICs that would be required per waste type are shown in the table below. 

Table 45 Assessment of the total number of shipments for which prior informed consent would be required by 

waste type for the period 2019-2030 for shipments to 0ECD third countries based on 20t and 100t shipment sizes 

As noted under measures 2a3, the costs of application of PIC vary by the nature of the PIC concerned, 

with electronic PIC less costly than paper-based PIC as a result of the time required for completion and 

transmission. As for measure 2a2 an assumption that one PIC addresses 56 shipments has been used. 

The costs resulting from PIC against the different wastes are shown in the tableError! Reference 

source not found. below. 

130 

Total number of PICs based on 20t shipmentsWaste type201920202021202220232024202520262027202820292030Ferrous metal570,743638,063643,779697,422716,950721,877779,076799,036803,173863,929884,320887,668Glass14,33213,94014,73615,55216,38917,24518,12219,01919,93620,87321,83022,808Non-ferrous metals34,02237,09741,69146,42751,30356,32061,47866,77772,21677,79683,51789,378Paper and cardboard61,89667,30269,51371,75574,02776,32878,66081,02283,41485,83688,28890,770Plastic25,82127,26528,74730,26731,82633,42335,05836,73138,44240,19141,97943,804Textiles7,5867,5967,5877,5577,5077,4367,3467,2357,1036,9516,7796,587Total714,400791,263806,054868,981898,001912,629979,7391,009,8181,024,2831,095,5761,126,7131,141,016Total number of PICs based on 100t shipmentsWaste type201920202021202220232024202520262027202820292030Ferrous metal114,149127,613128,756139,484143,390144,375155,815159,807160,635172,786176,864177,534Glass2,8662,7882,9473,1103,2783,4493,6243,8043,9874,1754,3664,562Non-ferrous metals6,8047,4198,3389,28510,26111,26412,29613,35514,44315,55916,70317,876Paper and cardboard12,37913,46013,90314,35114,80515,26615,73216,20416,68317,16717,65818,154Plastic5,1645,4535,7496,0536,3656,6857,0127,3467,6888,0388,3968,761Textiles1,5171,5191,5171,5111,5011,4871,4691,4471,4211,3901,3561,317Total142,880158,253161,211173,796179,600182,526195,948201,964204,857219,115225,343228,203YearYear 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 46 Total EUR cost for production of PIC documentation under measure 2a4 based on 20t and 100t shipping averages, paper and electronic based procedures. 

The split of costs in the tables below between Member State Competent Authorities and Operators is approximately 40% of the cost falling on Member State Competent 

Authorities and 60% falling on operators for both electronic and paper-based PIC.

131 

Waste type201920202021202220232024202520262027202820292030Waste type201920202021202220232024202520262027202820292030Ferrous metal5,462,8296,107,1716,161,8826,675,3276,862,2346,909,3897,456,8717,647,9137,687,5138,269,0318,464,2098,496,253Ferrous metal8,255,3949,229,1219,311,79910,087,71510,370,16810,441,42811,268,77911,557,48111,617,32412,496,11012,791,06212,839,487Glass137,176133,429141,047148,857156,862165,059173,450182,035190,812199,784208,948218,307Glass207,299201,638213,149224,953237,048249,436262,117275,090288,355301,912315,762329,904Non-ferrous metals325,642355,067399,046444,372491,045539,066588,433639,148691,210744,619799,375855,478Non-ferrous metals492,108536,575603,036671,533742,065814,633889,237965,8771,044,5521,125,2631,208,0101,292,793Paper and cardboard592,433644,174665,342686,798708,541730,573752,891775,497798,391821,572845,041868,797Paper and cardboard895,282973,4711,005,4611,037,8851,070,7441,104,0371,137,7651,171,9271,206,5241,241,5551,277,0211,312,921Plastic247,143260,964275,151289,703304,620319,903335,551351,564367,942384,686401,795419,269Plastic373,481394,368415,806437,797460,340483,435507,082531,281556,032581,335607,190633,596Textiles72,61072,70972,61772,33271,85271,17770,30869,24567,98766,53464,88763,046Textiles109,728109,877109,739109,307108,582107,562106,249104,642102,741100,54698,05895,275Total6,837,8337,573,5157,715,0858,317,3908,595,1558,735,1679,377,5049,665,4029,803,85510,486,22510,784,25510,921,150Total10,333,29211,445,05011,658,99112,569,19012,988,94713,200,53214,171,22814,606,29714,815,52715,846,72116,297,10116,503,976Waste type201920202021202220232024202520262027202820292030Waste type201920202021202220232024202520262027202820292030Ferrous metal1,092,5661,221,4341,232,3761,335,0651,372,4471,381,8781,491,3741,529,5831,537,5031,653,8061,692,8421,699,251Ferrous metal1,651,0791,845,8241,862,3602,017,5432,074,0342,088,2862,253,7562,311,4962,323,4652,499,2222,558,2122,567,897Glass27,43526,68628,20929,77131,37233,01234,69036,40738,16239,95741,79043,661Glass41,46040,32842,63044,99147,41049,88752,42355,01857,67160,38263,15265,981Non-ferrous metals65,12871,01379,80988,87498,209107,813117,687127,830138,242148,924159,875171,096Non-ferrous metals98,422107,315120,607134,307148,413162,927177,847193,175208,910225,053241,602258,559Paper and cardboard118,487128,835133,068137,360141,708146,115150,578155,099159,678164,314169,008173,759Paper and cardboard179,056194,694201,092207,577214,149220,807227,553234,385241,305248,311255,404262,584Plastic49,42952,19355,03057,94160,92463,98167,11070,31373,58876,93780,35983,854Plastic74,69678,87483,16187,55992,06896,687101,416106,256111,206116,267121,438126,719Textiles14,52214,54214,52314,46614,37014,23514,06213,84913,59713,30712,97712,609Textiles21,94621,97521,94821,86121,71621,51221,25020,92820,54820,10919,61219,055Total1,367,5671,514,7031,543,0171,663,4781,719,0311,747,0331,875,5011,933,0801,960,7712,097,2452,156,8512,184,230Total2,066,6582,289,0102,331,7982,513,8382,597,7892,640,1062,834,2462,921,2592,963,1053,169,3443,259,4203,300,795PIC electronic EUR cost based on 20 tonne shipments EU forecastPIC paper based EUR cost based on 20 tonne shipments EU forecastYearYearYearPIC electronic EUR cost based on 100 tonne shipments EU forecastYearPIC paper based EUR cost based on 100 tonne shipments EU forecast 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The extent to which the application of PIC may lead to alternative routing of EU waste to either OECD 

countries or being re-routed within the EU itself is likely to be influenced by the additional costs of 

applying PIC in comparison to the economic benefit of its export (essentially the reported Comext value 

of the wastes concerned). The effect of re-routing waste would generally more pronounced where PIC 

costs represent a higher proportion of the total value of those wastes. A calculation of this deterrence 

effect is shown in the table below. 

Table 47 Cost of PIC as a percentage of the EUR value of the wastes being exported to OECD countries for 20t 
shipments 

The percentages for 100t shipments are 20% of the values shown in Error! Reference source not 

found.. By way of example, for ferrous metals a 100t electronic PIC percentage in 2030 would be 0.05% 

of the EUR value of the wastes being shipped.  

A further cost, as under 2a3, would be in relation to the delay in shipments taking place as the 

timescales for application of PIC will generally lead to longer periods prior to waste being shipped and 

the need for those materials to be stored accordingly. As part of the evaluation of the Waste Shipment 

Regulation the storage costs resulting from the application of PIC were considered to be particularly 

burdensome, with business operators indicating the delays in shipments and associated costs averaging 

€150 00090. However, it is noted that these costs were generally related to hazardous wastes, the 

storage of which will be more expensive than for non-hazardous wastes addressed in the tables above. 

It has not been possible to gather information on the likely additional storage costs resulting from the 

application of PIC but it is clear that higher costs would be involved. 

The total costs of the application of PIC above are presented on the basis of all wastes continuing to be 

exported to OECD countries according to the forecast presented in Section 4. However, it is likely that 

some retention of waste within the EU would result from the application of PIC. In order to assess the 

possible impacts of such retention of waste the same costs and benefit approach as applied for 2a2 has 

90 Trinomics (2019) 

132 

Waste type201920202021202220232024202520262027202820292030Ferrous metal0.19%0.18%0.19%0.21%0.19%0.19%0.21%0.19%0.19%0.21%0.19%0.19%Glass0.38%0.41%0.42%0.43%0.44%0.45%0.46%0.46%0.47%0.48%0.49%0.49%Non-ferrous metals0.01%0.01%0.01%0.01%0.01%0.01%0.01%0.01%0.01%0.01%0.01%0.02%Paper and cardboard0.46%0.42%0.38%0.36%0.33%0.31%0.29%0.28%0.26%0.25%0.24%0.23%Plastic0.17%0.17%0.17%0.17%0.17%0.17%0.17%0.17%0.00%0.00%0.00%0.00%Textiles0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%0.06%Total0.10%0.10%0.10%0.11%0.10%0.10%0.11%0.10%0.10%0.11%0.10%0.10%Waste type201920202021202220232024202520262027202820292030Ferrous metal0.29%0.28%0.28%0.31%0.28%0.29%0.31%0.28%0.29%0.31%0.28%0.29%Glass0.57%0.62%0.64%0.65%0.66%0.68%0.69%0.70%0.71%0.72%0.73%0.75%Non-ferrous metals0.01%0.01%0.02%0.02%0.02%0.02%0.02%0.02%0.02%0.02%0.02%0.02%Paper and cardboard0.70%0.63%0.58%0.54%0.50%0.47%0.44%0.42%0.39%0.38%0.36%0.34%Plastic0.26%0.26%0.26%0.26%0.26%0.26%0.26%0.26%0.00%0.00%0.26%0.26%Textiles0.10%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%0.09%Total0.15%0.15%0.15%0.16%0.15%0.15%0.16%0.15%0.15%0.16%0.15%0.15%PIC electronic EUR cost based on 20 tonne shipments EU forecast as percentage of value of shipmentsYearPIC paper EUR cost based on 20 tonne shipments EU forecast as percentage of value of shipmentsYear 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

been applied for 2a4, analysing the potential impacts of 75%, 50% and 20% of EU wastes formerly 

exported to the OECD being retained within the EU as a result of the application of PIC. 

The results of the calculations of the economic costs in respect to waste management and benefits in 

respect to the EUR value of materials retained resulting from these scenarios are presented in Error! 

Reference source not found. and Error! Reference source not found. below. The waste management 

costs would generally fall on those involved in the production of the wastes concerned i.e. those 

producing the wastes would be required to pay a higher price for the management of their wastes 

within the EU in comparison to the likely lower prices charged by OECD countries. The costs of such 

management would also likely be shared with Member States that would need to invest in their own 

waste management facilities to manage these wastes. 

Additionally. It is expected that changes in the waste flows would carry economic impacts for those 

involved in the shipping process to OECD countries, whereby the quantities shipped would be reduced 

and the income for operators involved in such shipments would fall. However, as the amount of waste 

generated would remain the same the shipping would likely shift to other OECD countries or would 

remain within the EU. Consequently, there is likely to be a shift in the flows of materials that will be 

met with a shift in the efforts involved in such shipments whereby the total economic effort involved in 

such shipments will likely reduce in total as a result in the reduction of the total distance that waste is 

shipped. It has not been possible to calculate the total change in value as a result of these changes. 

133 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 48 Results of the economic cost calculations for sub-measure 2a4 comprising waste management costs 

134 

EUR value costs for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal1,186,832,1661,326,819,4411,338,705,5801,450,254,6761,490,861,3941,501,106,0971,620,049,7421,661,554,8661,670,158,1341,796,496,3271,838,899,8571,845,861,691Glass2,794,7042,718,3772,873,5653,032,6943,195,7633,362,7733,533,7243,708,6163,887,4494,070,2224,256,9364,447,590Non-ferrous metals602,960,300657,444,022738,875,653822,801,651909,222,015998,136,7461,089,545,8441,183,449,3081,279,847,1381,378,739,3351,480,125,8991,584,006,829Paper and cardboard12,069,72413,123,83713,555,10313,992,22814,435,21114,884,05215,338,75115,799,30916,265,72416,737,99817,216,13017,700,121Plastic47,213,47949,853,90052,564,10055,344,07958,193,83861,113,37664,102,69367,161,78970,290,66473,489,31976,757,75380,095,966Textiles73,964,52474,065,23573,972,26973,681,23473,192,12872,504,95271,619,70670,536,39069,255,00367,775,54666,098,01964,222,422Total1,925,834,8972,124,024,8112,220,546,2702,419,106,5622,549,100,3492,651,107,9962,864,190,4603,002,210,2773,109,704,1133,337,308,7483,483,354,5953,596,334,619EUR value costs for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal791,221,444884,546,294892,470,387966,836,451993,907,5961,000,737,3981,080,033,1611,107,703,2441,113,438,7561,197,664,2181,225,933,2381,230,574,460Glass1,863,1361,812,2511,915,7102,021,7962,130,5092,241,8492,355,8162,472,4112,591,6322,713,4812,837,9572,965,060Non-ferrous metals401,973,534438,296,014492,583,769548,534,434606,148,010665,424,497726,363,896788,966,205853,231,426919,159,557986,750,5991,056,004,553Paper and cardboard8,046,4838,749,2249,036,7359,328,1529,623,4749,922,70110,225,83410,532,87210,843,81611,158,66611,477,42011,800,080Plastic31,475,65333,235,93335,042,73336,896,05338,795,89240,742,25042,735,12844,774,52646,860,44348,992,87951,171,83553,397,311Textiles49,309,68349,376,82349,314,84649,120,82348,794,75248,336,63547,746,47147,024,26046,170,00245,183,69844,065,34642,814,948Total1,283,889,9311,416,016,5411,480,364,1801,612,737,7081,699,400,2331,767,405,3311,909,460,3072,001,473,5182,073,136,0752,224,872,4992,322,236,3972,397,556,413EUR value costs for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal316,488,577353,818,518356,988,155386,734,580397,563,038400,294,959432,013,265443,081,298445,375,502479,065,687490,373,295492,229,784Glass745,254724,901766,284808,718852,204896,740942,327988,9641,036,6531,085,3921,135,1831,186,024Non-ferrous metals160,789,413175,318,406197,033,507219,413,774242,459,204266,169,799290,545,558315,586,482341,292,570367,663,823394,700,240422,401,821Paper and cardboard3,218,5933,499,6903,614,6943,731,2613,849,3903,969,0814,090,3344,213,1494,337,5274,463,4664,590,9684,720,032Plastic12,590,26113,294,37314,017,09314,758,42115,518,35716,296,90017,094,05117,909,81018,744,17719,597,15220,468,73421,358,924Textiles19,723,87319,750,72919,725,93819,648,32919,517,90119,334,65419,098,58818,809,70418,468,00118,073,47917,626,13917,125,979Total513,555,972566,406,616592,145,672645,095,083679,760,093706,962,132763,784,123800,589,407829,254,430889,948,999928,894,559959,022,565Costs of treatmentYearYearYear 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 49 EUR retained value of materials retained within the EU for sub-measure 2a4

135 

EUR value retained within the EU forecast for 75% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal2,123,023,6932,483,520,8522,459,136,4332,430,742,2292,773,332,0802,742,353,7742,707,503,1193,074,396,8893,036,824,6972,995,517,5913,386,715,2823,342,549,203Glass27,280,00924,200,74825,052,30925,914,85426,788,38327,672,89828,568,39729,474,88130,392,35031,320,80332,260,24133,210,664Non-ferrous metals2,752,952,8042,807,677,9322,933,908,0903,062,173,3393,192,473,6793,324,809,1103,459,179,6323,595,585,2463,734,025,9513,874,501,7464,017,012,6334,161,558,611Paper and cardboard96,193,517115,875,828129,868,222144,588,141160,035,585176,210,554193,113,047210,743,066229,100,609248,185,677267,998,271288,538,389Plastic108,087,959114,039,533120,149,183126,416,907132,842,706139,426,580146,168,528153,068,552160,126,651167,342,825174,717,073182,249,396Textiles86,337,08594,473,95394,464,05594,175,23493,607,48992,760,82091,635,22790,230,71088,547,27086,584,90684,343,61881,823,407Total5,193,875,0665,639,788,8475,762,578,2915,884,010,7036,379,079,9216,503,233,7346,626,167,9517,153,499,3457,279,017,5277,403,453,5497,963,047,1188,089,929,670EUR value retained within the EU forecast for 50% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal1,415,349,1291,655,680,5681,639,424,2891,620,494,8191,848,888,0531,828,235,8491,805,002,0792,049,597,9262,024,549,7981,997,011,7282,257,810,1882,228,366,135Glass18,186,67316,133,83216,701,53917,276,56917,858,92218,448,59919,045,59819,649,92120,261,56620,880,53521,506,82722,140,443Non-ferrous metals1,835,301,8691,871,785,2881,955,938,7272,041,448,8932,128,315,7862,216,539,4072,306,119,7552,397,056,8312,489,350,6342,583,001,1642,678,008,4222,774,372,407Paper and cardboard64,129,01277,250,55286,578,81596,392,094106,690,390117,473,702128,742,031140,495,377152,733,739165,457,118178,665,514192,358,926Plastic72,058,64076,026,35680,099,45584,277,93888,561,80492,951,05397,445,686102,045,701106,751,101111,561,883116,478,049121,499,598Textiles57,558,05762,982,63562,976,03762,783,48962,404,99261,840,54661,090,15160,153,80759,031,51357,723,27156,229,07954,548,938Total3,462,583,3783,759,859,2313,841,718,8613,922,673,8024,252,719,9474,335,489,1564,417,445,3014,768,999,5634,852,678,3524,935,635,6995,308,698,0795,393,286,447EUR value retained within the EU forecast for 20% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal566,139,651662,272,227655,769,715648,197,928739,555,221731,294,340722,000,832819,839,171809,819,919798,804,691903,124,075891,346,454Glass7,274,6696,453,5336,680,6166,910,6287,143,5697,379,4397,618,2397,859,9688,104,6278,352,2148,602,7318,856,177Non-ferrous metals734,120,748748,714,115782,375,491816,579,557851,326,314886,615,763922,447,902958,822,732995,740,2531,033,200,4661,071,203,3691,109,748,963Paper and cardboard25,651,60530,900,22134,631,52638,556,83842,676,15646,989,48151,496,81356,198,15161,093,49666,182,84771,466,20576,943,570Plastic28,823,45630,410,54232,039,78233,711,17535,424,72237,180,42138,978,27440,818,28142,700,44044,624,75346,591,21948,599,839Textiles23,023,22325,193,05425,190,41525,113,39624,961,99724,736,21924,436,06024,061,52323,612,60523,089,30822,491,63221,819,575Total1,385,033,3511,503,943,6931,536,687,5441,569,069,5211,701,087,9791,734,195,6631,766,978,1201,907,599,8251,941,071,3411,974,254,2802,123,479,2312,157,314,579YearYearBenefitsYear 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Furthermore, the costs of transportation would fall in comparison to BAU under measure 2a4, 

dependent on the volume of wastes shipped. The savings in EUR are presented below. 

Table 50 Transport costs avoided under measure 2a4 for different ratios of wastes retained within the EU 

A comparison of the economic costs and benefits using the data from these tables indicates that for a 

majority of the waste streams, increased retention of EU wastes within the EU as a result of this 

measure results in economic costs outweighing the economic benefits. In order of highest cost, 

provisions concerning ferrous metal, paper and cardboard, glass, plastic and textiles all carry additional 

costs in comparison to the economic benefits for all scenarios, albeit the costs vary considerably. For 

the potential years for measures to enter into force the costs for all wastes are shown in the table 

below. Negative values in the table would indicate the additional costs incurred as a result of the 

measure. Positive values indicate the additional net economic benefits incurred. As can be seen in the 

table, the economic benefits of all waste materials modelled retained outweighing the costs of their 

management within the EU. 

136 

Transport costs avoided for 75% retained within EU lower confidence boundWaste type2019202020212,0222,0232,0242,0252,0262,0272,0282,0292,030Ferrous metal205,467,590229,702,565231,760,325251,072,006258,101,951259,875,542280,467,387287,652,866289,142,287311,014,296318,355,310319,560,561Glass5,159,4535,018,5425,305,0435,598,8195,899,8716,208,1976,523,7996,846,6767,176,8287,514,2557,858,9588,210,936Non-ferrous metals12,248,03013,354,76615,008,90016,713,70318,469,17320,275,31322,132,12024,039,59725,997,74128,006,55430,066,03632,176,186Paper and cardboard22,282,56724,228,62225,024,80625,831,80526,649,62027,478,25028,317,69529,167,95530,029,03030,900,92031,783,62532,677,146Plastic9,295,5179,815,37010,348,96110,896,29111,457,35912,032,16612,620,71113,222,99413,839,01514,468,77515,112,27315,769,509Textiles2,730,9982,734,7162,731,2842,720,5382,702,4792,677,1062,644,4202,604,4212,557,1082,502,4822,440,5422,371,289Total257,184,155284,854,581290,179,320312,833,163323,280,453328,546,573352,706,131363,534,507368,742,009394,407,282405,616,744410,765,628Transport costs avoided for 50% retained within EU lower confidence boundWaste type2019202020212,0222,0232,0242,0252,0262,0272,0282,0292,030Ferrous metal136,978,393153,135,043154,506,884167,381,338172,067,967173,250,361186,978,258191,768,577192,761,525207,342,864212,236,873213,040,374Glass3,439,6363,345,6953,536,6953,732,5463,933,2474,138,7984,349,1994,564,4514,784,5525,009,5045,239,3055,473,957Non-ferrous metals8,165,3538,903,17810,005,93411,142,46812,312,78213,516,87514,754,74716,026,39817,331,82818,671,03620,044,02421,450,791Paper and cardboard14,855,04516,152,41416,683,20417,221,20417,766,41318,318,83318,878,46319,445,30320,019,35320,600,61321,189,08421,784,764Plastic6,197,0116,543,5806,899,3087,264,1947,638,2408,021,4448,413,8078,815,3299,226,0109,645,85010,074,84910,513,006Textiles1,820,6651,823,1441,820,8561,813,6921,801,6521,784,7371,762,9471,736,2801,704,7391,668,3211,627,0281,580,860Total171,456,103189,903,054193,452,880208,555,442215,520,302219,031,049235,137,421242,356,338245,828,006262,938,188270,411,163273,843,752Transport costs avoided for 20% retained within EU upper confidence boundWaste type2019202020212,0222,0232,0242,0252,0262,0272,0282,0292,030Ferrous metal54,791,35761,254,01761,802,75366,952,53568,827,18769,300,14474,791,30376,707,43177,104,61082,937,14684,894,74985,216,150Glass1,375,8541,338,2781,414,6781,493,0181,573,2991,655,5191,739,6801,825,7801,913,8212,003,8012,095,7222,189,583Non-ferrous metals3,266,1413,561,2714,002,3734,456,9874,925,1135,406,7505,901,8996,410,5596,932,7317,468,4158,017,6108,580,316Paper and cardboard5,942,0186,460,9666,673,2826,888,4817,106,5657,327,5337,551,3857,778,1218,007,7418,240,2458,475,6338,713,906Plastic2,478,8042,617,4322,759,7232,905,6783,055,2963,208,5783,365,5233,526,1323,690,4043,858,3404,029,9394,205,203Textiles728,266729,258728,342725,477720,661713,895705,179694,512681,895667,328650,811632,344Total68,582,44175,961,22277,381,15283,422,17786,208,12187,612,41994,054,96896,942,53598,331,202105,175,275108,164,465109,537,501YearYearYear 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 51 Balance of costs and benefits for certain waste streams under 2a4 

The above tables use the Comext values for the value of the wastes exported. If the market value of 

the materials is applied then the results change as indicated in the table below. In general, the results 

maintain a positive outcome i.e. the economic benefits outweigh the costs, except for textiles where 

the economic costs would outweigh the benefits. 

Table 52 balance of costs and benefits using market value of primary and secondary materials 

Any diversion of EU wastes from OECD countries is likely to have an economic impact on the OECD third 

countries themselves, primarily in relation to a reduction in feedstock to recycling activities. Given the 

EUR values of wastes that would be retained under the scenarios laid down it is apparent that the EUR 

137 

EUR value of materials retained within the EU forecast for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal1,141,659,1171,386,403,9761,352,191,1781,231,559,5591,540,572,6371,501,123,2181,367,920,7641,700,494,8901,655,808,8501,510,035,5601,866,170,7341,816,248,073Glass29,644,75826,500,91427,483,78728,480,97929,492,49130,518,32231,558,47232,612,94133,681,72934,764,83735,862,26336,974,009Non-ferrous metals2,162,240,5332,163,588,6772,210,041,3372,256,085,3912,301,720,8372,346,947,6772,391,765,9092,436,175,5352,480,176,5542,523,768,9652,566,952,7702,609,727,968Paper and cardboard106,406,361126,980,613141,337,925156,427,718172,249,994188,804,751206,091,991224,111,712242,863,914262,348,599282,565,766303,515,414Plastic70,169,99774,001,00477,934,04481,969,11986,106,22790,345,37094,686,54799,129,757103,675,002108,322,280113,071,593117,922,939Textiles15,103,55923,143,43523,223,07023,214,53823,117,83922,932,97322,659,94122,298,74121,849,37521,311,84120,686,14119,972,274Total3,525,224,3243,800,618,6183,832,211,3413,777,737,3044,153,260,0254,180,672,3114,114,683,6224,514,823,5754,538,055,4234,460,552,0834,885,309,2674,904,360,678EUR value of materials retained within the EU forecast for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal761,106,078924,269,317901,460,786821,039,7061,027,048,4251,000,748,812911,947,1761,133,663,2601,103,872,5671,006,690,3731,244,113,8231,210,832,049Glass19,763,17217,667,27618,322,52418,987,31919,661,66020,345,54821,038,98121,741,96022,454,48623,176,55823,908,17624,649,340Non-ferrous metals1,441,493,6891,442,392,4511,473,360,8911,504,056,9271,534,480,5581,564,631,7841,594,510,6061,624,117,0231,653,451,0361,682,512,6441,711,301,8471,739,818,645Paper and cardboard70,937,57484,653,74294,225,283104,285,146114,833,329125,869,834137,394,660149,407,808161,909,276174,899,066188,377,177202,343,609Plastic46,779,99849,334,00251,956,02954,646,07957,404,15260,230,24763,124,36466,086,50569,116,66872,214,85475,381,06278,615,293Textiles10,069,03915,428,95615,482,04615,476,35915,411,89315,288,64915,106,62714,865,82714,566,25014,207,89413,790,76113,314,849Total2,350,149,5502,533,745,7452,554,807,5612,518,491,5362,768,840,0172,787,114,8742,743,122,4153,009,882,3833,025,370,2822,973,701,3893,256,872,8453,269,573,786EUR value of materials retained within the EU forecast for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal304,442,431369,707,727360,584,314328,415,882410,819,370400,299,525364,778,870453,465,304441,549,027402,676,149497,645,529484,332,820Glass7,905,2697,066,9107,329,0107,594,9287,864,6648,138,2198,415,5928,696,7848,981,7949,270,6239,563,2709,859,736Non-ferrous metals576,597,475576,956,980589,344,357601,622,771613,792,223625,852,714637,804,242649,646,809661,380,414673,005,057684,520,739695,927,458Paper and cardboard28,375,02933,861,49737,690,11341,714,05845,933,33250,347,93454,957,86459,763,12364,763,71069,959,62675,350,87180,937,444Plastic18,711,99919,733,60120,782,41221,858,43222,961,66124,092,09925,249,74626,434,60227,646,66728,885,94130,152,42531,446,117Textiles4,027,6166,171,5836,192,8196,190,5436,164,7576,115,4606,042,6515,946,3315,826,5005,683,1585,516,3045,325,940Total940,059,8201,013,498,2981,021,923,0241,007,396,6141,107,536,0071,114,845,9501,097,248,9661,203,952,9531,210,148,1131,189,480,5551,302,749,1381,307,829,514Balance of costs and benefitsYearYearYear 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal217,196,365242,814,753244,989,977265,404,033272,835,271274,710,104296,477,400304,073,050305,647,492328,768,029336,528,092337,802,143Glass13,543,56513,173,67313,925,73814,696,90115,487,16016,296,51817,124,97217,972,52418,839,17419,724,92120,629,76521,553,706Non-ferrous metals1,472,570,4161,605,632,4371,804,507,5722,009,474,5352,220,533,3262,437,683,9452,660,926,3922,890,260,6663,125,686,7693,367,204,6993,614,814,4573,868,516,043Paper and cardboard116,055,038126,190,738130,337,531134,540,653138,800,104143,115,884147,487,993151,916,430156,401,196160,942,291165,539,715170,193,468Plastic249,855,745263,828,965278,171,459292,883,228307,964,272323,414,590339,234,183355,423,051371,981,194388,908,612406,205,304423,871,271Textiles-7,510,244-7,520,470-7,511,030-7,481,479-7,431,816-7,362,041-7,272,155-7,162,156-7,032,046-6,881,825-6,711,491-6,521,046Total2,061,710,8852,244,120,0952,464,421,2472,709,517,8712,948,188,3173,187,858,9993,453,978,7853,712,483,5663,971,523,7794,258,666,7274,537,005,8424,815,415,58650% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal144,797,576161,876,502163,326,652176,936,022181,890,180183,140,069197,651,600202,715,367203,764,995219,178,686224,352,061225,201,429Glass9,029,0438,782,4499,283,8259,797,93410,324,77410,864,34511,416,64811,981,68312,559,44913,149,94713,753,17614,369,137Non-ferrous metals981,713,6111,070,421,6251,203,005,0481,339,649,6901,480,355,5511,625,122,6301,773,950,9281,926,840,4442,083,791,1792,244,803,1332,409,876,3052,579,010,696Paper and cardboard77,370,02584,127,15886,891,68789,693,76992,533,40395,410,58998,325,328101,277,620104,267,464107,294,861110,359,810113,462,312Plastic166,570,497175,885,977185,447,639195,255,485205,309,514215,609,727226,156,122236,948,701247,987,463259,272,408270,803,536282,580,847Textiles-5,006,829-5,013,647-5,007,354-4,987,653-4,954,544-4,908,028-4,848,103-4,774,771-4,688,031-4,587,883-4,474,327-4,347,364Total1,374,473,9231,496,080,0641,642,947,4981,806,345,2481,965,458,8782,125,239,3332,302,652,5242,474,989,0442,647,682,5192,839,111,1513,024,670,5613,210,277,05720% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal57,919,03164,750,60165,330,66170,774,40972,756,07273,256,02879,060,64081,086,14781,505,99887,671,47489,740,82590,080,571Glass3,611,6173,512,9793,713,5303,919,1734,129,9094,345,7384,566,6594,792,6735,023,7805,259,9795,501,2715,747,655Non-ferrous metals392,685,444428,168,650481,202,019535,859,876592,142,220650,049,052709,580,371770,736,178833,516,472897,921,253963,950,5221,031,604,278Paper and cardboard30,948,01033,650,86334,756,67535,877,50837,013,36138,164,23639,330,13140,511,04841,706,98642,917,94444,143,92445,384,925Plastic66,628,19970,354,39174,179,05678,102,19482,123,80686,243,89190,462,44994,779,48099,194,985103,708,963108,321,414113,032,339Textiles-2,002,732-2,005,459-2,002,941-1,995,061-1,981,818-1,963,211-1,939,241-1,909,908-1,875,212-1,835,153-1,789,731-1,738,946Total549,789,569598,432,025657,178,999722,538,099786,183,551850,095,733921,061,009989,995,6181,059,073,0081,135,644,4601,209,868,2251,284,110,823YearYearYearBalance of costs and benefits using market values 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

economic impact to OECD countries in total is likely to be similar to the value of wastes no longer 

exported. So, for example, a diversion of 20% of ferrous metal exports in 2030 would reduce the 

economic income to OECD third countries of between €13M and €400M per annum. Turkey, as the 

largest importers of ferrous metal waste at present, would be affected to the largest extent, but the 

UK, US, Switzerland and Norway would also be affected.  

Measure 2a5 – Ban all exports of waste to non-OECD third countries would have the second largest 

economic impacts of all of the measures considered under specific objective 2a. Under this measure, 

all exports of EU waste to non-OECD third countries would be halted. A prohibition of waste exports to 

third countries would likely result in changes in the destination countries of those wastes. In some cases 

the wastes may be diverted to OECD countries, in others all wastes may be retained within the EU. The 

results of the modelling under 2a2 provide an indication of the results of retaining certain percentages 

of wastes within the EU that would otherwise be sent to third countries. Those calculations are also 

applicable in relation to this measure when considering the values of materials retained within the EU, 

the costs of managing those wastes in the EU and the transport costs avoided. 

The results of the calculations of the economic costs in respect to waste management and benefits in 

respect to the EUR value of materials retained resulting from retaining 100% of the wastes concerned 

under this scenario are presented in Error! Reference source not found. and Error! Reference source 

not found.2 below. As for the previous measures considered under this specific objective, the waste 

management costs would generally fall on those involved in the production of the wastes concerned i.e. 

those producing the wastes would be required to pay a higher price for the management of their wastes 

within the EU in comparison to the likely lower prices charged by third countries. The costs of such 

management would also likely be shared with Member States that would need to invest in their own 

waste management facilities to manage these wastes. 

Additionally. It is expected that changes in the waste flows would carry economic impacts for those 

involved in the shipping process to third countries, whereby the quantities shipped would be reduced 

and the income for operators involved in such shipments would fall. However, as the amount of waste 

generated would remain the same the shipping would likely shift to intra-EU movements. Consequently, 

there is likely to be a shift in the flows of materials that will be met with a shift in the efforts involved 

in such shipments whereby the total economic effort involved in such shipments will likely reduce in 

total as a result in the reduction of the total distance that waste is shipped. It has not been possible to 

calculate the total change in value as a result of these changes. 

138 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 53 Results of the economic cost calculations for sub-measure 2a5 comprising waste management costs

Table 54 EUR retained value of materials retained within the EU for sub-measure 2a5

139 

EUR value costs for 100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal541,724,257424,275,283477,624,244398,089,260413,144,116468,681,656379,287,275393,144,255450,870,375351,616,596364,275,701424,190,402Glass863,101750,297703,111650,670592,975530,025461,821388,363309,651225,684136,46341,988Non-ferrous metals1,399,302,2001,367,727,4571,300,222,1671,229,391,0551,155,234,1211,077,751,365996,942,787912,808,387825,348,165734,562,121640,450,255543,012,566Paper and cardboard59,708,81463,037,20563,247,58963,450,16263,644,92563,831,87664,011,01764,182,34764,345,86564,501,57364,649,47064,789,556Plastic122,576,911123,297,517123,925,085124,459,613124,901,102125,249,553125,504,964125,667,337125,736,670125,712,965125,596,220125,386,437Textiles860,829,645897,094,199933,673,987970,517,8681,007,625,8431,044,997,9121,082,634,0741,120,534,3301,158,698,6801,197,127,1231,235,819,6601,274,776,290Total2,985,004,9282,876,181,9582,899,396,1822,786,558,6292,765,143,0822,781,042,3882,648,841,9392,616,725,0192,625,309,4072,473,746,0632,430,927,7692,432,197,239CostsYearEUR value of materials retained within the EU forecast for 100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal1,134,800,928775,321,520929,017,5511,088,059,961752,456,965914,944,8441,082,595,855714,587,633885,867,3601,062,126,973661,713,524841,785,100Glass7,217,2206,135,8426,012,2175,873,9465,721,0295,553,4665,371,2565,174,4004,962,8974,736,7494,495,9544,240,513Non-ferrous metals2,559,862,7992,705,576,5162,755,950,1942,803,610,4172,848,557,1862,890,790,4992,930,310,3582,967,116,7623,001,209,7103,032,589,2053,061,255,2443,087,207,828Paper and cardboard471,363,232512,872,981521,542,595529,242,175535,971,721541,731,235546,520,715550,340,163553,189,577555,068,958555,978,305555,917,620Plastic231,382,901232,673,709233,753,750234,623,024235,281,532235,729,273235,966,248235,992,456235,807,898235,412,573234,806,482233,989,624Textiles972,641,5831,109,231,4491,157,557,0211,206,254,4911,255,323,8591,304,765,1261,354,578,2911,404,763,3541,455,320,3161,506,249,1761,557,549,9341,609,222,591Total5,377,268,6635,341,812,0175,603,833,3275,867,664,0145,633,312,2925,893,514,4436,155,342,7235,877,974,7676,136,357,7596,396,183,6336,075,799,4426,332,363,275BenefitsYear 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Savings in terms of costs of transport would also be evident under this measure. The table below shows 

the savings that would be made for 100% of the wastes concerned to be retained within the EU in the 

future. 

Table 55 Transport savings were all wastes currently exported to non-OECD third countries retained in the EU 

A comparison of the economic costs and benefits using the data from these tables indicates that for a 

all of the waste streams modelled, retaining all formerly exported EU wastes to non-OECD third 

countries within the EU as a result of this measure results in economic benefits outweighing the 

economic costs (given that negative values in the table would indicate the additional costs incurred as a 

result of the measure).  

Table 56 Balance of costs and benefits for certain waste streams under 2a5 

The above tables use the Comext values for the value of the wastes exported. If the market value of 

the materials is applied, then the results change as indicated in Error! Reference source not found. 

below. In general, the results are worse for all waste types except for Non-Ferrous metals and Plastic. 

Table 57 Balance of costs and benefits certain waste streams under 2a5 replacing Comext values of wastes with 
virgin and secondary market values 

The results of using market rates are that, in general, the results remain positive, except in relation to 

textiles where the economic costs would outweigh the economic benefits derived. 

Any diversion of EU wastes from third countries is likely to have an economic impact on the third 

countries themselves, primarily in relation to a reduction in feedstock to recycling activities. Given the 

EUR values of wastes that would be retained under the scenarios laid down it is apparent that the EUR 

economic impact to third countries in total is likely to be similar to the value of wastes no longer 

exported. So, for example, a diversion of ferrous metal exports in 2030 would reduce the economic 

140 

EUR value of materials retained within the EU forecast for 100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal93,784,76673,451,68382,687,59968,918,28871,524,62581,139,43465,663,23768,062,19578,055,89760,872,81563,064,39373,436,988Glass1,593,4181,385,1641,298,0511,201,2371,094,723978,508852,594716,979571,664416,648251,93277,517Non-ferrous metals28,424,25127,782,86826,411,62324,972,81923,466,45721,892,53720,251,06018,542,02416,765,43014,921,27913,009,56911,030,302Paper and cardboard110,231,657116,376,378116,764,780117,138,761117,498,323117,843,464118,174,185118,490,486118,792,367119,079,828119,352,868119,611,488Plastic24,133,27224,275,14724,398,70424,503,94424,590,86524,659,46924,709,75524,741,72324,755,37424,750,70724,727,72224,686,419Textiles31,784,47933,123,47834,474,11635,834,50637,204,64738,584,53839,974,18141,373,57542,782,72044,201,61745,630,26447,068,663Total289,951,843276,394,718286,034,872272,569,554275,379,639285,097,951269,625,012271,926,983281,723,452264,242,893266,036,749275,911,377Transport savingsYearWaste type201920202021202220232024202520262027202820292030Ferrous metal686,861,437424,497,919534,080,906758,888,988410,837,474527,402,622768,971,818389,505,573513,052,882771,383,191360,502,216491,031,686Glass7,947,5366,770,7086,607,1576,424,5136,222,7776,001,9495,762,0285,503,0155,224,9104,927,7134,611,4234,276,041Non-ferrous metals1,188,984,8511,365,631,9281,482,139,6501,599,192,1811,716,789,5221,834,931,6711,953,618,6302,072,850,3982,192,626,9762,312,948,3632,433,814,5592,555,225,564Paper and cardboard521,886,075566,212,155575,059,785582,930,774589,825,119595,742,823600,683,884604,648,302607,636,078609,647,212610,681,703610,739,552Plastic132,939,262133,651,338134,227,369134,667,355134,971,295135,139,189135,171,039135,066,843134,826,602134,450,315133,937,983133,289,606Textiles143,596,417245,260,728258,357,150271,571,128284,902,662298,351,752311,918,398325,602,599339,404,356353,323,670367,360,539381,514,963Total2,682,215,5792,742,024,7772,990,472,0173,353,674,9393,143,548,8493,397,570,0063,776,125,7963,533,176,7303,792,771,8044,186,680,4633,910,908,4224,176,077,412Balance of costs and benefitsYear100% of formerly exported wastes to non-OECD third countries retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal99,138,31377,644,55087,407,68372,852,37375,607,48985,771,14369,411,51471,947,41282,511,58864,347,63866,664,31977,629,016Glass4,182,7213,636,0563,407,3833,153,2462,873,6472,568,5842,238,0581,882,0691,500,6171,093,701661,323203,481Non-ferrous metals3,417,424,0353,340,311,1103,175,447,3653,002,461,1842,821,352,5662,632,121,5102,434,768,0172,229,292,0872,015,693,7201,793,972,9151,564,129,6741,326,163,995Paper and cardboard574,123,213606,126,969608,149,895610,097,716611,970,432613,768,043615,490,549617,137,949618,710,245620,207,436621,629,521622,976,501Plastic648,682,240652,495,720655,816,834658,645,581660,981,962662,825,977664,177,625665,036,907665,403,823665,278,372664,660,555663,550,372Textiles-87,407,318-91,089,565-94,803,820-98,544,891-102,312,778-106,107,480-109,928,998-113,777,332-117,652,481-121,554,446-125,483,227-129,438,823Total4,656,143,2054,589,124,8394,435,425,3394,248,665,2104,070,473,3173,890,947,7773,676,156,7643,471,519,0933,266,167,5113,023,345,6162,792,262,1652,561,084,542YearBalance of costs and benefits 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

income to third countries of approximately between €78M and €491M per annum. India, Egypt and 

Pakistan, would be most impacted by this measure.  

Measure 2a6 – Ban all exports of waste would have the largest economic impacts of all of the 

measures considered under specific objective 2a. Under this measure, all exports of EU waste would be 

halted. 

The results of the calculations of the economic costs in respect to waste management and benefits in 

respect to the EUR value of materials retained resulting from these scenarios are presented in Error! 

Reference source not found. and Error! Reference source not found.2 below. As for the previous 

measures considered under this specific objective, the waste management costs would generally fall on 

those involved in the production of the wastes concerned i.e. those producing the wastes would be 

required to pay a higher price for the management of their wastes within the EU in comparison to the 

likely lower prices charged by third countries. The costs of such management would also likely be 

shared with Member States that would need to invest in their own waste management facilities to 

manage these wastes. 

Additionally. It is expected that changes in the waste flows would carry economic impacts for those 

involved in the shipping process to third countries, whereby the quantities shipped would be reduced 

and the income for operators involved in such shipments would fall. However, as the amount of waste 

generated would remain the same the shipping would likely shift to intra-EU movements. Consequently, 

there is likely to be a shift in the flows of materials that will be met with a shift in the efforts involved 

in such shipments whereby the total economic effort involved in such shipments will likely reduce in 

total as a result in the reduction of the total distance that waste is shipped. It has not been possible to 

calculate the total change in value as a result of these changes. 

141 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 58 Results of the economic cost calculations for sub-measure 2a6 comprising waste management costs 

Table 59 EUR retained value of materials retained within the EU for sub-measure 2a6 

142 

Costs of treating 100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal2,124,167,1442,193,367,8722,262,565,0172,331,762,1622,400,959,3072,470,156,4522,539,353,5972,608,550,7422,677,747,8872,746,945,0332,816,142,1782,885,339,323Glass4,589,3734,374,8004,534,5314,694,2624,853,9925,013,7235,173,4545,333,1855,492,9165,652,6475,812,3785,972,108Non-ferrous metals2,203,249,2672,244,319,4852,285,389,7042,326,459,9232,367,530,1412,408,600,3602,449,670,5792,490,740,7972,531,811,0162,572,881,2342,613,951,4532,655,021,672Paper and cardboard75,801,77980,535,65481,321,06082,106,46682,891,87383,677,27984,462,68585,248,09286,033,49886,818,90487,604,31188,389,717Plastic185,528,216189,769,384194,010,551198,251,719202,492,886206,734,054210,975,221215,216,389219,457,556223,698,724227,939,891232,181,059Textiles959,449,010995,847,8451,032,303,6791,068,759,5131,105,215,3481,141,671,1821,178,127,0161,214,582,8501,251,038,6841,287,494,5181,323,950,3521,360,406,186Total5,552,784,7905,708,215,0405,860,124,5426,012,034,0456,163,943,5476,315,853,0506,467,762,5526,619,672,0556,771,581,5576,923,491,0607,075,400,5627,227,310,065CostsYearEUR value of materials retained within the EU forecast for 100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal3,965,499,1854,086,682,6564,207,866,1284,329,049,5994,450,233,0714,571,416,5424,692,600,0144,813,783,4854,934,966,9575,056,150,4285,177,333,9005,298,517,371Glass43,590,56538,403,50639,415,29540,427,08441,438,87442,450,66343,462,45244,474,24145,486,03046,497,81947,509,60948,521,398Non-ferrous metals6,230,466,5376,449,147,0926,667,827,6476,886,508,2027,105,188,7577,323,869,3137,542,549,8687,761,230,4237,979,910,9788,198,591,5338,417,272,0888,635,952,643Paper and cardboard599,621,255667,374,085694,700,224722,026,362749,352,501776,678,640804,004,778831,330,917858,657,055885,983,194913,309,333940,635,471Plastic375,500,180384,726,420393,952,660403,178,900412,405,140421,631,379430,857,619440,083,859449,310,099458,536,339467,762,579476,988,819Textiles1,087,757,6961,235,196,7201,283,509,0951,331,821,4691,380,133,8441,428,446,2191,476,758,5931,525,070,9681,573,383,3421,621,695,7171,670,008,0921,718,320,466Total12,302,435,41812,861,530,48013,287,271,04813,713,011,61714,138,752,18614,564,492,75514,990,233,32415,415,973,89315,841,714,46216,267,455,03116,693,195,60017,118,936,168BenefitsYear 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Furthermore, savings in transport costs would be identified under this measure as shown in the table 

below. 

Table 60 Transport cost savings for measure 2a6 

A comparison of the economic costs and benefits using the data from these tables indicates that for a 

majority of the waste streams, retaining all formerly exported EU wastes within the EU as a result of 

this measure results in economic costs outweighing the economic benefits. In order of highest cost, 

provisions concerning paper and cardboard, glass, textiles and ferrous metals all carry additional costs 

in comparison to the economic benefits for all scenarios, albeit the costs vary considerably. Using the 

potential years for measures to enter into force the costs for all wastes are shown in the table below. 

Negative values in the table indicate the additional costs incurred as a result of the measure. Positive 

values indicate the additional net economic benefits incurred. As can be seen in the table the economic 

value of retaining materials within the EU outweighs the costs of their management within the EU for 

all wastes modelled except for glass where the economic costs would outweigh the economic benefits. 

Table 61 Balance of costs and benefits for certain waste streams under 2a6 

The above tables use the Comext values for the value of the wastes exported. If the market value of 

the materials is applied, then the results change as indicated in the table below.  

Table 62 Balance of costs and benefits certain waste streams under 2a6 replacing Comext values of wastes with 
virgin and secondary market values 

The results of using market rates are that, in general, the results remain positive, except in relation to 

textiles that moves from a net positive to a net negative where the economic costs would outweigh the 

economic benefits derived. 

143 

EUR value of materials retained within the EU forecast for 100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal367,741,553379,721,770391,701,366403,680,963415,660,560427,640,156439,619,753451,599,349463,578,946475,558,543487,538,139499,517,736Glass8,472,6898,076,5548,371,4418,666,3298,961,2179,256,1049,550,9929,845,88010,140,76810,435,65510,730,54311,025,431Non-ferrous metals44,754,95845,589,22446,423,49047,257,75648,092,02148,926,28749,760,55350,594,81951,429,08552,263,35153,097,61753,931,883Paper and cardboard139,941,746148,681,207150,131,188151,581,169153,031,150154,481,131155,931,111157,381,092158,831,073160,281,054161,731,035163,181,016Plastic36,527,29437,362,30738,197,31939,032,33239,867,34440,702,35741,537,36942,372,38243,207,39444,042,40744,877,41945,712,432Textiles35,425,81036,769,76738,115,82839,461,89040,807,95142,154,01343,500,07444,846,13646,192,19847,538,25948,884,32150,230,382Total632,864,050656,200,827672,940,632689,680,438706,420,243723,160,048739,899,854756,639,659773,379,464790,119,269806,859,075823,598,880YearTransport savingsWaste type201920202021202220232024202520262027202820292030Ferrous metal2,209,073,5932,273,036,5542,337,002,4772,400,968,4002,464,934,3232,528,900,2462,592,866,1692,656,832,0922,720,798,0152,784,763,9382,848,729,8612,912,695,784Glass47,473,88142,105,26043,252,20644,399,15245,546,09846,693,04447,839,99048,986,93650,133,88251,280,82852,427,77453,574,720Non-ferrous metals4,071,972,2284,250,416,8304,428,861,4334,607,306,0354,785,750,6384,964,195,2405,142,639,8425,321,084,4455,499,529,0475,677,973,6505,856,418,2526,034,862,855Paper and cardboard663,761,222735,519,638763,510,352791,501,065819,491,778847,482,491875,473,204903,463,918931,454,631959,445,344987,436,0571,015,426,770Plastic226,499,258232,319,343238,139,428243,959,513249,779,598255,599,683261,419,767267,239,852273,059,937278,880,022284,700,107290,520,192Textiles163,734,496276,118,641289,321,243302,523,845315,726,448328,929,050342,131,652355,334,254368,536,856381,739,458394,942,060408,144,662Total7,382,514,6787,809,516,2678,100,087,1398,390,658,0108,681,228,8828,971,799,7549,262,370,6259,552,941,4979,843,512,36910,134,083,24010,424,654,11210,715,224,984YearBalance of costs and benefits100% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal388,733,466401,397,554414,060,986426,724,418439,387,850452,051,282464,714,714477,378,146490,041,578502,705,010515,368,442528,031,873Glass22,240,80821,200,95321,975,03322,749,11423,523,19424,297,27425,071,35525,845,43526,619,51527,393,59528,167,67628,941,756Non-ferrous metals5,380,851,2565,481,154,3595,581,457,4625,681,760,5655,782,063,6675,882,366,7705,982,669,8736,082,972,9756,183,276,0786,283,579,1816,383,882,2846,484,185,386Paper and cardboard728,863,263774,381,285781,933,269789,485,253797,037,237804,589,221812,141,205819,693,189827,245,174834,797,158842,349,142849,901,126Plastic981,823,2341,004,267,6731,026,712,1131,049,156,5521,071,600,9911,094,045,4311,116,489,8701,138,934,3091,161,378,7481,183,823,1881,206,267,6271,228,712,066Textiles-97,420,976-101,116,858-104,818,527-108,520,197-112,221,866-115,923,535-119,625,205-123,326,874-127,028,543-130,730,213-134,431,882-138,133,551Total7,405,091,0517,581,284,9677,721,320,3367,861,355,7058,001,391,0748,141,426,4438,281,461,8128,421,497,1818,561,532,5498,701,567,9188,841,603,2878,981,638,656YearBalance of costs and benefits 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Any diversion of EU wastes from third countries is likely to have an economic impact on the third 

countries themselves, primarily in relation to a reduction in feedstock to recycling activities. Given the 

EUR values of wastes that would be retained under the scenarios laid down it is apparent that the EUR 

economic impact to third countries in total is likely to be similar to the value of wastes no longer 

exported. So, for example, a diversion of ferrous metal exports in 2030 would reduce the economic 

income to third countries of approximately €5.2B per annum. Turkey, as the largest importer of ferrous 

metal waste at present, would be affected to the largest extent, India, Egypt, Pakistan, the UK, US, 

Switzerland, Norway Morocco and Bangladesh would also be affected.  

  Specific objective 2b – verify ESM in destination countries 

This specific objective is addressed through two sub-measures detailed in the table below.  

Table 63 Sub measures to address specific objective 2b  

Sub measure  

Short name  

2b1  

2b2  

Clarify the criteria which should be taken into consideration to assess if waste treated in 3rd 

countries are managed in an environmentally sound manner  

Creation of a dedicated body at the EU level with the task to monitor export of waste as well 

as their treatment in third countries  

By clarifying the criteria for consideration when assessing if waste treated in 3rd countries are managed 

in an environmentally sound manner, the key economic impacts will be on competent authorities and 

industry who will have to ensure equivalence for third-country treatment. This might also reduce the 

volume of waste exported to third countries, where this equivalence cannot be demonstrated.  

This sub measure is dependent on access to sites to perform the assessment on 

ESM practices, stakeholders noted this as a particularly challenging facet. Experience from the ship 

recycling regulation shows that checking facilities outside of the EU has a large time and cost burden.  

The creation of a dedicated EU body will help distribute these costs to the European Commission. A 

study on the feasibility of the establishment of a Waste Implementation Agency found that an agency 

would require a total annual cost of €16 million, 61 members of staff and an additional start-up cost of 

€1.6 million in the first two years46. The responsibility of this agency would have been to carry out 

several enforcement tasks, such as reviews of Member States' enforcement systems, inspection 

activities and training of Member States through programmes and guidance. Moreover, third countries 

were out of scope of the proposal for a Waste Implementation Agency, consequently the cost data is 

not directly comparable to the development of the EU body within this measure.  

There are currently 34 similar decentralised agencies47 and Table 3.1 presents the expenditure of the 

three comparable bodies taken from the most recent annual financial reports.  

There is potential to explore if the tasks in question could be allocated to an existing body and in the 

context of the WSR, such as the European Border and Coast Guard Agency (Frontex) due to its links to 

customs and harmonised border controls. The expenditure of the body is also presented in the table 

below.  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 64 Details on the expenditure of three decentralised bodies with figures taken from the latest financial 
reports.  

Decentralised agency  

Number of staff 

Expenses (EUR ‘000)  

European Fisheries Control Agency 

(EFCA)48  

European Border and Coast Guard Agency 

(FRONTEX)49  

Staff – 8,120  

63 

Administrative – 1,634  

Other – 6,993  

Staff – 47,655  

315 

Administrative – 26,592  

Operational – 236,610  

Staff – 44,180  

European Food Safety Authority (EFSA)50  

435 

Administrative – 8,220  

European Maritime Safety Agency 

(EMSA)51  

Operational – 20,650  

Staff – 22,902  

250 

Administrative – 16,319  

Operational – 57,308  

By ensuring the environmentally sound management of waste in third countries the measure has 

potential to reduce environmental impacts of waste shipment. The extent of the impact is dependent 

on the volumes of waste concerned.  

During the workshop, stakeholders were presented the two sub-measures and attendees showed they 

were mostly in favour of adding provisions referring to conditions set out in Article 13 of the Waste 

Framework Directive. In addition, stakeholders appeared to support the development of a dedicated EU 

body.  

For Member States, the principle of subsidiarity needs to be considered in the establishment of a 

dedicated EU body. The new body should not take away powers from Member States when they are 

responsible for monitoring their exports and ensuring the treatment of their wastes by third countries is 

environmentally sound. The decision on a dedicated body at EU level needs to define what provisions 

are necessary first, then ask who best placed to take on those responsibilities. Following this, it will be 

possible to determine if a dedicated EU body can help verify ESM of waste treatment in third countries. 

For instance, Producer Responsibility Organisations (PRO) and Extended Producer Responsibility (EPR) in 

Germany’s packaging law requires manufactures of packaging to check facilities outside the EU to 

ensure packaging recycling rates are achieved. 

  Specific objective 3a – Further strengthen provisions on enforcement and inspections  

To improve enforcement and inspection of waste shipment across the EU, this specific objective  

encompasses two possible measures. 

Firstly, a strengthening of the WSR provisions in Article 50, with the aim to facilitate inspections, 

increase efficiency of enforcement operations and provide for deterrent sanctions would look to make 

better use of reports already drawn up by Member States. Article 50 could include a requirement that 

the inspections plans drawn up are made available to the Commission. This would have limited 

economic cost given that the publication of parts of these reports is already required. The main 

difference from the status quo for Member States is in relation to the additional costs of placing a 

document online, the costs of which are considered to be minor, encompassing a maximum of 8 hours 

145 

  
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

work per annum Member State in order to ensure that any confidential information is protected and 

remains confidential.  

Furthermore, requiring that the Commission produce regular reports to the attention of the Member 

States to help steering enforcement activities, notably through a description of the main features and 

recent trends in illegal waste shipment activities would predominantly carry a cost for the Commission. 

The extent to which the Commission reports would be informed through data collection from Member 

States to be shared with others could lead to additional burden being placed on Member States 

services. However, the information on trends in illegal waste shipment activities are already addressed 

through existing mechanisms like IMPEL and Interpol. the latter maintains a database of known 

criminals involved in illegal environmental activities, as well as issuing report alerts – a good example of 

which is the Interpol alert in relation to waste plastic crime released in August 202091. 

Secondly, the creation of a dedicated body/forum at the EU level would aim to monitor and improve 

cooperation between EU Member States on waste shipment enforcement, by sharing best practices, 

intelligence, and activities ongoing.  

During the stakeholder consultation, Member State representatives noted that IMPEL currently provides 

many tools to help inspection and enforcement for practitioners. There is a risk of overlap between the 

proposed EU forum and the tools provided by IMPEL. In particular, the Guidance on Effective Waste 

Shipment Inspection Planning provides essential tools and best practices for authorities to develop a 

complete inspection plan. The status of this guidance document is however informal, and not mandated 

by the Regulation itself. 

The direct administrative costs of creating a dedicated body would include the total staff, overhead 

and external costs to manage and administer it, in order to fulfil the monitoring and cooperation tasks. 

The administrative costs can be looked at from the FTE perspective, given the high variation of staff 

costs within an EU body depending on location. Using a recent assessment calculating the 

administrative costs of the European Structural and Investment Funds – relevant because involved in the 

environmental protection and in the cooperation among members – it is possible to estimate the 

administrative costs of a dedicated body. Considering the relevant functions like programme 

preparation, managing authorities, certifying authorities, the total costs are 0.89 FTE, of which 0.012 

FTE per million euro (median value) are dedicated to monitoring, reporting and evaluation, an 

important task of this specific objective. It could be noted the tasks under this objective might 

potentially benefit from economies of scale since some of the administrative costs could be spread over 

a larger total budget. Furthermore, the specific body considered under specific objective 2b could 

include aspects of this specific objective within its remit.  

Were the dedicated body be set more up as an advisory forum, similar in nature to the Forum for 

Exchange of Information on Enforcement (Enforcement Forum) organised by the European Chemicals 

Agency (ECHA)92 the costs of operation of the expert group are likely to be around €50 000 per meeting 

met by attendees incorporating both staff at €500 per day and travel costs for attendance. The 

Enforcement Forum meets three times per year – should the new advisory forum on waste shipments 

91 INTERPOL (2020) www.interpol.int/content/download/15587/file/INTERPOL%20Report%20_criminal%20trends-
plastic%20waste.pdf  
92 https://echa.europa.eu/about-us/who-we-are/enforcement-forum  

146 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

meet on the same frequency the annual costs for Member States would be €150 000 per annum. The 

impacts of Covid-19 have indicated that the need for physical meetings may be less and that the Forum 

could meet virtually for some or all of these meetings. The reduced cost of a virtual meeting compared 

to an in-person meeting is approximately €13 500 per meeting, composed of the travel costs saved. 

Additionally, Commission resources would be required to service the new advisory forum. It is 

estimated that the management of the Forum would require 0.15FTE in Commission staff resources per 

annum. 

  Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and 

national levels and strengthen cooperation across the EU and with international partners  

The first measure looks to improve enforcement and inspections across the EU by providing EU  

guidance on sanctions and penalties, intelligence led inspection activities, prioritising action to address 

illegal waste shipments, and efficient use of staff to maximise impact on illegal activities.  

The second measure aims to enhance cooperation with inspection and enforcement bodies beyond the 

EUs borders by working closer with greater advocacy at a global level and financial support for 

bilateral, regional, and global projects.  

During the stakeholder consultation, a Member State representative indicated that IMPEL already 

produced guidance on the topics under considerations. In particular, the Step-by-step guidance book for 

waste shipment inspections provides detailed indications on how Member states should conform to the 

enforcement and inspection rules set out in the WSR. In addition, the E-waste inspection and 

enforcement manual offers practical guidance for transboundary movements of electronic waste. 

Chapter 4 provides a strategy for a successful inspection and investigation of the waste, considering 

both the administrative and physical aspects.  

The Basel Convention has also developed and adopted technical guidance to provide States with 

guidance for their waste management strategies and obligations93. Of particular relevance for this 

measure, guidance documents have been issued under the Basel Convention with a view to achieving 

the objectives of preventing and combating illegal traffic of waste94. Taking into account such technical 

guidelines, the European Commission has developed additional correspondence guidelines, though not 

legally binding.  

Good quality guidance documents can help competent authorities improve practices and address issues 

of governance. To produce the guidance document the Commission will need to gather information on 

practical inspection and enforcement issues to identify best practice. This information will need to be 

disseminated to the key destination regions for waste from the EU and be produced in the native 

language.  

93 Guidance on the implementation of the Basel Convention provisions dealing with illegal traffic (paragraphs 2, 3 
and 4 of Article; Guidance Elements for Detection, Prevention and Control of Illegal Traffic in Hazardous Waste; 
Instruction manual on the prosecution of illegal traffic of hazardous wastes or other wastes; and Basel Convention 
Training Manual on Illegal Traffic for Customs and Enforcement Agencies 9.  
94 
http://www.basel.int/Implementation/TechnicalMatters/DevelopmentofTechnicalGuidelines/TechnicalGuidelines/t
abid/8025/Default.aspx#:~:text=Basel%20Convention%20Technical%20Guidelines%20(Framework%20documents)&text
=The%20Technical%20Guidelines%20are%20principally,waste%20management%20plans%20or%20strategies 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

The economic impact of producing additional guidance will therefore be measured considering how 

much of the existing guidance, mentioned in the previous subsection, could be used to address the 

requirements of this specific objective. This is done in terms of administrative costs, which include the 

cost of travel and the cost of the staff, as well as considering the amount of time necessary to produce 

such guidance and to perceive the desired outcome.  

Such inputs have been calculated in a comparative framework considering the Terms of Reference 

(ToR) of the Enforcement Actions project set up by IMPEL with the similar objectives of minimising 

illegal shipments and promote cooperation among Member States. This four-years project led to two 

project reports covering the results of inspections on waste shipment and a report on the final waste 

and shipment conference.  

The costs to create the additional guidance would include the travel and event costs, i.e. the cost of 

holding the meetings and developing the guidance. Additional to this, the cost of the staff necessary to 

draft the reports would need to be added. Taking into account the ToRs used by IMPEL in the 

development of their own Guidance on Effective Waste Shipment Inspection Planning, the total cost of 

all meeting events for detailed guidance on the topics laid down under this measure would be 

approximately €135 000 with about 50 individuals making input.  

The staff time involved in developing the guidance is also likely to be considerable. Even considering a 

minor input per Member State of ten days per year this would mean total EU competent authority staff 

costs of €135 000 per annum. The time taken for IMPEL to develop its guidance was four years and with 

this type of timescale considered this would lead to a total cost of approximately €675 000 for the 

guidance to be developed. Commission staff resources would also be required to develop such 

guidance. 

The impact of guidance and reporting will not be seen immediately. Real tangible benefits will be met 

in a 4-years period – following the example just presented – and this might not be ideal if the 

Commission wants to promptly address the issues of inspection and enforcement. A further cost to be 

considered is the direct cost necessary to apply the guidance. A more sensible approach would probably 

be to make already existing inspection and enforcement mechanisms more visible and available to 

executives, for example through a detailed website, that would obtain the same benefits and 

objectives desired but at a modest cost.  

Concerning the enhancement of cooperation with inspection and enforcement bodies beyond the EUs 

borders, the EU and a number of Member States provide regular funding to promote implementation of 

ESM of waste in third countries, and address the fight against waste trafficking, notably through the 

Basel Convention, IMPEL and other organisations and initiatives. By way of example, the Basel 

Convention has a Trust Fund established to support developing countries and other countries in need of 

technical assistance in the implementation of the Convention. For 2020, the European Union and its 

Member States pledged contributions totalling over US$1.5M, with the EU contributing just under 8% of 

that total with a number of Member States being larger contributors individually including Germany 

(23.5%), France (17%), Italy (12.75%) and Spain (8.25%)95. Comparing the total EU share of the Trust 

95 
http://www.basel.int/TheConvention/FinanceBudget/TrustFund(BC)/ContributionsStatus/2020/tabid/8379/Default.
aspx  

148 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Fund, the EU contributed a little of 32% of the total trust fund pledges for 2020 (the total being 

US$4.847M). Additional financial support will have an impact on the EU and Member States budgets. 

Furthermore, as noted in the public consultation by a number of stakeholders, the EU plays an active 

role at the international level in the development of guidance and sharing of best practice. 

IMPEL has strong collaboration with countries in Africa and Asia with whom they have regular 

interactions. These interactions, however, are on an informal basis and IMPEL lacks an official mandate 

or strategy, but still these contacts could be used to enhance cooperation. According to the consulted 

stakeholders, such cooperation should be done at the EU level and cannot be done individually by 

Member States.  

The cooperation among Parties to the Basel Convention, including EU Member States, is also guaranteed 

by the Environmental Network for Optimizing Regulatory Compliance on Illegal Traffic (ENFORCE). 

Established by the Basel convention, it has the objective to increase compliance with the provisions of 

the convention and prevent illegal traffic, by enhancing international cooperation and coordination, as 

well as relying on capacity-building. There are indeed organisations able to provide support through 

workshop and training, with the ultimate goal to share best practices and existing tools already 

implemented at the national level on how to increase and develop inspection programs. Support can be 

provided in different instances also depending on the available funding and additional organisations, 

where examples could be facilitating information sharing, providing libraries of capacity building 

resources, or online collaboration tools. The IMPEL capacity building and training project is a good 

example of how to develop and tailor such strategy to reach the desired outcome under the specific 

umbrella issue of Waste Shipment.  

The Technical Assistance and Information Exchange instrument of the European Commission (TAIEX) 

also presently provides support to the public administrations in the enforcement of EU legislation as 

well as facilitating the sharing of EU best practices. For waste management, support is provided via the  

Environment and Climate Regional Accession Network (ECRAN), which strengthens regional cooperation 

between the EU candidate countries and potential candidates.  

Given the above funding mechanisms and international action to address illegal waste shipment, the 

most sensible course of action would be to ensure that those actions are provided with sufficient 

funding to operate and sufficient technical support from the EU in addressing capacity building to 

tackle illegal waste shipments. This could include: 

• 

• 

an increase in direct funding from the EU,  

a change to the pledge system within the EU tying Member State contributions to a particular 

percentage of the EU total based on the GDP of each Member State; or  

• 

retain the existing voluntary agreement system with direct encouragement of Member States 

to make larger pledges.  

Given the uncertainties in any final value that could be added to this action economically no value has 

been added in this analysis. 

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8.3  Social impacts of measures 

  Specific objective 1a – Align shipments with the waste hierarchy 

The data collected did not provide any impacts in relation to social impacts, including in relation to 

employment. More detailed data would be required to better understand how this measure would 

ensure the creation of new waste treatment facilities. If new facilities were created, it would increase 

demand for new jobs in these facilities, albeit it is likely that such facilities would be developed at the 

expense of other facilities.  

There is literature which outlines the higher labour intensity of recovery processes over that of 

landfilling or incineration. The US Environmental Protection Agency (EPA) estimated that 10 000 tonnes 

of waste equated to 1 job in a landfilling site, or 36 in a recycling facility.96 In Australia it was shown 

that per 10 000 tonnes of waste generate 2.8 direct Full Time Equivalent (FTE) via landfilling, with 9.2 

FTEs from recycling.97 When viewing Eurostat Structural Business Statistics (SBS) in conjunction with 

Eurostat waste treatment data a different trend is observable. In 2018, the EU average FTE per 10 000 

tonnes of waste for treatment and disposal was 3.9 for non-hazardous waste, and 76.9 for hazardous 

waste; while for recovery of sorted materials it was only 2.6. It is likely that the two data sets are not 

well matched, as the NACE classification used by the data combines waste treatment and disposal, 

likely overexaggerating the number of jobs in disposal. Therefore a transition from landfilling activities 

to recovery processes would be likely to result in higher overall FTE in the waste management sector 

across the EU. 

In addition, recovery operations require higher capacities of intensive collection and sorting, which in 

turn require greater numbers of labour intensity. An example of this can be seen in the table below, 

which highlights the jobs gained via the additional labour required for material recovery collection and 

sorting. However, additionally to higher employment figures and more complex sorting and collection 

would be an associated higher economic impact. 

Table 65 – Jobs gained from specific material recycling activities in the UK 

Materials for collection and sorting 

Jobs gain / 10 000 tonnes of waste 

Plastics 

Paper 

Glass (mixed) 

Glass (separated) 

Green waste 

WEEE 

Aluminium 

Steel 

Source: EPRS (2017)98 

156 

26 

3.3 

6 

5 

400 

110 

54 

Therefore if this measure increased the creation of new waste treatment facilities in line with the 

waste hierarchy, there could be a foreseeable increase in job creation as a result of the job intensity of 

both the necessary waste recovery facilities and collection and sorting processes. 

96 Trinomics et al. (2018) https://ec.europa.eu/environment/enveco/circular_economy/pdf/studies/Annexes.pdf  
97 Access Economics (2009) https://www.environment.gov.au/system/files/resources/5cc6a848-a93e-4b3f-abf7-
fc8891d21405/files/waste-and-recycling-employment.pdf  
98 EPRS (2017) 
https://www.europarl.europa.eu/RegData/etudes/STUD/2017/581913/EPRS_STU(2017)581913_EN.pdf  

150 

 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

  Specific objective 1b Simplification and reduction of administrative burden for intra-EU 

shipments of waste 

During the workshop, one Member States’ Competent Authority representative pointed out that their 

workload is increasing while their staff level is decreasing. There was a similar understanding among 

different stakeholders interviewed during the initial targeted interviews.  

As such, introduction of the electronic data interchange could have an impact on employment levels for 

staff at Competent Authorities. The impacts could be positive as well as negative. With regards to 

understaffed Competent Authorities, their staff could be less overloaded given that introduction of the 

EDI would, on annual basis, save 35% of their time (as addressed above in section 8.2.2 on economic 

impacts).  

  Specific objective 1c Harmonisation of interpretation, application and enforcement across 

Member States 

Data collected did not provide any social impacts related to this measure.  

  Specific objective 1d – Better adapt to technical progress and stimulation of innovation  

Data collected did not provide any social impacts related to this measure 

  Specific objective 2a – stop or restrict export of waste outside of the EU 

There are two large social impacts stemming from four of the five measures foreseen under specific 

objective 2a, (noting that measures 2a1 is expected to have little additional social impact in 

comparison to the status quo): 

• 

those related to employment within the EU as a result of wastes formerly exported to third 

countries being retained within the EU. 

• 

Those related to the social impacts, including both employment and impacts on standards of 

living for people living in the third countries to which EU waste is presently shipped. 

These impacts for measures 2a2, 2a3, 2a4 and 2a5 are described below. 

Measures 2a2: Ban export of all waste outside the OECD, except for third countries which notify 

the EU of their willingness and readiness to import such waste and 2a3: Require that the export of 

green-listed waste outside the OECD is subject to the “prior written notification and consent” (PIC) 

procedure where it is allowed have been considered together as their impacts on EU employment 

impacts within the EU are broadly similar and are heavily influenced by the quantities of waste that 

would be retained within the EU as a result of those measure. In keeping with the assessment of the EU 

retaining 75%, 50% and 20% of the wastes formerly exported to non-OECD third countries the 

employment impacts have been calculated using the same thresholds, the results of which are shown in 

the table below. 

151 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 66 FTE created within the EU under measures 2a2 and 2a3 based on different levels of EU waste 
retention that was formerly exported to non-OECD third countries  

Additionally, under measure 2a3 the application of PIC would require staff resource for relevant 

documentation to be completed. The calculation of the FTE generated by such PIC documentation 

completion is shown below. 

152 

Waste type201920202021202220232024202520262027202820292030Ferrous metal14,75211,55313,00610,84011,25012,76310,32810,70612,2789,5759,92011,551Glass60524946413732272216103Non-ferrous metals9,7719,5509,0798,5848,0677,5266,9616,3745,7635,1294,4723,792Paper and cardboard7,6658,0928,1198,1458,1708,1948,2178,2398,2608,2808,2998,317Plastic8,2028,2508,2928,3288,3578,3808,3978,4088,4138,4118,4048,390Textiles5,8356,0816,3296,5796,8317,0847,3397,5967,8558,1158,3778,642Total46,28443,57944,87442,52242,71643,98341,27541,35042,59039,52639,48140,693Waste type201920202021202220232024202520262027202820292030Ferrous metal9,8347,7028,6717,2277,5008,5086,8867,1378,1856,3836,6137,701Glass4035333028252218141162Non-ferrous metals6,5146,3676,0535,7235,3785,0174,6414,2493,8423,4192,9812,528Paper and cardboard5,1105,3955,4135,4305,4475,4635,4785,4935,5075,5205,5335,544Plastic5,4685,5005,5285,5525,5715,5875,5985,6065,6095,6085,6025,593Textiles3,8904,0544,2194,3864,5544,7234,8935,0645,2365,4105,5855,761Total30,85629,05329,91628,34828,47729,32227,51727,56628,39326,35126,32127,129Waste type201920202021202220232024202520262027202820292030Ferrous metal3,9343,0813,4682,8913,0003,4032,7542,8553,2742,5532,6453,080Glass161413121110976431Non-ferrous metals2,6062,5472,4212,2892,1512,0071,8561,7001,5371,3681,1931,011Paper and cardboard2,0442,1582,1652,1722,1792,1852,1912,1972,2032,2082,2132,218Plastic2,1872,2002,2112,2212,2292,2352,2392,2422,2432,2432,2412,237Textiles1,5561,6221,6881,7541,8211,8891,9572,0262,0952,1642,2342,304Total12,34211,62111,96611,33911,39111,72911,00711,02711,35710,54010,52810,852FTEs created within the EU forecast for 75% retained within EUYearYearYearFTEs created within the EU forecast for 20% retained within EUFTEs created within the EU forecast for 50% retained within EU 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 67 FTE generated by the application of PIC to all shipments to non-OECD third countries 

153 

Total number of FTEs to process paper based PICs based on 20t shipmentsWaste type201920202021202220232024202520262027202820292030Waste type201920202021202220232024202520262027202820292030Ferrous metal745865545664525361484958Ferrous metal493843363742343541323338Glass111111110000Glass111111000000Non-ferrous metals22222120181716151312109Non-ferrous metals15141413121111109876Paper and cardboard879192929292939393939494Paper and cardboard576061616161616262626262Plastic191919191919191919191919Plastic131313131313131313131313Textiles252627282930313234353637Textiles171718191920212122232424Total228217224214216224212213221207209217Total151144149142143148140141146137138143Total number of PICs based on 100t shipmentsWaste type201920202021202220232024202520262027202820292030Waste type201920202021202220232024202520262027202820292030Ferrous metal151213111113101112101012Ferrous metal1089778778678Glass000000000000Glass000000000000Non-ferrous metals444443333222Non-ferrous metals333322222211Paper and cardboard171818181818191919191919Paper and cardboard111212121212121212121212Plastic444444444444Plastic333333333333Textiles555666667777Textiles334444444555Total464345434345424344414243Total302930282930282829272829YearTotal number of FTEs to process electronic PICs based on 20t shipmentsPIC electronic EUR cost based on 100 tonne shipments EU forecastYearYearYear 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The impacts on third country employment in the countries that presently receive EU wastes under 

measures 2a2 and 2a3 is likely to be much higher in FTE terms than the benefits shown above for the EU 

as a result of the more efficient waste management and more automated systems employed in the EU 

in comparison to a majority of the third countries to which waste is exported. 

Furthermore, the social impacts in terms of living conditions impacted by EU wastes in third countries 

would be reduced under these measures. By way of example, the Greenpeace report ‘The Recycling 

Myth 2.0 – the toxic after effects of imported plastic waste in Malaysia99’ noted that visits to one 

dumpsite contained large amounts of plastic waste piles from numerous countries including waste from  

Germany, Spain and Scandinavia with an examination of the waste revealing mainly non-recyclable 

plastic, in addition to other scraps including e-waste (e.g. plastic cases or circuit boards from 

electronic devices). Signs of open burning indicated attempts to dispose of evidence of the type of 

wastes discarded at the dumpsite by burning them. A restriction of wastes sent to such third countries 

would undoubtedly reduce the volumes of materials dumped and open-burned in such a manner, having 

a positive impact on the social wellbeing on people in proximity to such waste sites as well as in 

relation to the health and safety of those currently involved in such waste management activities. 

Measure 2a4: Restrict exports to OECD countries - In keeping with the assessment of the EU retaining 

75%, 50% and 20% of the wastes formerly exported to OECD countries the employment impacts of 2a4 

have been calculated using the same thresholds, the results of which are shown in the table below. 

99 Greenpeace (2020) https://www.greenpeace.org/static/planet4-southeastasia-stateless/2020/06/4dbab0db-the-
recycling-myth-2.0-the-toxic-after-effects-of-imported-plastic-waste-in-malaysia.pdf  

154 

 
 
 
 
 
 
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Table 68 FTE created within the EU under measure 2a4 based on different levels of EU waste retention that was 
formerly exported to OECD countries  

Additionally, under measure 2a4 the application of PIC would require staff resource for relevant 

documentation to be completed. The calculation of the FTE generated by such PIC documentation 

completion is shown in the next table. 

155 

FTEs created within the EU forecast for 75% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal43,09148,17448,60552,65554,13054,50258,82060,32760,64065,22766,76667,019Glass261254268283298314330346363380397415Non-ferrous metals5,6146,1216,8797,6608,4659,29310,14411,01811,91612,83613,78014,747Paper and cardboard2,0662,2462,3202,3952,4712,5472,6252,7042,7842,8652,9473,029Plastic4,2124,4484,6894,9375,1925,4525,7195,9926,2716,5566,8487,146Textiles669669669666662655647638626613597580Total55,91261,91163,43068,59771,21772,76378,28581,02582,59888,47691,33592,937FTEs created within the EU forecast for 50% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal28,72732,11632,40435,10436,08636,33439,21340,21840,42643,48444,51144,679Glass174169179189199209220231242253265277Non-ferrous metals3,7424,0814,5865,1075,6436,1956,7637,3457,9448,5589,1879,832Paper and cardboard1,3771,4971,5471,5971,6471,6981,7501,8031,8561,9101,9642,020Plastic2,8082,9653,1263,2923,4613,6353,8133,9944,1814,3714,5654,764Textiles446446446444441437432425417408398387Total37,27541,27442,28745,73147,47848,50952,19054,01655,06658,98460,89061,958FTEs created within the EU forecast for 20% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal11,49112,84612,96114,04114,43514,53415,68516,08716,17117,39417,80417,872Glass706871757984889297101106111Non-ferrous metals1,4971,6321,8342,0432,2572,4782,7052,9383,1783,4233,6753,933Paper and cardboard551599619639659679700721742764786808Plastic1,1231,1861,2501,3171,3841,4541,5251,5981,6721,7481,8261,905Textiles178179178178176175173170167163159155Total14,91016,51016,91518,29218,99119,40320,87621,60722,02623,59424,35624,783YearYearYear 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 69 FTE generated by the application of PIC to all shipments to OECD countries  

156 

Total number of FTEs to process paper based PICs based on 20t shipmentsWaste type202220232024202520262027202820292030Waste type202220232024202520262027202820292030Ferrous metal263270272293301303325333334Ferrous metal174179180194199200215220221Glass666778889Glass444555556Non-ferrous metals171921232527293134Non-ferrous metals121314151718192122Paper and cardboard272829303131323334Paper and cardboard181819202021212223Plastic111213131414151616Plastic8889910101011Textiles333333332Textiles222222222Total327338344369380386413424430Total217224227244252255273281284Total number of PICs based on 100t shipmentsWaste type202220232024202520262027202820292030Waste type202220232024202520262027202820292030Ferrous metal535454596061656767Ferrous metal353636394040434444Glass111112222Glass111111111Non-ferrous metals344555667Non-ferrous metals233334444Paper and cardboard566666677Paper and cardboard444444445Plastic223333333Plastic222222222Textiles111111110Textiles000000000Total656869747677838586Total434545495051555657Total number of FTEs to process electronic PICs based on 20t shipmentsYearYearPIC electronic EUR cost based on 100 tonne shipments EU forecastYearYear 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The social impacts in OECD countries to which EU waste would no longer be exported is likely to be 

primarily in relation to employment, with the FTE numbers shown in Error! Reference source not 

found. for additional FTEs in the EU likely to be broadly similar to the number of employees displaced 

in affected OECD countries as a result of the more broadly equivalent management of waste in OECD 

countries with the EU than for other third countries. 

Measure 2a5 – Ban all exports of waste to non-OECD third countries – would have the second largest 

social impacts of the measures considered under this specific objective. The impacts on employment 

within the EU as a result of the retention of EU wastes formerly exported to non-OECD third countries is 

shown in the table below. 

Table 70 FTEs generated within the EU resulting from the management of wastes formerly exported to non-
OECD third countries as considered under 2a5 

For non-OECD third countries, displacement of employment that is currently linked to the management 

of EU wastes would take place and for a large number of countries involved in generally lower 

standards of waste management than the EU a reduction in the social impacts of poorly managed EU 

wastes in communities in proximity to poorer quality waste management facilities would be expected. 

Measure 2a6 – Ban all exports of waste – would have the largest social impacts of the measures 

considered under this specific objective. The impacts on employment within the EU as a result of the 

retention of EU wastes formerly exported to all third countries is shown in the table below. 

Table 71 FTEs generated within the EU resulting from the management of wastes formerly exported to third 
countries as considered under 2a6 

The social impacts on third countries resulting from these changes are considered to be a mix of those 

identified under measures 2a2, 2a3, 2a4 and 2a5. This would be, for all countries, displacement of 

employment that is currently linked to the management of EU wastes and for a large number of 

countries involved in generally lower standards of waste management than the EU a reduction in the 

social impacts of poorly managed EU wastes in communities in proximity to poorer quality waste 

management facilities. 

157 

Waste type201920202021202220232024202520262027202820292030Ferrous metal19,66915,40417,34114,45415,00017,01713,77114,27416,37012,76613,22615,401Glass81706661554943362921134Non-ferrous metals13,02812,73412,10511,44610,75510,0349,2828,4987,6846,8395,9635,056Paper and cardboard10,21910,78910,82510,86010,89310,92510,95610,98511,01311,04011,06511,089Plastic10,93511,00011,05611,10311,14311,17411,19711,21111,21711,21511,20511,186Textiles7,7818,1088,4398,7729,1079,4459,78510,12810,47310,82011,17011,522Total61,71258,10559,83256,69556,95458,64455,03455,13356,78652,70152,64154,258FTEs created within the EU forecast for 100% of wastes foremerly exported to non-OECD countries retained within EUYearWaste type201920202021202220232024202520262027202820292030Ferrous metal77,12479,63682,14884,66187,17389,68692,19894,71097,22399,735102,248104,760Glass428408423438453468483497512527542557Non-ferrous metals20,51320,89521,27721,66022,04222,42522,80723,18923,57223,95424,33624,719Paper and cardboard12,97413,78413,91814,05314,18714,32214,45614,59114,72514,85914,99415,128Plastic16,55116,93017,30817,68718,06518,44318,82219,20019,57819,95720,33520,713Textiles8,6729,0019,3309,6609,98910,31910,64810,97811,30711,63711,96612,296Total136,261140,654144,406148,158151,910155,662159,414163,166166,918170,670174,421178,173YearFTEs created within the EU under 2a6 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

  Specific objective 2b – verify ESM in destination countries 

By ensuring the environmentally sound management of waste in third countries the measure has 

potential to reduce socially abhorrent waste treatment behaviours in third countries. This issue is 

addressed in more detail under Specific objective 2a above. The extent of the impact is dependent on 

the volumes of waste concerned.  

A 2015 study by the International Labour Organization (ILO)100 found that in relation to e-waste 

management in China: 

• 

There was an urgent need for competent, knowledge and training in human health and 

environmental risk control and management in the industry in China. Despite the large number 

of people working in the sector, the majority of workers and employers are unaware or unclear 

about the severity of risks to which they are exposed. 

• 

The industry was urged to strengthen occupation safety and health in order to ensure these 

rights. 

A similar ILO study from 2019101 undertaken in relation to e-waste in India reaches similar conclusions. 

  Specific objective 3a – Further strengthen provisions on enforcement and inspections  

Enhancing and strengthening enforcement will in first instance likely see an increase in inspection 

conducted by competent authorities, this is likely to see an increase in the cases of illegal shipments 

prosecuted and brought to court.  

Improved and more enforcement and prosecution activities are likely to lead to the dismantling of 

illegal shipment operations and corresponding networks, which build on the informal illegal economy 

and black markets. This should therefore reduce frauds and other illegal activities such as illegal 

employment. This will require greater deployment of staff in competent authorities and an increase in 

employment can be expected. 

  Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and 

national levels and strengthen cooperation across the EU and with international partners  

The social impact of developing the EU guidance would most likely not be very high in terms of new 

employment. Instead, a more efficient deployment of staff would be expected.  

At the international level, greater cooperation could be funded by greater staff time from Member 

States, which could increase employment. The social impact can be observed by the trade-off between 

the time spent in bilateral cooperation activities, for example in training and workshops, and the 

efficiency gains from participating. Similarly, sharing best practices would need a time allocation from 

involved staff but would produce a net positive outcome. The staff members and inspectors would 

benefit from a human capital perspective, by gaining in particular in terms of efficiency of their 

operating mandate, having a better understanding of the current waste crime trends and learning how 

to integrate best detection, investigation and prosecution methods and tools into their operations.  

100 International Labour Organization (2013) http://apgreenjobs.ilo.org/resources/the-labour-human-health-and-
environmental-dimensions-of-e-waste-management-in-china/at_download/file1  
101 International Labour Organization (2019) https://www.ilo.org/wcmsp5/groups/public/---ed_dialogue/---
sector/documents/publication/wcms_732426.pdf  

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Both measures would lead to a decrease in illegal activity, which would imply more legal employment 

in legal businesses and an efficient allocation of staff members. 

8.4  Environmental impacts of measures 

  Specific objective 1a – Align shipments with the waste hierarchy  

In regard to a ‘lighter touch’ approach on waste for reuse and recovery (recycling), it is important 

to review how much waste will be affected by the narrowing of restrictions in Article 12 (which current 

allows objections to waste shipments intended for recovery). To do this it is important to assess how 

many objections are currently made for recovery shipments, in line with Article 12. This can be found 

in the implementation report on the WSR, published in 2018102, which shows figures from Member 

States who filled in the table in Annex IX of the WSR on shipments of waste for recovery which are 

objected to. Four Member States filled in the table, including Belgium, Finland, Lithuania and Spain, for 

the years 2013, 2014 and 2015. The data highlighted that a total of 16 objections were made by 

competent authorities. Seven of these were in some regard connected to R1 recovery, with the rest 

being linked to either R4 or R5 recovery.103 For the latter, this amounted to 12 545 tonnes of waste for 

recovery practices objected to in 2015 alone. This can then be compared with total non-R1 recovery 

data from Eurostat, which shows 2 701 699 tonnes of wastes shipped intra-EU in 2015. Therefore, 

Member State objections to waste for recovery accounted for 0.5% of total EU-wide recovery 

shipments. This can be seen as an insignificant proportion of total EU waste shipments, and as such a 

minor environmental impact.  

With regard to a stricter control on shipments of waste for energy recovery, the previously used 

data on net-export (see Error! Reference source not found.) highlights possible dependencies of 

certain countries on waste imports, to utilise their waste treatment facilities efficiently. For Slovakia, 

Sweden and the Netherlands, this was noted for waste for energy recovery imports. Economically, a 

stricter import of such wastes could negatively impact facilities in such countries. They would be forced 

to move away from technologies such as waste for energy recovery, as the facilities could no longer 

import waste to meet their operational needs. Environmentally it could be assumed that this could lead 

to lower levels of emissions with reduced levels of waste for energy recovery. The negative impact of 

these stricter provisions could be realised in the largely exporting countries of waste for energy 

recovery, who would either need to build new recovery infrastructure to deal with this waste or use it 

domestically for disposal practices (most likely incineration, owing to the strict 2030 landfilling 

targets104). This could include countries like Italy, Belgium, and Germany.  

With regard to stricter controls on landfilling, the previously used net-export data for disposal (Error! 

Reference source not found.) can highlight countries that would decrease their landfilling quantities 

owing to reduced imports of waste for landfilling. Portugal, France and Germany would see decreased 

imports of waste for landfilling following stricter provisions. This would likely have a positive 

environmental impact in these countries. However countries such as Italy and Luxembourg, which have 

extremely high net-exports of waste for landfilling, would be required to recover or dispose of this 

waste domestically, likely leading to negative environmental impacts (assuming the waste was disposed 

102 SWD (2018) 468 final PART 2 https://eur-lex.europa.eu/resource.html?uri=cellar:44a84bd6-ee4e-11e8-b690-
01aa75ed71a1.0001.02/DOC_2&format=PDF  
103 Two of these objections were related to the shipments for recovery of materials with a lower quality than is 
recommended by destination countries. 
104 The gradual limitation of landfilling of municipal waste to 10% by 2030. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

domestically in landfills). However, without key data on waste treatment facilities standards and 

emissions, it is not possible to draw quantitative conclusions on the environmental impacts. 

  Specific objective 1b - Simplification and reduction of administrative burden for intra-EU 

shipments of waste 

Stakeholders responding to the open public consultation agreed that no negative impacts on the 

environment should arise as a result of the introduction of the EDI. Instead, it could create 

transparency and increase the efficiency of implementing the WSR’s obligations (both of which were 

also generally supported during the workshop) and help to create/improve a single market for 

secondary raw materials. It could also lead to savings of paper, when the remaining Member States 

relying on paper-based system step over to electronic system. Lastly, introduction of the EDI could 

positively contribute to the implementation of EMAS (Eco-Management Audit Scheme). However, no 

qualitative data were provided or identified to support these expectations of impacts. Furthermore, the 

positive impact on employment volume within Competent Authorities (see section 7.3.2 above on social 

impacts of specific objective 1b above) could also have (an indirect) positive impact on the 

environment as the time saved as a result of the introduction of EDI could be dedicated to, for 

example, physical inspections of recycling facilities by Competent Authorities.  

With regards to the simplification of the financial guarantee system, stakeholders during the workshop 

most commonly agreed that introduction of an EU-wide fund would for the same level of protection as 

the current system. During the open public consultation process it was highlighted that entire 

abandonment of the financial guarantee system or its replacement with another regime could lead to 

lesser environmental protection and the environmental impact of any replacement solutions would have 

to be assessed in view of their ability to compensate any consequences linked to illegal shipment of 

waste (notably take back obligations). 

  Specific objective 1c - harmonisation of interpretation, application and enforcement across 

Member States 

When viewing mutual recognition for the classification of waste between Member States, there was 

a wide range of views from stakeholders via the workshops and consultation activities on its effects. 

Principally via a polling exercise which asked how stakeholders perceived environmental impacts as a 

result of mutual recognition for classifications (see  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 49). The majority of stakeholders perceived positive impacts for both mutual recognition for 

hazardous and non-hazardous classification (27 stakeholders, 58%), and classifying a commodity as a 

waste or non-waste (26 stakeholders, 59%). However, large groups of stakeholders further perceived 

negative impacts. 

161 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 49 – Workshop Poll: “What would be the environmental impact of introducing mutual recognition for 
classification of a commodity as waste or non-waste and waste as hazardous or non-hazardous” (n=46 and n=45) 

Several industry associations from the workshop noted that mutual agreement could lead to supporting 

the weakest definition (on what is potentially waste or hazardous). A waste treatment trade association 

outlined that allowing mutual recognition for only the strongest standards could be a way forward, 

citing the mutual recognition procedure for EoW in France (see below).  

Figure 50 – French Code of the Environment (Article L541-4-3, IV) 

Substances or objects which have ceased to be waste under this article remain subject to the waste regime for 

the application of the provisions of Regulation (EC) No 1013/2006 of the European Parliament and of the Council 

of 14 June 2006 concerning shipments of waste, unless the exporter provides proof that the competent authority 

of destination (within the meaning of this regulation), has no objection to the request on the classification of the 

substance or object being transferred. 

Source: https://www.legifrance.gouv.fr/codes/id/LEGIARTI000042176104/2020-07-31/. 

It is apparent, however, that the mischaracterisation of waste as hazardous or non-hazardous continues 

to be problematic. An examination of notifiable waste shipments within the EU for the period 2014-

2017105 identified the following types of errors, potentially leading to lower levels of protection from 

the treatment of the waste at the receiving countries. 

• 

Export of 96 tonnes of wastes from paint or varnish removal containing organic solvents or 

other hazardous substances in 2017 being categorised as non-hazardous when the correct 

category was hazardous. 

• 

Export of 3.7 tonnes of solvent-based developer solutions being incorrectly categorised as non-

hazardous waste in 2017. 

•  Over 4 500 tonnes of primary production slags being exported incorrectly as non-hazardous 

waste between 2014 and 2016. 

• 

Almost 6 000 tonnes of other wastes from mechanical treatment of waste containing hazardous 

substances exported and identified incorrectly as non-hazardous waste. 

105 SWD(2018) 468 final PART 2 https://eur-lex.europa.eu/resource.html?uri=cellar:44a84bd6-ee4e-11e8-b690-
01aa75ed71a1.0001.02/DOC_2&format=PDF   

162 

41%; 1942%; 1959%; 2658%; 27051015202530Classification of a commodity as waste or non-wasteClassification of waste as hazardous or non-hazardousPositive impactNegative impact 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Total mischaracterisations of waste totalling over 10 000 tonnes in a four-year period emphasises the 

lower scale of potential benefit likely to be achieved by ensuring harmonisation of classification via 

mutual recognition of hazardous and non-hazardous waste classification. 

On the issues of defining contamination thresholds either via guidance documents or legally binding 

instruments, beyond the stakeholder support for a legally binding instrument (as noted in the economic 

impacts section), there was little evidence for environmental impacts, either positively or negatively. 

However, it would be expected that the lower the contamination threshold set, the purer the waste 

and the easier it should be able to be treated, leaving a lower amount of residue. However, practically 

speaking, some level of contamination is always likely to occur and setting a threshold that prevents 

deliberate contamination to save on shipping costs whilst allowing a pragmatic level of contamination 

to be present is likely to require continuous action over a long-term basis to achieve the best 

environmental outcome. 

  Specific objective 1d – Better adapt to technical progress and stimulation of innovation  

No specific environmental impacts stemming from objective 1d have been identified, with the main aim 

of the objective targeting positive economic impacts as identified above.  

  Specific objective 2a – Stop or restrict export of waste outside of the EU 

The measures foreseen under specific objective 2a would, on the whole, have significant environmental 

impacts as outlined below. In examining the environmental benefits achieved the following has been 

considered. 

• 

The third country treatment of wastes has been shown in some cases to be poorer than the 

equivalent treatment in the EU. As noted in relation to the social impacts of 2a, evidence 

exists from a number of sources of poor management of EU wastes in third 

countries106107108109110. Quantification of the environmental damage done in third countries is 

difficult to perform. By way of example, the rate of plastics discarded or inadequately 
disposed of in third countries is estimated to be between 18% and 88%111. 
Recycling of European plastic waste has been identified as a source of plastic debris in the 

ocean. As noted in the study by Bishop et al in 2020112 approximately 3% of EU exported plastic 

waste is estimated to end up in the Ocean. This would mean using the 2030 baseline that 

without action approximately 204 000 tonnes of plastic waste would be entering the Ocean as a 
result of EU plastic waste being treated in third countries. 
The use of secondary materials in comparison to primary materials generally results in lower 

greenhouse gas emissions in overall production. A complete calculation of the savings made for 

all of the potential changes in waste flows resulting under this specific objective has not been 

• 

• 

possible within the resources of this study. However, as demonstrated in Error! Reference 

source not found. below, the replacement of primary materials by secondary materials in 

production process can result in significant greenhouse gas savings per kg of production. 

106 https://www.greenpeace.org/southeastasia/publication/4058/the-recycling-myth-2-0-the-toxic-after-effects-of-
imported-plastic-waste-in-malaysia/ 
107 Global Alliance for Incinerator Alternatives (2019) https://www.no-burn.org/wp-content/uploads/Report-April-
22.pdf 
108 CIEL et al. (2019) https://www.ciel.org/wp-content/uploads/2019/02/Plastic-and-Health-The-Hidden-Costs-of-a-
Plastic-Planet-February-2019.pdf  
109 https://espresso.repubblica.it/inchieste/2020/02/10/news/plastica-italia-malesia-traffico-illegale-1.344113 
110 Waste Force (2020) https://www.wasteforceproject.eu/wp-content/uploads/2020/03/WCA_5.pdf 
111 Jambeck et al. (2015) https://science.sciencemag.org/content/347/6223/768  
112 Bishop et al. (2020) https://pubmed.ncbi.nlm.nih.gov/32603969/  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Measures 2a2, 2a3, 2a4 and 2a5 would all have the impact of increasing the amount of 

materials available within the EU for recycling purposes, thereby offering the opportunity to 

replace virgin materials in production processes. 

Table 72 GHG emissions from primary and secondary material (selected datasets) 

*Include transports and distribution. 
EF: Environmental Footprint datasets. 
Sources:  
Ecoinvent dataset v3.7 https://www.ecoinvent.org/database/database.html 
EF datasets, http://lcdn.thinkstep.com/Node/. 

• 

The environmental externalities linked with the actual transport of wastes beyond the EUs 

borders are important aspects to be assessed. In this respect typical emissions per tonne of 

material transported to a number of destinations has been derived as detailed in Annex 3 to 

this report. These emissions have been used to estimate the environmental externalities 

avoided as a result of waste no longer being shipped to those destinations in the future. The 

EUR values have been calculated for measures 2a2 to 2a6. 

• 

The nature of manufacturing in third countries in terms of efficiency in comparison to similar 

activities within the EU. It has not been possible to quantify the total environmental benefits 

resulting from use of wastes in EU production facilities in comparison to third countries 

resulting, for example, from stricter emission standards being applied in the EU in comparison 

to the same industrial activities elsewhere. However, it is apparent that the nature of the re-

processing of waste materials in the EU will result in additional environmental benefits overall. 

By way of example, for industrial activities such as ferrous metal and non-ferrous metal 

processing energy forms a significant input into the process. Taking into account the CO2 

equivalent intensity of electricity grids importing EU ferrous metal scrap it is apparent from 

the table below that the energy used in processing facilities in the EU will generally result in 

lower net CO2 emissions resulting from energy use in the major importing countries of EU 

ferrous metal wastes. 

164 

Steel production0.643126EF-datasetsCast iron; electric arc furnace route, from steel scrap, secondary production; single route, at plant; > 2,06 % carbon contentEU-28+EFTAPrimary Steel production, electric, low-alloyed - Europe without Switzerland and Austria0.65Ecoinvent 3.7steel production, electric, low-alloyedEuropeSecondary steel production0.366EF-datasetsSecondary steel slab; electric arc furnace route, from steel scrap, secondary production; single route, at plant; carbon steelEU-28+EFTASecondary steel from iron scrap0.264Ecoinvent 3.7steel production, electric, low-alloyedCanadaPrimary Glass production for bottles and jars; 1 kg of formed and finished container glass1.08EF datasetsContainer glass, virgin; Virgin container glass (all sizes) to be used for glass bottles and food jars; Production mix. Technology mix. EU-28 + EFTAPrimary Glass Fibres production2.092Ecoinvent 3.7Glass fibre productionEUPrimary Glass Fibres production2.51Ecoinvent 3.7Glass fibre productionRoW (Rest-of-WorldRecycled glass (100% recycled)0.63EF datasetsEU-27, Container glass, ER, Recycled content 100%, provided by FEVEPrimary Aluminium ingot mix8.21EF datasetAluminium ingot mix; primary production; production mix, to consumer; aluminium ingot product, primary productionEU-28+EFTAPrimary Aluminium ingot mix11.28EF datasetAluminium ingot mix (high purity); primary production, aluminium casting; single route, at plant; 2.7 g/cm3, >99% AlEU-28+EFTAPrimary Aluminium production, , ingot7.3Ecoinvent 3.7Aluminium production, primary, ingot – IAI Area, EU27 & EFTAIAI Area, EU27 & EFTAPrimary Aluminium ingot, to aluminium, cast alloy market19.5Ecoinvent 3.7Aluminium ingot, primary, to aluminium, cast alloy market – GLOGlobal averageSecondary aluminium production0.5636EF datasetsAluminium die-casting; secondary production, aluminium casting; single route, at plant; 2.7 g/cm3EU-28+EFTATreatment of aluminium scrap, post-consumer, prepared for recycling, at remelter (secondary aluminium production from scraps)4.75Ecoinvent 3.7Treatment of aluminium scrap, post-consumer, prepared for recycling, at remelter REREUMaterialSourceNameRegionkg CO2-eq./kg  
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 73 CO2 equivalent intensity of energy production of the major countries importing EU ferrous metal 
waste 

Source: Eurofer, 2021 – Briefing paper – The export of ferrous scrap & the Waste Shipment Regulation113 

• 

The greenhouse gas reductions that would result from disposal activities in the EU in 

comparison to third countries – the CO2-eq reductions have been calculated for measures 2a2 

to 2a6. 

• 

An issue raised by stakeholders during the workshop under this study noted that third countries 

often welcome EU wastes as they are generally well sorted and have a higher economic value 

in reprocessing terms in comparison to wastes from other countries or from domestic waste 

generation. However, the knock-on consequence of this is that EU wastes can displace 

domestically generated wastes in third countries, effectively blocking the more effective 

management of those domestic wastes in third countries as a result of EU wastes being easier 

to manage. Considering that Turkey and India - the main importers of European waste in 

201915 – landfill 99%114 and dump 77%115 of waste, respectively, whereas in other OECD and EU 

countries only 35% of waste is landfilled, it can be assumed that this is a problem that exists in 

practice. Placing a financial cost on such displacement is not possible. However, this is an 

important consideration for all of the measures foreseen under specific objective 2a and, 

whilst not repeated for each specific measure, is considered as a positive environmental 

benefit that would stem from each more considered. 

Measure 2a1: Maintain the current legal regime and facilitate its implementation – would likely have 

the smallest impacts given its most relevant impacts are economic – making the current regime more 

efficient and looking to reduce the costs of administering the regulatory framework rather than 

specifically addressing the environmental impacts of exported wastes. 

113 The sources used by Eurofer in determining the figures is taken from https://www.iea.org/data-and-
statistics/charts/carbon-intensity-of-electricity-generation-in-selected-regions-in-the-sustainable-development-
scenario-2000-2040  
European Standard EN 19694-2: Stationary source emissions — Determination of greenhouse gas (GHG) emissions in 
energy-intensive industries; and Carbon Footprint; Country Specific Electricity Grid Greenhous Gas Emission Factors, 
Last Updated June 2019; www.carbonfootprint.com  
114 OECD (2015) https://www.oecd-ilibrary.org/docserver/9789264235199-
en.pdf?expires=1618302257&id=id&accname=guest&checksum=B1862D973930AF4714455B0B8A257010  
115 World Bank (2020) What a Waste Global Database - Country level dataset 
https://datacatalog.worldbank.org/dataset/what-waste-global-database/resource/de74cc68-e796-4e42-9793-
f140719c91ac#{view-
graph:{graphOptions:{hooks:{processOffset:{},bindEvents:{}}}},graphOptions:{hooks:{processOffset:{},bindEvents:{}}}} 

165 

 
 
 
  
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Measure 2a2: Ban export of all waste outside the OECD, except for third countries which notify the 

EU of their willingness and readiness to import such waste places an additional burden on third 

countries to prove that they are managing wastes in an environmentally sound manner. A more 

comprehensive evidence chain under this measure would likely result in ensuring that for those 

countries that are managing wastes are managed in an environmentally sound manner can continue to 

import EU wastes whilst reassuring exporters of those wastes of the protections provided in their 

management by third countries. For those countries that do not notify the EU of their willingness to 

import such wastes and to manage them according to ESM, the diversion of wastes from those non-OECD 

third countries to those that do comply with the provisions under 2a2 or to OECD countries or fore 

which the wastes are retained in the EU ESM is more likely to be applied.  

With regard to the possible retention of wastes within the EU that would otherwise have been sent to 

third countries, the following external environmental costs in EUR would be avoided in relation to 

transport (note that these values are also valid for measure 2a3 given the deterrence of export impact 

could be similar and the use of 75%, 50% and 20% diversion scenarios gives an idea of the variations that 

could occur for both 2a2 and 2a3). 

Table 74 Environmental transport externalities avoided under 2a2 and 2a3 with regard to different percentages 
of retention of EU waste that would normally have been exported to non-OECD third countries in EUR value  

Furthermore, in respect to the waste management of wastes in third countries in comparison to the EU, 

reductions in greenhouse gas emissions would be expected based on the landfill and incineration 

practices in comparison to those in third countries. Error! Reference source not found. below provides 

the changes that would be anticipated in CO2-eq.  

166 

Environmental transport externalities avoided forecast for 75% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal178,130,690139,510,919157,053,215130,900,386181,134,332205,483,597166,290,514172,365,815197,674,616154,158,888159,709,006185,977,344Glass2,550,0162,216,7392,077,3271,922,3921,751,9331,565,9501,364,4431,147,413914,858666,780403,179124,053Non-ferrous metals91,999,95589,924,01085,485,73880,828,80375,953,20670,858,94565,546,02160,014,43554,264,18648,295,27342,107,69835,701,460Paper and cardboard377,865,380398,928,997400,260,407401,542,387402,774,935403,958,052405,091,738406,175,992407,210,816408,196,208409,132,169410,018,698Plastic87,119,94887,632,11088,078,14588,458,05488,771,83789,019,49489,201,02489,316,42889,365,70689,348,85889,265,88389,116,782Textiles61,765,19664,367,20666,991,83469,635,41172,297,93874,979,41377,679,83680,399,20983,137,53185,894,80288,671,02191,466,190Total799,431,185782,579,981799,946,667773,287,434822,684,181845,865,450805,173,577809,419,292832,567,713786,560,809789,288,956812,404,528Environmental transport externalities avoided forecast for 50% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal118,753,79393,007,279104,702,14387,266,924120,756,222136,989,065110,860,343114,910,543131,783,077102,772,592106,472,671123,984,896Glass1,700,0111,477,8261,384,8851,281,5951,167,9551,043,966909,629764,942609,906444,520268,78682,702Non-ferrous metals61,333,30459,949,34056,990,49253,885,86950,635,47047,239,29743,697,34840,009,62336,176,12432,196,84928,071,79923,800,974Paper and cardboard251,910,253265,952,665266,840,272267,694,925268,516,623269,305,368270,061,159270,783,995271,473,877272,130,805272,754,779273,345,799Plastic58,079,96558,421,40658,718,76358,972,03659,181,22559,346,32959,467,34959,544,28559,577,13759,565,90559,510,58959,411,188Textiles41,176,79742,911,47144,661,22346,423,60848,198,62549,986,27551,786,55853,599,47355,425,02157,263,20159,114,01460,977,460Total532,954,124521,719,987533,297,778515,524,956548,456,120563,910,300536,782,385539,612,862555,045,142524,373,873526,192,637541,603,018Environmental transport externalities avoided forecast for 20% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal47,501,51737,202,91241,880,85734,906,77048,302,48954,795,62644,344,13745,964,21752,713,23141,109,03742,589,06849,593,958Glass680,004591,130553,954512,638467,182417,587363,851305,977243,962177,808107,51433,081Non-ferrous metals24,533,32123,979,73622,796,19721,554,34820,254,18818,895,71917,478,93916,003,84914,470,45012,878,74011,228,7209,520,389Paper and cardboard100,764,101106,381,066106,736,109107,077,970107,406,649107,722,147108,024,463108,313,598108,589,551108,852,322109,101,912109,338,320Plastic23,231,98623,368,56323,487,50523,588,81423,672,49023,738,53223,786,94023,817,71423,830,85523,826,36223,804,23523,764,475Textiles16,470,71917,164,58817,864,48918,569,44319,279,45019,994,51020,714,62321,439,78922,170,00822,905,28023,645,60624,390,984Total213,181,649208,687,995213,319,111206,209,982219,382,448225,564,120214,712,954215,845,145222,018,057209,749,549210,477,055216,641,207YearYearYear 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 75 GHG emissions avoided in tonnes of CO2-eq under Measure 2a2 and 2a3  

In addition to calculating the changes in CO2-eq emissions resulting from the changes under this 

scenario, a calculation of the cost of the environmental externalities resulting from waste management 

of rejected wastes in third countries in comparison to the EU has been performed. The results in EUR 

are presented below. Negative values indicate an increase in external environmental costs in 

comparison to the baseline. 

167 

GHG emission reductions tonnes CO2 eq75% of wastes retainedWaste type201920202021202220232024202520262027202820292030Ferrous metal71,83356,25963,33452,78754,78362,14850,29452,13159,78646,62548,30356,248Glass5144474193873533162752311841348125Non-ferrous metals21,77121,28020,23019,12817,97416,76815,51114,20212,84111,4299,9658,449Paper and cardboard632,799668,073670,303672,450674,514676,495678,394680,209681,942683,593685,160686,645Plastic8,5978,6488,6928,7308,7608,7858,8038,8148,8198,8178,8098,795Textiles168,954176,072183,251190,483197,766205,101212,488219,926227,417234,959242,553250,199Total904,469930,779946,228943,964954,151969,613965,764975,515990,990985,557994,8721,010,360GHG emission reductions tonnes CO2 eq50% of wastes retainedWaste type201920202021202220232024202520262027202820292030Ferrous metal47,88937,50642,22235,19136,52241,43233,52934,75439,85731,08332,20237,499Glass343298279258235210183154123905417Non-ferrous metals14,51414,18713,48612,75211,98311,17910,3419,4688,5617,6196,6435,632Paper and cardboard421,866445,382446,869448,300449,676450,997452,262453,473454,628455,728456,773457,763Plastic5,7325,7655,7955,8205,8405,8575,8695,8765,8795,8785,8735,863Textiles112,636117,381122,168126,989131,844136,734141,659146,618151,611156,639161,702166,800Total602,979620,519630,819629,309636,100646,408643,843650,343660,660657,038663,248673,574GHG emission reductions tonnes CO2 eq20% of wastes retainedWaste type201920202021202220232024202520262027202820292030Ferrous metal19,15615,00316,88914,07714,60916,57313,41213,90215,94312,43312,88115,000Glass137119112103948473624936227Non-ferrous metals5,8065,6755,3955,1014,7934,4724,1363,7873,4243,0482,6572,253Paper and cardboard168,746178,153178,747179,320179,870180,399180,905181,389181,851182,291182,709183,105Plastic2,2932,3062,3182,3282,3362,3432,3472,3502,3522,3512,3492,345Textiles45,05446,95348,86750,79552,73854,69456,66358,64760,64562,65664,68166,720Total241,192248,208252,328251,724254,440258,563257,537260,137264,264262,815265,299269,429YearYearYear 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 76 Change in external costs resulting from the management of rejected wastes in third countries moving 
to the EU under measure 2a2 in EUR  

Measure 2a3: Require that the export of green-listed waste outside the OECD is subject to the 

“prior written notification and consent” (PIC) procedure where it is allowed – would add more 

stringent provisions that measure 2a2 from an environmental perspective, requiring a more transparent 

transport and management evidence trail than exists at present. The same potential environmental 

benefits as 2a2 apply, albeit the application of PIC means that obtaining those benefits in practice is 

more likely under 2a3 than under 2a2 where information and rules would only apply at the national 

level and not the individual shipment level.  

Measure 2a4: Restrict exports to OECD countries – the environmental impacts of restricting 

movements of some of the wastes to OECD countries is likely, per tonne, to be less that the measures 

foreseen under 2a2 and 2a3 above – most notably for metals. This is because the methods and rules for 

management of metal wastes between OECD parties, including the EU, are generally more akin to ESM 

than other non-OECD third countries. An assessment, for example, of the potential impacts of use of 

waste ferrous metals in the EU in comparison to Turkey, as the largest OECD recipient of EU ferrous 

metal wastes, considered the likely emissions from iron and steel installations using those materials. 

Presently Turkey is involved in a process of implementing its industrial emissions strategy116 for the 

period 2020-2023. This process will bring Turkey’s permitting approach to iron and steel installations 

much closer, if not equal, to the industrial emissions framework in place within the EU under Directive 

2010/75/EU on industrial emissions. Given the timescale for measures considered in this report to come 

into effect it is difficult, therefore, to identify significant environmental advantages to the use of waste 

materials in industrial processes within the EU in comparison to OECD countries. 

116 https://www.dai.com/our-work/projects/turkey-determination-of-industrial-emissions-strategy-of-turkey-in-
accordance-with-integrated-pollution-prevention-and-control  

168 

Waste management EUR externalities75% of wastes retainedWaste type201920202021202220232024202520262027202820292030Ferrous metal7,239,0125,669,5526,382,4495,319,6305,520,8076,262,9505,068,3815,253,5516,024,9404,698,6204,867,7835,668,418Glass51,78645,01842,18739,04035,57831,80227,70923,30218,57913,5418,1882,519Non-ferrous metals2,193,9972,144,4902,038,6471,927,5891,811,3171,689,8301,563,1291,431,2121,294,0821,151,7361,004,176851,401Paper and cardboard72,683,99976,735,67476,991,77777,238,37177,475,45777,703,03477,921,10378,129,66478,328,71778,518,26178,698,29778,868,825Plastic89,142,27389,666,32490,122,71390,511,44190,832,50891,085,91491,271,65891,389,74191,440,16391,422,92391,338,02291,185,460Textiles28,308,05229,500,59830,703,51031,915,10733,135,38834,364,35435,602,00536,848,34038,103,36039,367,06540,639,45441,920,528Total199,619,119203,761,656206,281,283206,951,179208,811,056211,137,884211,453,986213,075,811215,209,840215,172,147216,555,921218,497,152Waste management EUR externalities50% of wastes retainedWaste type201920202021202220232024202520262027202820292030Ferrous metal4,826,0083,779,7014,254,9663,546,4203,680,5384,175,3003,378,9213,502,3674,016,6263,132,4143,245,1893,778,945Glass34,52430,01228,12426,02723,71921,20118,47315,53512,3869,0275,4591,680Non-ferrous metals1,462,6651,429,6601,359,0981,285,0601,207,5451,126,5531,042,086954,142862,721767,824669,451567,601Paper and cardboard48,455,99951,157,11651,327,85151,492,24751,650,30451,802,02351,947,40252,086,44352,219,14552,345,50852,465,53252,579,217Plastic59,428,18259,777,54960,081,80960,340,96160,555,00560,723,94260,847,77260,926,49460,960,10860,948,61560,892,01560,790,307Textiles18,872,03519,667,06520,469,00721,276,73822,090,25922,909,57023,734,67024,565,56025,402,24026,244,71027,092,96927,947,019Total133,079,412135,841,104137,520,855137,967,453139,207,370140,758,589140,969,324142,050,540143,473,227143,448,098144,370,614145,664,768Waste management EUR externalities20% of wastes retainedWaste type201920202021202220232024202520262027202820292030Ferrous metal1,930,4031,511,8801,701,9861,418,5681,472,2151,670,1201,351,5681,400,9471,606,6511,252,9651,298,0751,511,578Glass13,81012,00511,25010,4119,4888,4807,3896,2144,9543,6112,183672Non-ferrous metals585,066571,864543,639514,024483,018450,621416,834381,657345,088307,130267,780227,040Paper and cardboard19,382,40020,462,84620,531,14020,596,89920,660,12220,720,80920,778,96120,834,57720,887,65820,938,20320,986,21321,031,687Plastic23,771,27323,911,02024,032,72424,136,38424,222,00224,289,57724,339,10924,370,59824,384,04324,379,44624,356,80624,316,123Textiles7,548,8147,866,8268,187,6038,510,6958,836,1049,163,8289,493,8689,826,22410,160,89610,497,88410,837,18811,178,807Total53,231,76554,336,44255,008,34255,186,98155,682,94856,303,43656,387,72956,820,21657,389,29157,379,23957,748,24658,265,907YearYearYear 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The process of applying PIC to wastes currently not addressed by such procedures would provide greater 

transparency to shipments of wastes and a better guarantee of their ESM within the country of 

destination. 

The same approach to addressing the environmental externalities of transport of EU wastes to OECD 

countries as used under 2a2 and 2a3 has been applied under 2a4, reflecting different levels of retention 

of EU waste as a result of the application of the PIC procedure. The results are presented in Error! 

Reference source not found. below. 

Table 77 Environmental transport externalities avoided under 2a4 in EUR value with regard to different percentages of 
retention of EU waste that would normally have been exported to OECD countries 

Furthermore, in respect to the waste management of wastes in third countries in comparison to the EU, 

reductions in greenhouse gas emissions would be expected based on the landfill and incineration 

practices in comparison to those in third countries. Error! Reference source not found. below provides 

the savings that would be anticipated in tonnes of CO2-eq. Negative values indicate an increase in CO2-

eq emissions in comparison to the baseline. 

169 

Environmental externalities avoided in EUR EU forecast for 75% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal330,235,779369,187,207372,494,522403,533,033414,831,843417,682,429450,778,471462,327,262464,721,120499,874,693511,673,466513,610,594Glass8,168,6847,945,5878,399,1898,864,3099,340,9479,829,10410,328,77910,839,97311,362,68511,896,91612,442,66512,999,932Non-ferrous metals23,530,88325,657,14328,835,06032,110,32235,482,92838,952,87842,520,17246,184,81149,946,79353,806,12057,762,79061,816,805Paper and cardboard35,188,89238,262,12439,519,46740,793,89042,085,39343,393,97444,719,63646,062,37647,422,19648,799,09550,193,07451,604,132Plastic15,365,47516,224,79217,106,81818,011,55318,938,99819,889,15220,862,01621,857,58922,875,87123,916,86324,980,56526,066,975Textiles4,312,8244,318,6964,313,2754,296,3054,267,7864,227,7174,176,0994,112,9314,038,2153,951,9483,854,1333,744,768Total416,802,538461,595,548470,668,332507,609,412524,947,894533,975,255573,385,173591,384,942600,366,880642,245,636660,906,692669,843,207Environmental externalities avoided in EUR EU forecast for 50% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal220,157,186246,124,805248,329,681269,022,022276,554,562278,454,953300,518,981308,218,175309,814,080333,249,796341,115,644342,407,063Glass5,445,7905,297,0585,599,4595,909,5396,227,2986,552,7366,885,8537,226,6497,575,1237,931,2778,295,1108,666,621Non-ferrous metals15,687,25517,104,76219,223,37321,406,88123,655,28525,968,58528,346,78130,789,87433,297,86235,870,74638,508,52741,211,203Paper and cardboard23,459,26125,508,08226,346,31127,195,92728,056,92828,929,31629,813,09030,708,25131,614,79732,532,73033,462,04934,402,755Plastic10,243,65010,816,52811,404,54512,007,70212,625,99913,259,43513,908,01014,571,72615,250,58115,944,57516,653,71017,377,984Textiles2,875,2162,879,1312,875,5172,864,2042,845,1912,818,4782,784,0662,741,9542,692,1432,634,6322,569,4222,496,512Total277,868,358307,730,365313,778,888338,406,275349,965,263355,983,503382,256,782394,256,628400,244,587428,163,757440,604,462446,562,138Environmental externalities avoided in EUR EU forecast for 20% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal88,062,87598,449,92299,331,873107,608,809110,621,825111,381,981120,207,592123,287,270123,925,632133,299,918136,446,258136,962,825Glass2,178,3162,118,8232,239,7842,363,8162,490,9192,621,0942,754,3412,890,6593,030,0493,172,5113,318,0443,466,649Non-ferrous metals6,274,9026,841,9057,689,3498,562,7539,462,11410,387,43411,338,71312,315,94913,319,14514,348,29915,403,41116,484,481Paper and cardboard9,383,70410,203,23310,538,52510,878,37111,222,77111,571,72711,925,23612,283,30012,645,91913,013,09213,384,82013,761,102Plastic4,097,4604,326,6114,561,8184,803,0815,050,3995,303,7745,563,2045,828,6906,100,2326,377,8306,661,4846,951,193Textiles1,150,0861,151,6521,150,2071,145,6811,138,0761,127,3911,113,6261,096,7821,076,8571,053,8531,027,769998,605Total111,147,343123,092,146125,511,555135,362,510139,986,105142,393,401152,902,713157,702,651160,097,835171,265,503176,241,785178,624,855YearYearYear 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 78 GHG emissions avoided in tonnes of CO2-eq under Measure 2a4  

In addition to calculating the changes in CO2-eq emissions resulting from the changes under this 

scenario, a calculation of the cost of the environmental externalities resulting from waste management 

of rejected wastes in third countries in comparison to the EU has been performed. The results in EUR 

are presented below.  

Table 79 Change in external costs resulting from the management of rejected wastes in third countries moving 
to the EU under measure 2a4 in EUR 

170 

GHG emissions avoided from waste management with 75% retained of formerly exported wastes retained within EU in tonnes of CO2-eqWaste type201920202021202220232024202520262027202820292030Ferrous metal209,834234,584236,685256,407263,587265,398286,427293,765295,287317,623325,120326,351Glass2,2192,1582,2812,4072,5372,6702,8052,9443,0863,2313,3793,531Non-ferrous metals12,50813,63915,32817,06918,86220,70622,60224,55026,55028,60230,70532,860Paper and cardboard170,554185,450191,544197,721203,981210,323216,748223,256229,847236,521243,277250,116Plastic4,4154,6624,9165,1765,4425,7155,9956,2816,5746,8737,1787,491Textiles19,35619,38219,35819,28219,15418,97418,74218,45918,12417,73617,29716,807Total418,886459,875470,112498,062513,562523,786553,320569,256579,467610,586626,957637,155GHG emissions avoided from waste management with 50% retained of formerly exported wastes retained within EU in tonnes of CO2-eqWaste type201920202021202220232024202520262027202820292030Ferrous metal139,889156,389157,790170,938175,724176,932190,952195,844196,858211,749216,747217,567Glass1,4791,4391,5211,6051,6911,7801,8701,9632,0572,1542,2532,354Non-ferrous metals8,3399,09210,21911,37912,57413,80415,06816,36717,70019,06820,47021,907Paper and cardboard113,703123,633127,696131,814135,987140,215144,499148,838153,231157,681162,185166,744Plastic2,9443,1083,2773,4503,6283,8103,9974,1874,3824,5824,7864,994Textiles12,90412,92212,90512,85512,76912,64912,49512,30612,08211,82411,53211,204Total279,258306,583313,408332,041342,375349,191368,880379,504386,311407,057417,972424,770GHG emissions avoided from waste management with 20% retained of formerly exported wastes retained within EU in tonnes of CO2-eqWaste type201920202021202220232024202520262027202820292030Ferrous metal55,95662,55663,11668,37570,29070,77376,38178,33778,74384,70086,69987,027Glass592575608642677712748785823862901942Non-ferrous metals3,3363,6374,0874,5525,0305,5226,0276,5477,0807,6278,1888,763Paper and cardboard45,48149,45351,07852,72654,39556,08657,80059,53561,29363,07264,87466,698Plastic1,1771,2431,3111,3801,4511,5241,5991,6751,7531,8331,9141,997Textiles5,1625,1695,1625,1425,1085,0604,9984,9224,8334,7304,6134,482Total111,703122,633125,363132,817136,950139,676147,552151,802154,525162,823167,189169,908YearYearYearWaste management externalities avoided in EUR forecast for 75% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal21,146,03923,640,22223,852,00025,839,49426,562,99226,745,52428,864,76929,604,27429,757,56032,008,55532,764,06732,888,108Glass223,576217,470229,885242,616255,661269,022282,698296,689310,996325,618340,555355,807Non-ferrous metals1,260,5261,374,4281,544,6661,720,1191,900,7862,086,6682,277,7642,474,0752,675,6012,882,3413,094,2963,311,466Paper and cardboard19,590,09021,300,99622,000,97522,710,46223,429,45824,157,96124,895,97325,643,49326,400,52227,167,05927,943,10428,728,657Plastic45,780,42048,340,69750,968,63553,664,23456,427,49559,258,41762,157,00065,123,24468,157,14971,258,71674,427,94477,664,834Textiles3,243,0603,247,4763,243,4003,230,6393,209,1933,179,0633,140,2493,092,7493,036,5662,971,6972,898,1442,815,906Total91,243,71398,121,290101,839,561107,407,563111,785,585115,696,655121,618,452126,234,525130,338,394136,613,986141,468,111145,764,778Waste management externalities avoided in EUR forecast for 50% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal14,097,36015,760,14815,901,33317,226,32917,708,66217,830,35019,243,17919,736,18319,838,37421,339,03621,842,71221,925,405Glass149,051144,980153,257161,744170,441179,348188,465197,793207,331217,078227,037237,205Non-ferrous metals840,351916,2851,029,7771,146,7461,267,1911,391,1121,518,5091,649,3831,783,7341,921,5612,062,8642,207,644Paper and cardboard13,060,06014,200,66414,667,31715,140,30815,619,63816,105,30716,597,31517,095,66217,600,34818,111,37318,628,73619,152,438Plastic30,520,28032,227,13133,979,09035,776,15637,618,33039,505,61141,438,00043,415,49645,438,10047,505,81149,618,63051,776,556Textiles2,162,0402,164,9842,162,2662,153,7592,139,4622,119,3762,093,4992,061,8332,024,3771,981,1311,932,0961,877,271Total60,829,14265,414,19367,893,04171,605,04274,523,72377,131,10381,078,96884,156,35086,892,26391,075,99094,312,07497,176,519Waste management externalities avoided in EUR forecast for 20% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal5,638,9446,304,0596,360,5336,890,5327,083,4657,132,1407,697,2727,894,4737,935,3498,535,6158,737,0858,770,162Glass59,62057,99261,30364,69768,17671,73975,38679,11782,93286,83190,81594,882Non-ferrous metals336,140366,514411,911458,698506,876556,445607,404659,753713,494768,624825,146883,058Paper and cardboard5,224,0245,680,2665,866,9276,056,1236,247,8556,442,1236,638,9266,838,2657,040,1397,244,5497,451,4947,660,975Plastic12,208,11212,890,85313,591,63614,310,46215,047,33215,802,24416,575,20017,366,19818,175,24019,002,32419,847,45220,710,622Textiles864,816865,994864,907861,504855,785847,750837,400824,733809,751792,453772,838750,908Total24,331,65726,165,67727,157,21628,642,01729,809,48930,852,44132,431,58733,662,54034,756,90536,430,39637,724,82938,870,607YearYearYear 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Measure 2a5 – Ban all exports of waste to non-OECD third countries carries the second largest 

potential environmental benefits. In comparison to the other options above, addressing ESM in non-

OECD third countries is most obviously obtained by not allowing export to non-OECD non-EU countries in 

the first place – if it is not exported it cannot be managed in a non-ESM manner. The general 

environmental benefits highlighted for all measures e.g. ensuring ESM, replacing virgin materials with 

secondary materials, removing EU wastes from third country waste management systems that would be 

better focussed on domestic waste management and reducing environmental externalities of transport 

all apply here. 

A calculation of the transport externalities avoided is shown in Error! Reference source not found. 

below. 

Table 80 Environmental transport externalities avoided under 2a5 with regard to the ban of export of EU waste 
in EUR  

In respect to the waste management of wastes in non-OECD third countries in comparison to the EU, 

reductions in greenhouse gas emissions would be expected based on the landfill and incineration 

practices in comparison to those in third countries. Error! Reference source not found. below provides 

the savings that would be anticipated in CO2-eq tonnes. Negative values indicate an increase in CO2-eq 

emissions in comparison to the baseline. 

Table 81 GHG emissions avoided in tonnes of CO2-eq under Measure 2a5 

In addition to calculating the changes in CO2-eq emissions resulting from the changes under this 

scenario, a calculation of the cost of the environmental externalities resulting from waste management 

of rejected wastes in third countries in comparison to the EU has been performed. The results in EUR 

are presented below.  

Table 82 Change in external costs resulting from the management of rejected wastes in third countries moving 
to the EU under measure 2a5 in EUR 

171 

Environmental transport externalities avoided forecast for 100% retained within EU in EURWaste type201920202021202220232024202520262027202820292030Ferrous metal237,507,586186,014,558209,404,286174,533,848181,134,332205,483,597166,290,514172,365,815197,674,616154,158,888159,709,006185,977,344Glass4,035,2903,507,8943,287,2813,042,1022,772,3582,478,0482,159,1721,815,7311,447,7241,055,151638,013196,309Non-ferrous metals71,983,70970,359,42266,886,77763,243,04259,428,21855,442,30651,285,30446,957,21442,458,03537,787,76732,946,41027,933,965Paper and cardboard279,158,927294,720,280295,703,898296,650,997297,561,578298,435,639299,273,182300,074,207300,838,712301,566,699302,258,167302,913,116Plastic61,116,91161,476,20561,789,11162,055,62762,275,75462,449,49162,576,84062,657,79962,692,36862,680,54962,622,34062,517,742Textiles80,493,40283,884,38487,304,84290,749,99494,219,84197,714,383101,233,619104,777,549108,346,175111,939,494115,557,509119,200,217Total734,295,825699,962,744724,376,194690,275,610697,392,081722,003,464682,818,631688,648,314713,457,630669,188,548673,731,444698,738,693YearGHG emission reductions expected through the retention of wastes in tonnes of CO2-eqWaste type201920202021202220232024202520262027202820292030Ferrous metal95,77875,01384,44570,38373,04582,86467,05969,50979,71562,16664,40574,998Glass68559655851747142136730824617910833Non-ferrous metals29,02828,37326,97325,50323,96522,35820,68118,93617,12215,23813,28611,265Paper and cardboard843,731890,764893,737896,600899,352901,994904,525906,946909,257911,457913,547915,526Plastic11,46311,53111,58911,63911,68111,71311,73711,75211,75911,75711,74611,726Textiles225,272234,763244,335253,977263,688273,468283,317293,235303,223313,279323,404333,599Total1,205,9581,241,0391,261,6381,258,6191,272,2011,292,8171,287,6861,300,6861,321,3201,314,0761,326,4961,347,147YearWaste management externalities avoided in EUR forecast for 100% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal9,652,0167,559,4028,509,9327,092,8407,361,0768,350,6006,757,8427,004,7348,033,2536,264,8276,490,3777,557,890Glass69,04860,02456,24952,05447,43842,40236,94631,06924,77218,05510,9173,359Non-ferrous metals2,925,3292,859,3202,718,1962,570,1192,415,0902,253,1072,084,1721,908,2831,725,4421,535,6481,338,9021,135,202Paper and cardboard96,911,998102,314,232102,655,702102,984,494103,300,609103,604,046103,894,805104,172,886104,438,289104,691,015104,931,063105,158,433Plastic118,856,365119,555,099120,163,618120,681,922121,110,011121,447,885121,695,544121,852,988121,920,217121,897,231121,784,030121,580,614Textiles37,744,06939,334,13040,938,01342,553,47644,180,51845,819,13947,469,34049,131,12150,804,48152,489,42054,185,93955,894,037Total266,158,825271,682,208275,041,710275,934,905278,414,741281,517,179281,938,647284,101,081286,946,454286,896,196288,741,228291,329,536Year 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Measure 2a6 – Ban all exports of waste carries the largest potential environmental benefits. In 

comparison to the other options above, addressing ESM in all third countries is most obviously obtained 

by not allowing export to non-EU countries in the first place – if it is not exported it cannot be managed 

in a non-ESM manner. The general environmental benefits highlighted for all measures e.g. ensuring 

ESM, replacing virgin materials with secondary materials, removing EU wastes from third country waste 

management systems that would be better focussed on domestic waste management and reducing 

environmental externalities of transport all apply here. 

A calculation of the transport externalities avoided is shown in Error! Reference source not found. 

below. 

Table 83 Environmental transport externalities avoided under 2a6 with regard to the ban of export of EU waste 
in EUR  

In respect to the waste management of wastes in all third countries in comparison to the EU, reductions 

in greenhouse gas emissions would be expected based on the landfill and incineration practices in 

comparison to those in third countries. Error! Reference source not found. below provides the savings 

that would be anticipated in CO2-eq. Negative values indicate an increase in CO2-eq emissions in 

comparison to the baseline. 

Table 84 GHG emissions avoided in tonnes of CO2-eq under Measure 2a6  

In addition to calculating the changes in CO2-eq emissions resulting from the changes under this 

scenario, a calculation of the cost of the environmental externalities resulting from waste management 

of rejected wastes in third countries in comparison to the EU has been performed. The results in EUR 

are presented below. Negative values indicate an increase in external environmental costs in 

comparison to the baseline. 

Table 85 Change in external costs resulting from the management of rejected wastes in third countries moving 
to the EU under measure 2a6 in EUR 

172 

Environmental transport externalities avoided forecast for 100% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal931,296,328961,635,929991,973,9591,022,311,9891,052,650,0201,082,988,0501,113,326,0801,143,664,1101,174,002,1411,204,340,1711,234,678,2011,265,016,231Glass21,456,87320,453,67121,200,46721,947,26222,694,05823,440,85424,187,65024,934,44625,681,24226,428,03727,174,83327,921,629Non-ferrous metals113,340,816115,453,574117,566,332119,679,089121,791,847123,904,605126,017,363128,130,121130,242,878132,355,636134,468,394136,581,152Paper and cardboard354,398,989376,531,455380,203,495383,875,536387,547,577391,219,617394,891,658398,563,699402,235,739405,907,780409,579,820413,251,861Plastic92,504,46494,619,11296,733,76098,848,409100,963,057103,077,705105,192,353107,307,002109,421,650111,536,298113,650,947115,765,595Textiles89,714,98193,118,51996,527,38699,936,253103,345,121106,753,988110,162,856113,571,723116,980,590120,389,458123,798,325127,207,193Total1,602,712,4511,661,812,2591,704,205,3991,746,598,5391,788,991,6791,831,384,8201,873,777,9601,916,171,1001,958,564,2402,000,957,3812,043,350,5212,085,743,661YearGHG emissions avoided for the retention of all exported wastes in tonnes of CO2-eqWaste type201920202021202220232024202520262027202820292030Ferrous metal375,556387,791400,025412,259424,493436,728448,962461,196473,430485,664497,898510,132Glass3,6433,4733,6003,7273,8533,9804,1074,2344,3614,4874,6144,741Non-ferrous metals45,70646,55847,41048,26249,11449,96650,81851,67052,52253,37454,22655,078Paper and cardboard1,071,1371,138,0311,149,1291,160,2281,171,3261,182,4241,193,5231,204,6211,215,7201,226,8181,237,9161,249,015Plastic17,35017,74718,14418,54018,93719,33419,73020,12720,52420,92021,31721,713Textiles251,080260,606270,146279,686289,226298,767308,307317,847327,387336,927346,468356,008Total1,764,4741,854,2051,888,4541,922,7021,956,9501,991,1982,025,4462,059,6952,093,9432,128,1912,162,4392,196,687Year 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

173 

Waste management externalities avoided for the retention of all exported wastes in EURWaste type201920202021202220232024202520262027202820292030Ferrous metal37,846,73539,079,69940,312,59941,545,49942,778,39944,011,29945,244,20046,477,10047,710,00048,942,90050,175,80051,408,700Glass367,150349,984362,762375,541388,319401,098413,876426,655439,433452,212464,990477,769Non-ferrous metals4,606,0314,691,8914,777,7514,863,6114,949,4715,035,3305,121,1905,207,0505,292,9105,378,7705,464,6305,550,490Paper and cardboard123,032,119130,715,561131,990,336133,265,111134,539,886135,814,661137,089,435138,364,210139,638,985140,913,760142,188,535143,463,310Plastic179,896,925184,009,361188,121,798192,234,234196,346,671200,459,107204,571,543208,683,980212,796,416216,908,853221,021,289225,133,725Textiles42,068,14943,664,09845,262,54646,860,99448,459,44250,057,89051,656,33853,254,78654,853,23556,451,68358,050,13159,648,579Total387,817,108402,510,594410,827,792419,144,990427,462,188435,779,385444,096,583452,413,781460,730,979469,048,177477,365,375485,682,573Year 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

  Specific objective 2b – verify ESM in destination countries 

By ensuring the environmentally sound management of waste in third countries, the measure has 

potential to reduce environmental impacts of waste shipment. The extent of the impact is dependent 

on the volumes of waste concerned. Further information on the volumes of waste concerned are 

presented in Table 34 Forecast of tonnes of waste to be exported from the EU to third countries under 

the baseline scenario above. 

  Specific objective 3a – Further strengthen provisions on enforcement and inspections 

A study on the environmental damage of illegal waste transport117 monetised the impacts of individual 

illegal shipments between €4,000 and €1.2 million with an average of €320,000. The study also states a 

lack of information and data make that this outcome should be considered as incomplete and probably 

largely underestimates the real impact of illegal waste trafficking. The primary impacts relate to 

climate change, particulate matter, and ozone depletion. Improving inspection and enforcement 

practices has the potentially to considerable reducing the environmental impact of waste shipment. 

The volume of illegal waste shipments is not known. As earlier indicated, data from IMPEL found that as 

part of 3 060 waste shipments inspected in 2016, 1 020 (33.4%) were in violation of the WSR. In 2017 of 

2 766 waste-related transport inspections 853 (30.8%) were in violation of the WSR. Of the 2016 

inspections undertaken on roads or at ports over 2014-2015 related to waste shipments over 16.6% were 

in violation of the WSR. The Contact Committee of the Supreme Audit Institutions of the European 

Union (EUROSAI) in its coordinate audit on the enforcement of the European Waste Shipment 

Regulation118 did not come up with a value of the number of illegal shipments taking place but noted 

that IMPEL had identified hundreds of illegal shipments taking place each year. In a report on global 

WEEE streams estimated by Zoetman in 2006119 it was assumed that 10-20 per cent of the total amount 

of WEEE generated in the EU was illegally exported. With just under 200 000 shipments taking place per 

year of notified wastes in the EU (see economic impacts of specific objective 1a for total numbers of 

shipments) even with a 10% level of illegality, 20 000 shipments per annum would be affected. Even at 

the bottom end of the monetised impacts of costs of individual illegal shipments taken from the 

WasteForce report above of €4 000 per illegal shipment, the total cost of illegal shipments would be 

€80 000 000.  

  Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and 

national levels and strengthen cooperation across the EU and with international partners  

Increasing global cooperation to drive up global standards has the potential to substantially improve 

environmental impacts of waste shipment. 

The environmental impact is deemed to be high, as the final outcome would be a reduction in illegal 

shipments and a better waste management. The quantitative environmental estimate calculated for 

specific objective 3a could be equally applicable to 3b, as the EU guidance to be developed as part of 

its objectives aims to address the issue of illegal waste transport and the resulting environmental 

impacts. 

117 Waste Force (2020) https://www.wasteforceproject.eu/wp-content/uploads/2020/04/D2.3-WasteForce-
Measuring-Environmental-Damage.pdf 
118 ECA (2013) 
https://www.eca.europa.eu/sites/cc/Lists/CCDocuments/other%20publications/Coordinated_audit_on_the_enforce
ment_of_the_European_Waste_Shipment_Regulation.pdf  
119 Zoetman (2006) 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

More trained staff would also result in environmental benefits thanks to intelligent inspection and 

enforcement mechanisms. 

8.5  Other impacts of measures 

An important consideration in respect to the measures foreseen under specific objective 2a concerning’ 

the stopping or restricting of export of waste outside of the EU is that with regard to trade and existing 

international agreements. Several stakeholders noted that the measures addressed under 2a appeared 

contrary to: 

• 

• 

• 

The Basel Convention 

The OECD Decision C(92)39/FINAL and 

The World Trade Organisation General Agreement on Tariffs and Trade (GATT) 

A brief examination of these issues is provided below. 

The Basel Convention 

Perhaps the easiest of the three instruments to consider with regard to the potential conflicts posed by 

measures under 2a that would restrict or prohibit movements of waste, the Basel Convention contains 

text that effectively supports the potential restriction foreseen including: 

Article 4 – General obligations  

2. Each Party shall take the appropriate measures to: 

(a) Ensure that the generation of hazardous wastes and other wastes within it is reduced to a 

minimum, taking into account social, technological and economic aspects; 

(b) Ensure the availability of adequate disposal facilities, for the environmentally sound 

management of hazardous wastes and other wastes, that shall be located, to the extent possible, 

within it, whatever the place of their disposal; 

(d) Ensure that the transboundary movement of hazardous wastes and other wastes is reduced to 

the minimum consistent with the environmentally sound and efficient management of such 

wastes, and is conducted in a manner which will protect human health and the environment against 

the adverse effects which may result from such movement; 

9. Parties shall take the appropriate measures to ensure that the transboundary movement of 

hazardous wastes and other wastes only be allowed if: 

(a) The State of export does not have the technical capacity and the necessary facilities, 

capacity or suitable disposal sites in order to dispose of the wastes in question in an 

environmentally sound and efficient manner; or 

(b) The wastes in question are required as a raw material for recycling or recovery industries in the 

State of import; or 

(c) The transboundary movement in question is in accordance with other criteria to be decided by 

the Parties, provided those criteria do not differ from the objectives of this Convention. 

11. Nothing in this Convention shall prevent a Party from imposing additional requirements that 

are consistent with the provisions of this Convention, and are in accordance with the rules of 

international law, in order better to protect human health and the environment. 

175 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

13. Parties shall undertake to review periodically the possibilities for the reduction of the amount 

and/or the pollution potential of hazardous wastes and other wastes which are exported to 

other States, in particular to developing countries. 

It appears clear under the Basel Convention that restrictions in keeping with specific objective 2a 

would not be considered as in conflict with the Convention itself. 

The OECD Decision 

The OECD Decision is less clear on the ability for Member countries to take additional measures with 

regard to restrictions of waste shipments. Indeed, one of the recitals to the Decision states 

‘RECOGNISING that the environmentally sound and economically efficient recovery of wastes may 

justify transboundary movements of wastes between Member countries’ that could be read as 

effectively stating that transboundary movements should take place in order to be environmentally 

sound and economically efficient. 

The Convention on the OECD – the governing Convention for Members states under Article 1 that ‘the 

aims of the Organisation for Economic Co-operation and Development (hereinafter called the 

"Organisation") shall be to promote policies designed… (c) to contribute to the expansion of world trade 

on a multilateral, non-discriminatory basis in accordance with international obligations.’ 

Finally, in its publication ‘International Trade and the Transition to a Circular Economy’ from 2018, the 

OECD stated that ‘Trade can provide potential opportunities towards a global circular economy by 

channelling waste and materials to destinations where there is comparative advantage in sorting and 

processing these materials. Therefore, unnecessary trade barriers such as import and export restrictions 

on waste and scrap should be avoided to the extent possible. However, these benefits should not be at 

the expense of environmental consequences.’ 

Consequently, the legal implications of the measures foreseen under specific objective 2a are unclear 

with regard to the OECD, albeit it appears that such measures are likely to be questioned by the OECD 

with adequate justification of the environmental consequences of the measure foreseen to justify 

export restrictions. This is likely to be most difficult for those measures that specifically address other 

OECD Members i.e. measures 2a4 and 2a6. 

The World Trade Organisation General Agreement on Tariffs and Trade (GATT) 

As noted in an article ‘The Waste Trade Puzzle and GATT conflict’120 ‘The GATT articles of WTO 

emerged in the international scenario as a guardian to the ideology of Free Trade and Globalization. 

However, the non- tariff trade barriers were accepted as an exception to the GATT rules, when 

conflicting interests were witnessed. One of these exceptions included the environmental issue which 

developed from the concept of "sustainable development" forming a happy union between trade, 

economy, growth, development and environment.’ 

WTO members have the right to adopt trade-related measures to protect the environment and human 

health and life as long as such measures comply with GATT rules, or fall under the exceptions to these 

120 Singhal, K. (n.d.)  

176 

 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

rules. As noted by the WTO, this right has been affirmed by panels and the Appellate Body time and 

again. However, the chapeau to Article XX that addresses general exceptions under which such 

measures can be applied notes that Specifically, the application of the measure must not constitute a 

“means of arbitrary or unjustifiable discrimination” or a “disguised restriction on international trade”.  

Two exceptions under Article XX that are of particular relevance to environmental and human health 

protection are (b) and (g) that allow WTO members to justify GATT-inconsistent measures if these are 

either necessary to protect human, animal or plant life or health, or if the measures relate to the 

conservation of exhaustible natural resources, respectively. Examples of where these exceptions have 

been applied are included on the WTO website121 including with regard to import bans on retreaded 

tyres, asbestos, fuels, and shrimp and shrimp products. It is notable, however, that these measures 

effectively restricted import and not export, as would be the case under specific objective 2a. The 

direct applicability of the findings of these cases to the measures foreseen under 2a requires more 

detailed examination that has not been performed under this specific assessment. 

121 https://www.wto.org/english/tratop_e/envir_e/envt_rules_exceptions_e.htm  

177 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

9  Conclusions: How do the policy options 

compare? 

As a reminder, the policy options and measures included in this assessment address three key 

objectives: 

1.  Ensuring a smoother functioning of the EU internal market for waste and supporting the 

transition to a circular economy 

2.  Better guaranteeing wastes shipped outside the EU are managed in an environmentally sound 

manner 

3.  Better preventing and addressing illegal shipments of waste 

As illustrated in the previous chapters, the proposed policy options and measures contained therein 

have significantly different economic, environmental and social impacts. However, for the purpose of 

comparing the effectiveness of options and measures we will first look at the options and measures 

included against each of the objectives repeated above. In the next section we will consider possible 

combinations of options and measures in a policy package that bring together some of the synergies 

between the options and measures that sit under different objectives for the purpose of the assessment 

undertaking up to this point, but which clearly contribute to more than one objective in reality. 

An overall assessment of the impacts is summarised below. Further analysis against each specific 

objective is provided in the following section. 

178 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 86 – Summary assessment of impacts of measures  

Specific objective 

Measures 

Sub-Measure 1a1: A ‘lighter touch’ 

Economic impact 

Social impact 

Environmental impact 

benefits 

Impacts 

Overall balance of costs and 

approach to make it more difficult for 

Positive - increased employment in 

Positive - Generally lower costs 

Positive - likely increases in 

Positive - Improvements for all 

Specific objective 

than the baseline.  

for recycling and easier to deny waste 

to the baseline 

Member States to refuse waste imported 

recovery and recycling in comparison 

recovery and reuse 

criteria against the baseline.  

1a – Align 

shipments with 

the waste 

hierarchy and 

existing EU 

legislation 

Specific objective 

1b – Simplification 

and reduction of 

administrative 

imported for disposal. 

Sub-Measure 1a2: Stricter provisions, 

establishing EU-wide bans of shipments 

of waste for landfilling, decreased 

Limited - The economic impacts 

Positive - increased employment in 

Limited - The environmental 

Positive - Overall Improvements 

possibility for incineration and energy 

are likely to be slightly positive 

recovery and recycling in comparison 

impacts are likely to be slightly 

expected with some limited negative 

recovery shipments and increased 

or negative. 

to the baseline 

positive or negative. 

impacts against the baseline.  

facilitation of shipments for recycling / 

reuse 

Sub-Measure 1b1: Targeted changes to 

Positive - Generally lower costs 

Limited - The social impacts are likely 

the functioning of the current framework 

than the baseline.  

to be slightly positive or negative. 

Limited 

expected with some limited negative 

Positive - Overall Improvements 

impacts against the baseline.  

Positive - Overall Improvements 

burden for intra-

Sub-Measure 1b2: Structural change to 

Positive - Generally lower costs 

EU shipments of 

the functioning of the current framework 

than the baseline.  

No impacts identified 

Limited 

expected with some limited negative 

waste 

Specific objective 

1c – harmonisation 

of interpretation, 

application and 

enforcement 

across 

Member States 

Limited - The economic impacts 

impacts against the baseline.  

Positive - Overall Improvements 

Sub-Measure 1c1: Targeted changes to 

the functioning of the current framework 

are likely to be slightly positive 

No impacts identified 

Limited 

expected with some limited negative 

Sub-Measure 1c2: Comprehensive change 

Limited - The economic impacts 

or negative. 

impacts against the baseline.  

Positive - Overall Improvements 

in relation to determining levels of 

are likely to be slightly positive 

No impacts identified 

Limited 

expected with some limited negative 

contamination 

or negative. 

impacts against the baseline.  

179 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 

Measures 

Economic impact 

Social impact 

Environmental impact 

benefits 

Impacts 

Overall balance of costs and 

Specific objective 

1d – Better adapt 

to technical 

progress and 

stimulation of 

innovation 

Set of sub-measures 1d1: Swifter 

Positive - Overall Improvements 

adaptation to technical progress and 

Limited 

No impacts identified 

No impacts identified 

expected with some limited negative 

sharing of best practices 

impacts against the baseline.  

Sub-Measure 2a1: Maintain the current 

Limited - potential savings in 

legal regime and facilitate its 

time taken to identify 

No impacts identified 

No impacts identified 

implementation 

restrictions in third countries 

Positive - Improvements expected 

against the baseline.  

Sub-Measure 2a2: Ban export of all waste 

in recovery and recycling in 

Positive - Generally lower costs 

Positive within the EU in terms of 

employment - increased employment 

Specific objective 

outside the OECD, except for third 

countries which notify the EU of their 

than the baseline with the 

exception of paper and 

cardboard waste where 

comparison to the baseline. Would 

Positive - improvements in 

have negative impacts on levels of 

protection of the environment 

Positive - Improvements for all 

criteria against the baseline.  

willingness and readiness to import such 

employment in waste management in 

expected for all wastes 

2a – stop or 

restrict export of 

waste outside of 

waste 

the EU 

economic costs are slightly 

higher than savings 

Positive - Generally lower costs 

Sub-Measure 2a3: Require that the 

than the baseline with the 

export of green-listed waste outside the 

exception of paper and 

OECD is subject to the “prior written 

cardboard waste where 

notification and consent” procedure 

economic costs are slightly 

third countries concerned but would 

also reduce the social costs of EU 

wastes in those countries. 

Positive within the EU in terms of 

employment - increased employment 

in recovery and recycling in 

Positive - improvements in 

comparison to the baseline. Would 

protection of the environment 

have negative impacts on levels of 

expected for all wastes 

Positive - Improvements for all 

criteria against the baseline.  

higher than savings 

employment in waste management in 

third countries concerned but would 

180 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 

Measures 

Economic impact 

Social impact 

Environmental impact 

benefits 

Impacts 

Overall balance of costs and 

also reduce the social costs of EU 

wastes in those countries. 

Positive within the EU in terms of 

employment - increased employment 

in recovery and recycling in 

Sub-Measure 2a4: Restrict exports to 

OECD countries 

Positive - Generally lower costs 

comparison to the baseline. Would 

Positive - improvements in 

than the baseline for all wastes 

have negative impacts on levels of 

protection of the environment 

considered 

employment in waste management in 

expected for all wastes 

Positive - Improvements for all 

criteria against the baseline.  

third countries concerned but would 

also reduce the social costs of EU 

wastes in those countries. 

Positive within the EU in terms of 

employment - increased employment 

in recovery and recycling in 

Sub-Measure 2a5 – Ban export of all 

waste outside the OECD 

Positive - Generally lower costs 

comparison to the baseline. Would 

Positive - improvements in 

than the baseline for all wastes 

have negative impacts on levels of 

protection of the environment 

considered 

employment in waste management in 

expected for all wastes 

Positive - Improvements for all 

criteria against the baseline.  

third countries concerned but would 

also reduce the social costs of EU 

wastes in those countries. 

Positive - Generally lower costs 

Positive within the EU in terms of 

than the baseline with the 

employment - increased employment 

Sub-measure 2a6: Ban all exports of 

exception of paper and 

in recovery and recycling in 

waste from the EU to third countries 

cardboard waste where 

comparison to the baseline. Would 

economic costs are slightly 

have negative impacts on levels of 

higher than savings 

employment in waste management in 

Positive - improvements in 

protection of the environment 

expected for all wastes 

Positive - Improvements for all 

criteria against the baseline.  

181 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 

Measures 

Economic impact 

Social impact 

Environmental impact 

benefits 

Impacts 

Overall balance of costs and 

third countries concerned but would 

also reduce the social costs of EU 

wastes in those countries. 

Sub-Measure 2b1: clarify the criteria 

which should be taken into consideration 

Limited - The economic impacts 

Positive - addresses socially abhorrent 

Positive - improvements in 

to assess if waste treated in 3rd 

are likely to be slightly positive 

waste treatment behaviour in third 

protection of the environment 

countries are managed in an 

or negative  

countries. 

expected for all wastes 

environmentally sound manner 

Sub-Measure 2b2: Creation of a 

dedicated body at the EU level with the 

task to monitor export of waste as well 

as their treatment in third countries 

Negative - the economic costs 

Positive - addresses socially abhorrent 

Positive - improvements in 

entail costs in relation to the 

waste treatment behaviour in third 

protection of the environment 

setting up of a dedicated body 

countries. 

expected for all wastes 

Sub-Measure 3a1: improve reporting on 

Limited - The economic impacts 

Positive - addresses social impacts of 

Positive - improvements in 

inspections and enforcement and its 

are likely to be slightly positive 

illegal shipments in countries of 

protection of the environment 

follow-up 

or negative. 

receipt. 

against illegal shipments 

Specific objective 

2b – verify ESM in 

destination 

countries 

Specific objective 

3a – Further 

strengthen 

provisions on 

Sub-Measure 3a2: Creation of a 

enforcement and 

dedicated body at the EU level with the 

inspections 

task to monitor and improve waste 

shipment enforcement 

Specific objective 

3b – Increase 

Sub-Measure 3b1: develop guidance on 

efficiency in the 

efficient inspections and enforcement 

fight against 

Negative - the economic costs 

Positive - addresses social impacts of 

Positive - improvements in 

entail costs in relation to the 

illegal shipments in countries of 

protection of the environment 

setting up of a dedicated body 

receipt. 

against illegal shipments 

Limited - The economic impacts 

Positive - addresses social impacts of 

Positive - improvements in 

are likely to be slightly positive 

illegal shipments in countries of 

protection of the environment 

or negative 

receipt. 

against illegal shipments 

Positive - The economic costs of 

application are outweighed by the 

social and environmental gains 

compared against the baseline.  

Positive - The economic costs of 

application are outweighed by the 

social and environmental gains 

compared against the baseline.  

Positive - The economic costs of 

application are outweighed by the 

social and environmental gains 

compared against the baseline.  

Positive - The economic costs of 

application are outweighed by the 

social and environmental gains 

compared against the baseline.  

Positive - The economic costs of 

application are outweighed by the 

social and environmental gains 

compared against the baseline.  

182 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 

Measures 

Economic impact 

Social impact 

Environmental impact 

benefits 

Impacts 

Overall balance of costs and 

illegal shipments 

of waste at EU 

and national levels 

and strengthen 

cooperation across 

the EU and with 

international 

partners 

Sub-Measure 3b2: Enhancing cooperation 

Limited - The economic impacts 

Positive - addresses social impacts of 

Positive - improvements in 

with inspection and enforcement bodies 

are likely to be slightly positive 

illegal shipments in countries of 

protection of the environment 

beyond the EU’s borders 

or negative. 

receipt. 

against illegal shipments 

Positive - The economic costs of 

application are outweighed by the 

social and environmental gains 

compared against the baseline.  

No impact identified 

Positive impact overall 

Negative impact overall 

Mix of positive and negative impacts 

183 

 
 
 
 
 
  
 
 
 
 
  
 
 
 
 
  
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

9.1  Objective 1 – Ensuring a smoother functioning of the EU internal market 

for waste and supporting the transition to a circular economy 

Specific objective 1a – Align shipments with the waste hierarchy and existing EU legislation -  

The measures addressing stricter provisions for energy recovery and landfilling are generally perceived 

to be those with the least effect in aligning shipments with the waste hierarchy and existing EU 

legislation. This is exacerbated by the fact that landfilling, incineration and R1 activities are likely to 

remain a necessity for the foreseeable future for those wastes that cannot be treated further up the 

waste hierarchy. Restrictions on shipments across the EU may be counterproductive to those Member 

States that have limited capacity within their own facilities to treat waste at lower levels in the waste 

hierarchy, requiring them to set up their own facilities rather than using the capacity available in other 

Member States. Additionally, provisions already exist for Member States to apply their own prohibitions 

on waste imports or exports for landfill and the majority of stakeholders that have provided opinion on 

these measures have been unsupportive. 

Reducing the administrative burden and other costs linked with notification procedures for waste 

shipped for reuse or recycling appears to be generally well supported by stakeholders, in particular 

from the business community, offering the opportunity to reduce the administrative burden associated 

with the present consenting approach. As noted in Error! Reference source not found. below, using 

data on shipments from Eurostat’s env_wasship database, shipments for recovery or mix (a mix of 

recovery and disposal) already represent the largest share of notified shipments made within the EU 

and the potential administrative savings of a improving and streamlining procedures for such shipments 

would potentially encourage more wastes currently being addressed under disposal or R1 activities for 

which the current procedures would remain to be sent for reuse and recovery instead. Predictions for 

how these shipments may change has been made using a linear regression based on 2010-2018 data. 

This would particularly be the case if this approach also reduced the time necessary for approval of a 

shipment to take place. However, as highlighted in statements made by some stakeholders, ESM should 

remain ensured at destination. Facilitating shipments for recycling only within the EU should ensure 

that this is the case as a result of the application of other EU law when it comes to the management of 

those wastes in the country of destination.  

184 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 51 Forecast of notified waste shipments within the EU under the baseline for the period 2010-2030 

Specific objective 1b – simplification and reduction of administrative burden for intra-EU shipments 

of waste 

The savings (~€44M/annum) gained in comparison to the cost of implementing an EDI (€480k setup and 

maintenance of €230k for the first two years then approximately €113k/annum from then on) makes the 

EDI an obvious measure to implement under all circumstances. 

With regard to the use of a financial guarantee, two approaches are suggested in this report  

• 

– a common fee being applied to all shipments to fulfil a national account that can be used to 

address shipments to which fees are required as a result of costs required to be covered for 

certain shipments. As the provisions in relation to financial guarantees are applied to less than 

5 in every 1000 shipments, with the average fine for the most expensive Member State 

(Belgium) being €38 000 and six shipments being subject to such fines in total in Belgium per 

annum, a fee of approximately €355 per shipment for all shipments made would address the 

costs concerned. 

• 

A common financial guarantee value being applied of approximately €40k per shipment. 

Neither approach would build on the polluter pays principle, particularly in the case of the application 

of a fixed fee to replace the financial guarantee for all shipments. However, the value of money’s held 

in financial guarantees could effectively be reduced to approximately 30% of present values, allowing 

the use of the freed money for other purposes. 

For the financial guarantee provisions to be simplified either approach could be enacted, with the 

second providing a greater deterrence than the first. The entire abandonment of the financial 

guarantee would be unworkable, one important reason it being obliged under the Basel Convention, 

which the WSR implements. 

185 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific objective 1c – harmonisation of interpretation, application and enforcement across 

Member States 

Two measures foreseen under this objective are considered to be relatively difficult to implement in 

legislation in practice – introducing provisions within the Regulation on the principle of mutual 

recognition in relation to categorisation of waste as hazardous or not and for determining when a 

commodity is a waste or not. Instead, further guidance appears to be the preferred approach to address 

this issue for stakeholders (although it should be noted that business was generally more in favour of 

mutual recognition being included within the Regulation). 

The defining of contamination thresholds is clearly supported by a majority of stakeholders albeit it is 

admittedly a difficult issue to reach agreement on as reflected by comments from stakeholders during 

the project workshop. It is apparent that setting thresholds within the Regulation is likely to prove 

impossible. However, the development of thresholds through implementing acts or provide more 

guidance on the matter are considered to be most effective approaches to harmonising this matter 

across the EU. 

Finally, with regard to the setting up of a platform to share experiences, there is support for such a 

platform, albeit the preferred approach signalled by a number of stakeholders is to use existing 

platforms rather than to create a new one, using the likes of IMPEL or the Waste Correspondents 

Meeting. This is also the case for the sharing of innovate practices considered under specific objective 

1d below. 

Specific objective 1d – Better adapt to technical progress and stimulation of innovation 

The use of delegated or implementing acts with regard to matters such as waste classification, 

notification procedures and related annexes make sense from the administrative perspective of 

alternatively having to use the ordinary legislative procedure to amend the Regulation itself to address 

these matters. The need to consult on the contents of delegated acts with all relevant stakeholders was 

also raised as an important matter given the potential impacts on operators and Member State 

competent authorities resulting from the changes made through such acts. 

9.2  Objective 2 – Better guarantee waste shipped outside the EU are managed 

in an environmentally sound manner 

Specific objective 2a – stop or restrict export of waste outside of the EU 

Measure 2a1 may offer some improvement of the current approach to dealing with shipments of wastes 

to third countries. However, the current disproportionate workload for the Commission and the 

unwieldiness of the process to update the legal basis for enforcement with relevant information will 

remain largely unchanged. Moreover, it fundamentally does not address the issue of ESM in third 

countries in a better way than the present WSR. 

Measure 2a2 carries a number of costs and benefits. Examining the monetised costs and benefits 

together (economic and environmental externalities) the following figures are identified. 

186 

 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 87 Balance of monetised costs and benefits for measure 2a2  

Furthermore, depending on the percentage of EU waste retained, additional employment within the EU 

related to the management of these wastes would likely increase between 10 000 and 40 000 FTEs. ESM 

would be much more likely to be achieved in comparison to the status quo, although less so in 

comparison to measure 2a5 and 2a6 for non-OECD third countries. 

Measure 2a3 carries similar costs and benefits to 2a2, with the additional cost related to the 

application of prior informed consent procedures for all exports. The combination of costs and benefits 

results in the following benefits being obtained for all monetised elements based on 20 tonne shipments 

and the application of electronic PIC (given the overwhelming support for an EDI under objective 1). 

Table 88 Balance of monetised costs and benefits for measure 2a3 

187 

EUR value of materials retained within the EU forecast for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal592,723,665379,131,754468,958,828626,175,088367,292,381462,669,492631,044,672348,429,377449,356,524628,890,625322,542,740429,019,923Glass7,207,5026,161,9225,971,0925,758,3525,523,7035,267,1444,988,6754,688,2974,366,0094,021,8123,655,7043,267,687Non-ferrous metals915,250,8231,047,205,5871,133,452,1011,220,051,3391,307,003,3011,394,307,9871,481,965,3961,569,975,5291,658,338,3861,747,053,9671,836,122,2721,925,543,301Paper and cardboard546,772,297588,677,074595,860,200602,290,522607,968,038612,892,749617,064,655620,483,756623,150,051625,063,541626,224,226626,632,105Plastic206,946,674208,111,188209,092,268209,889,915210,504,128210,934,907211,182,253211,246,166211,126,644210,823,689210,337,301209,667,479Textiles159,843,724238,288,752250,326,960262,469,333274,715,870287,066,572299,521,439312,080,471324,743,668337,511,030350,382,556363,358,248Total2,428,744,6852,467,576,2772,663,661,4502,926,634,5492,773,007,4212,973,138,8523,245,767,0923,066,903,5963,271,081,2833,553,364,6643,349,264,7993,557,488,744EUR value of materials retained within the EU forecast for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal469,423,524310,925,791378,125,045472,031,049331,695,766406,953,326500,414,633314,916,880394,334,458493,162,808291,591,561375,169,157Glass5,725,5654,908,1984,730,6504,532,8914,314,9224,076,7423,818,3523,539,7513,240,9402,921,9182,582,6852,223,242Non-ferrous metals658,019,726744,909,794800,098,964855,409,549910,841,548966,394,9631,022,069,7911,077,866,0351,133,783,6931,189,822,7671,245,983,2541,302,265,157Paper and cardboard585,537,289625,794,416631,361,941636,398,682640,904,640644,879,814648,324,204651,237,810653,620,633655,472,673656,793,928657,584,400Plastic213,691,870214,913,400215,955,161216,817,155217,499,380218,001,837218,324,527218,467,448218,430,601218,213,986217,817,603217,241,451Textiles141,283,058195,042,433204,543,308214,124,279223,785,344233,526,505243,347,762253,249,113263,230,559273,292,101283,433,738293,655,470Total2,073,681,0312,096,494,0312,234,815,0692,399,313,6042,329,041,6002,473,833,1872,636,299,2682,519,277,0372,666,640,8842,832,886,2512,698,202,7692,848,138,876EUR value of materials retained within the EU forecast for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal186,804,208123,614,376150,399,025188,103,135131,942,199161,946,270199,490,069125,266,279156,930,458196,638,641115,987,587149,311,874Glass2,283,3211,957,2771,886,6351,807,9511,721,2251,626,4571,523,6461,412,7931,293,8991,166,9621,031,982888,961Non-ferrous metals262,915,357297,677,986319,767,766341,906,808364,095,110386,332,674408,619,499430,955,586453,340,933475,775,542498,259,412520,792,543Paper and cardboard224,523,716240,086,343242,279,206244,261,023246,031,795247,591,521248,940,201250,077,836251,004,424251,719,968252,224,465252,517,917Plastic73,591,11174,009,85074,365,70374,658,67074,888,75175,055,94675,160,25675,201,68075,180,21975,095,87174,948,63874,738,519Textiles52,738,81674,083,56077,723,52281,394,36485,096,08688,828,68892,592,17196,386,533100,211,776104,067,898107,954,901111,872,784Total802,856,530811,429,392866,421,857932,131,951903,775,166961,381,5571,026,325,842979,300,7071,037,961,7081,104,464,8811,050,406,9851,110,122,597YearYearYearBalance of costs and benefitsEUR value of materials retained within the EU forecast for 75% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal590,853,552377,667,092467,309,998624,800,824365,866,146461,051,533629,735,316347,072,184447,800,052627,676,792321,285,206427,555,555Glass7,175,7286,134,3015,945,2085,734,3995,501,8745,247,6324,971,6744,674,0004,354,6104,013,5033,650,6813,266,142Non-ferrous metals914,684,0301,046,651,5841,132,925,4411,219,553,3691,306,535,3691,393,871,4391,481,561,5801,569,605,7931,658,004,0761,746,756,4301,835,862,8551,925,323,351Paper and cardboard544,574,226586,356,473593,531,855599,954,719605,625,066610,542,895614,708,206618,120,999620,781,275622,689,032623,844,273624,246,995Plastic206,465,445207,627,130208,605,746209,401,295210,013,774210,443,186210,689,529210,752,804210,633,010210,330,149209,844,219209,175,220Textiles159,209,926237,628,255249,639,530261,754,775273,973,992286,297,178298,724,335311,255,462323,890,560336,629,628349,472,667362,419,676Total2,422,962,9072,462,064,8352,657,957,7782,921,199,3822,767,516,2202,967,453,8633,240,390,6403,061,481,2423,265,463,5833,548,095,5353,343,959,9003,551,986,939EUR value of materials retained within the EU forecast for 50% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal467,553,411309,461,129376,476,215470,656,785330,269,531405,335,367499,105,276313,559,688392,777,986491,948,975290,334,027373,704,788Glass5,693,7924,880,5774,704,7664,508,9384,293,0934,057,2303,801,3513,525,4543,229,5402,913,6092,577,6612,221,696Non-ferrous metals657,452,933744,355,790799,572,304854,911,579910,373,616965,958,4151,021,665,9761,077,496,2981,133,449,3831,189,525,2291,245,723,8371,302,045,207Paper and cardboard583,339,218623,473,816629,033,596634,062,880638,561,667642,529,959645,967,754648,875,054651,251,857653,098,164654,413,975655,199,290Plastic213,210,641214,429,342215,468,639216,328,534217,009,027217,510,116217,831,802217,974,086217,936,967217,720,445217,324,520216,749,192Textiles140,649,260194,381,935203,855,878213,409,722223,043,466232,757,111242,550,657252,424,104262,377,451272,410,700282,523,848292,716,898Total2,067,899,2542,090,982,5892,229,111,3982,393,878,4382,323,550,3992,468,148,1982,630,922,8172,513,854,6842,661,023,1852,827,617,1222,692,897,8702,842,637,072EUR value of materials retained within the EU forecast for 20% of formerly exported wastes retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal184,934,095122,149,715148,750,195186,728,872130,515,964160,328,311198,180,713123,909,086155,373,986195,424,808114,730,053147,847,505Glass2,251,5481,929,6561,860,7511,783,9981,699,3961,606,9451,506,6451,398,4971,282,4991,158,6531,026,959887,415Non-ferrous metals262,348,564297,123,982319,241,106341,408,838363,627,178385,896,127408,215,684430,585,849453,006,622475,478,004497,999,995520,572,593Paper and cardboard222,325,644237,765,743239,950,861241,925,221243,688,823245,241,666246,583,752247,715,079248,635,648249,345,459249,844,512250,132,807Plastic73,109,88373,525,79273,879,18174,170,04974,398,39774,564,22574,667,53274,708,31974,686,58574,602,33074,455,55674,246,260Textiles52,105,01973,423,06277,036,09280,679,80784,354,20888,059,29491,795,06695,561,52499,358,668103,186,497107,045,012110,934,213Total797,074,752805,917,949860,718,185926,696,785898,283,965955,696,5681,020,949,391973,878,3531,032,344,0091,099,195,7521,045,102,0851,104,620,793Balance of costs and benefitsYearYearYear 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Included in the benefits would be reductions in greenhouse gas emissions. Were 20% of wastes to be 

retained approximately 218 000 tonnes CO2-eq emission would be saved, with the figure climbing to 

817 000 tonnes with 75% of wastes retained. Depending on the percentage of EU waste retained, 

additional employment within the EU related to the management of these wastes would likely increase 

between 10 000 and 40 000 FTEs (but it must be noted that this takes into account additional staff 

required to apply the PIC provisions that are 200 FTEs as a maximum for 75% of wastes retained that 

would generate additional employment in comparison to 2a2, but where the overall objective for the 

review is to reduce burden related to the notification procedure).  

Measure 2a4 is generally more cost effective in terms of the total benefits than measures 2a2 and 2a3. 

The combination of costs and benefits results in the following benefits being obtained for all monetised 

elements based on 20 tonne shipments and the application of electronic PIC (given the overwhelming 

support for an EDI under objective 1). 

Table 89 Balance of monetised costs and benefits for measure 2a4  

For all wastes the benefits outweigh the costs. Included in this assessment are potential CO2-eq 

greenhouse gas emissions of between 59 000 and 223 000 tonnes from waste management in the EU in 

comparison to third countries. In terms of employment benefits, between 24 000 and 92 000 jobs would 

likely be generated based on the rate of diversion of the wastes concerned. The generally higher levels 

of ESM of waste in OECD countries in comparison to non-OECD third countries also means that these 

controls are likely to have less benefit per tonne of waste than measures 2a2 and 2a3. 

Measure 2a5 has a good level of certainty of ESM being employed by effectively preventing the shipping 

of EU waste outside of the EU to non-OECD countries, with the understanding that all Member States 

are currently obliged to employ ESM under the existing EU acquis and that the OECD Decision offers a 

better level of guarantee of ESM than the Basel Convention on its own. The following overall benefits 

have been monetised for measure 2a5. 

188 

Total EUR benefits EU forecast for 75% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal1,487,578,1071,773,124,2341,742,375,8191,654,256,7591,975,105,2381,938,641,7831,840,107,1322,184,778,5132,142,600,0172,033,649,7772,402,144,0582,354,250,523Glass37,899,84334,530,54135,971,81437,439,04638,932,23740,451,38841,996,49943,567,56845,164,59846,787,58648,436,53450,111,442Non-ferrous metals2,186,706,3002,190,265,1802,240,022,0172,289,471,4592,338,613,5052,387,448,1562,435,975,4122,484,195,2732,532,107,7382,579,712,8072,627,010,4822,674,000,761Paper and cardboard160,592,909185,899,559202,193,025219,245,273237,056,303255,626,114274,954,708295,042,084315,888,242337,493,181359,856,903382,979,406Plastic131,068,750138,305,528145,734,346153,355,203161,168,100169,173,036177,370,011185,759,026194,340,080203,113,174212,078,307221,235,480Textiles22,586,83330,636,89830,707,12730,669,15030,522,96730,268,57729,905,98029,435,17828,856,16828,168,95327,373,53126,469,902Total4,026,432,7424,352,761,9414,397,004,1484,384,436,8904,781,398,3494,821,609,0544,800,309,7435,222,777,6415,258,956,8435,228,925,4795,676,899,8165,709,047,514Total EUR benefits EU forecast for 50% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal842,410,7291,014,642,582992,811,654919,899,3531,128,776,4731,103,362,1611,022,568,6921,247,227,1871,218,229,4921,129,554,8561,369,994,7271,337,413,647Glass30,637,85429,304,67331,279,95233,304,66935,378,82337,502,41339,675,44141,897,90544,169,80646,491,14548,861,92051,282,132Non-ferrous metals1,476,605,0541,480,592,0471,513,529,8061,546,238,4801,578,718,0671,610,968,5691,642,989,9861,674,782,3171,706,345,5621,737,679,7211,768,784,7941,799,660,782Paper and cardboard115,666,648132,135,947144,101,446156,613,421169,671,872183,276,800197,428,203212,126,083227,370,439243,161,272259,498,580276,382,365Plastic54,562,19957,334,11460,169,23863,067,33566,028,40569,052,44772,139,46375,289,45178,502,41281,778,34685,117,25388,519,132Textiles243,336,225271,729,482277,810,011296,615,022306,427,604312,413,365332,273,827342,314,945348,205,936369,121,850379,391,504385,187,726Total2,763,218,7092,985,738,8453,019,702,1083,015,738,2803,285,001,2443,316,575,7553,307,075,6123,593,637,8883,622,823,6473,607,787,1893,911,648,7773,938,445,784Total EUR benefits EU forecast for 20% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal335,853,401404,724,245396,365,836367,312,515451,183,762441,435,167409,247,591499,467,542488,328,760453,006,930549,575,584537,046,616Glass19,736,59719,855,25820,553,27721,261,47221,979,84422,708,39123,447,11524,196,01524,955,09125,724,34326,503,77127,293,376Non-ferrous metals593,967,511595,390,831608,983,645622,500,304635,940,807649,305,154662,593,346675,805,382688,941,262702,000,987714,984,556727,891,970Paper and cardboard32,817,36538,554,84142,483,26346,604,13050,917,44255,423,20060,121,40265,012,05070,095,14475,370,68280,838,66686,499,095Plastic112,997,610123,308,715126,847,724135,530,325140,669,754144,332,253153,598,432158,990,672162,776,661172,626,417178,271,469182,180,948Textiles4,376,8266,521,2686,542,0666,538,4166,510,3216,457,7796,380,7916,279,3566,153,4756,003,1485,828,3745,629,155Total1,099,749,3091,188,355,1591,201,775,8111,199,747,1621,307,201,9301,319,661,9431,315,388,6771,429,751,0171,441,250,3931,434,732,5081,556,002,4211,566,541,159YearYearYear 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Table 90 Balance of monetised costs and benefits for measure 2a5 

For all wastes the benefits outweigh the costs. Included in this assessment are potential CO2-eq 

greenhouse gas emissions of approximately 1.35M tonnes from waste management in the EU in 

comparison to non-OECD third countries. In terms of employment benefits, approximately 54 000 jobs 

would likely be generated based on the rate of diversion of the wastes concerned. 

Finally, measure 2a6 provides the greatest level of certainty of ESM being employed by effectively 

preventing the shipping of EU waste outside of the EU, with the understanding that all Member States 

are currently obliged to employ ESM under the existing EU acquis. The following overall benefits have 

been monetised for measure 2a6. 

Table 91 Balance of monetised costs and benefits for measure 2a6  

With regard to employment stemming from measure 2a6, approximately 178 000 jobs would be 

generated within the EU through its application. Included in this assessment are potential CO2-eq 

greenhouse gas emissions of approximately 2.2M tonnes from waste management in the EU in 

comparison to third countries. 

Specific objective 2b – verify ESM in destination countries 

Two measures are foreseen under this objective.  

Clarification of the criteria to be taken into consideration to assess if waste treated in third countries 

are managed in an environmentally sound manner within the Regulation would helpfully build on 

experience in implementing the Regulation to date by clarifying or further developing the relevant 

provisions. Notably, to link this with measure 2a2 where non-OECD countries outside the EU would have 

to demonstrate their ability to ensure ESM according to a set of such criteria, would result in an 

enhanced potential to ensure ESM in those countries that would still accept certain green listed waste 

streams.  

The creation of a dedicated body at the EU level tasked with verifying the export of waste as well as its 

treatment in third countries in those cases where suspicion arose on the actual destiny or treatment 

under equivalent conditions in the receiving countries, would provide a more reliable way of confirming 

that ESM is being employed in practice. However, the level of support for such a body has been found 

to be split with stakeholders and the true effectiveness of such a body would depend upon the extent 

to which third countries would allow any EU body to inspect foreign waste treatment sites. The creation 

189 

Total EUR value for 100% retained within EUWaste type201920202021202220232024202520262027202820292030Ferrous metal934,021,039618,071,880751,995,124940,515,677599,332,882741,236,819942,020,173568,876,122718,760,751931,806,907526,701,599684,566,920Glass12,051,87510,338,6269,950,6869,518,6699,042,5728,522,3987,958,1467,349,8156,697,4066,000,9185,260,3534,475,709Non-ferrous metals1,263,893,8881,438,850,6701,551,744,6221,665,005,3421,778,632,8291,892,627,0842,006,988,1062,121,715,8962,236,810,4532,352,271,7782,468,099,8702,584,294,730Paper and cardboard897,957,000963,246,667973,419,386982,566,265990,687,306997,782,5081,003,851,8711,008,895,3951,012,913,0801,015,904,9261,017,870,9331,018,811,102Plastic312,912,537314,682,642316,180,098317,404,903318,357,059319,036,565319,443,422319,577,629319,439,187319,028,095318,344,353317,387,961Textiles261,833,889368,479,242386,600,005404,874,598423,303,021441,885,274460,621,357479,511,269498,555,011517,752,584537,103,986556,609,218Total3,682,670,2283,713,669,7283,989,889,9214,319,885,4544,119,355,6704,401,090,6484,740,883,0744,505,926,1264,793,175,8885,142,765,2074,873,381,0945,166,145,641YearWaste type201920202021202220232024202520262027202820292030Ferrous metal3,178,216,6563,273,752,1823,369,289,0353,464,825,8893,560,362,7423,655,899,5953,751,436,4493,846,973,3023,942,510,1564,038,047,0094,133,583,8634,229,120,716Glass69,297,90462,908,91564,815,43566,721,95568,628,47670,534,99672,441,51674,348,03776,254,55778,161,07780,067,59881,974,118Non-ferrous metals4,189,919,0754,370,562,2954,551,205,5154,731,848,7354,912,491,9555,093,135,1755,273,778,3965,454,421,6165,635,064,8365,815,708,0565,996,351,2766,176,994,496Paper and cardboard1,141,192,3301,242,766,6541,275,704,1831,308,641,7121,341,579,2401,374,516,7691,407,454,2981,440,391,8261,473,329,3551,506,266,8841,539,204,4131,572,141,941Plastic498,900,647510,947,816522,994,986535,042,156547,089,325559,136,495571,183,664583,230,834595,278,003607,325,173619,372,343631,419,512Textiles295,517,625412,901,258431,111,175449,321,093467,531,010485,740,928503,950,846522,160,763540,370,681558,580,599576,790,516595,000,434Total9,373,044,2379,873,839,11910,215,120,32910,556,401,53910,897,682,74911,238,963,95911,580,245,16911,921,526,37812,262,807,58812,604,088,79812,945,370,00813,286,651,218Year 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

of a dedicated EU body would require a total annual cost of €16 million, 61 members of staff and an 

additional start-up cost of €1.6 million in the first two years46. Given the EUR value of waste shipments 

currently taking place to third countries of over €14 billion per annum, the total cost of a body 

representing 0.1% of total export value appears relatively small. It could be more cost efficient to make 

use of existing EU investigative bodies like OLAF122 and where needed refine their existing tools and 

competences (see also 8.1.3) 

9.3  Objective 3 – Better prevent and address illegal shipments of waste 

Specific objective 3a – Further strengthen provisions on enforcement and inspections 

A mandate for the Commission to assess the national or regional inspection plans that are already 

required to be drawn up and that are made available online to the Commission, would have limited 

economic cost given that the reports themselves are already required to be  

The creation of a dedicated body/forum at the EU level with the task to monitor and improve 

cooperation between EU Member States on waste shipment enforcement, by sharing best practices, 

intelligence, and activities ongoing can be considered in the context of measure regarding a body 

identified under specific objective 2b above. In this context, it seems more cost effective to opt for a 

forum of exports on enforcement to be established. Although it is considered by stakeholders that the 

most effective route to monitoring and improving cooperation would be to use the IMPEL network or the 

Waste Correspondents to take on this role, there are significant disadvantages to this approach: IMPEL 

is a project driven network that has no formal mandate on EU level, and the Correspondents at the 

moment rather gather administration experts and devote limited time to enforcement discussions, such 

as the above mentioned inspection plans and possible streamlining thereof. Additional funding would be 

required for this to be undertaken, but this would be less expensive than setting up a dedicated EU 

level body that has on the ground enforcement in its core competences. 

Specific objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and 

national levels and strengthen cooperation across the EU and with international partners 

Good quality guidance documents can help competent authorities improve practices and address issues 

of governance and given the issues of consistency identified under objective 1 and the need to address 

illegal shipments under this specific objective it appears obvious that additional guidance would be 

welcome by stakeholders on a number of topics. At the moment, guidance is mostly developed by 

existing networks including IMPEL and the waste shipment correspondents. As indicated in relation to 

the economic impacts of this measure, the costs of development of guidance are relatively limited. 

However, the timescale required to develop guidance – up to four years in the case of guidance 

developed by IMPEL – means that the timely nature of this measure can be called into question and is 

unlikely to resolve efficiency of the fight against illegal shipments alone. As regards development of 

guidance by the waste shipment correspondents, at times the result of often lengthy deliberations 

among correspondents, that need consensus to come to an agreement, may not be the clearest and 

strongest guidance possible. In this regard, it is worth referring to the possible measure to delegate 

some of this work to implementing act (see 1d). 

122 The European Anti-Fraud Agency 

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Concerning the enhancement of cooperation with inspection and enforcement bodies beyond the EUs 

borders, mechanisms already exist via the Basel Convention Trust Fund, IMPEL and the ENFORCE 

network to secure such cooperation. However, the effectiveness of these networks could be further 

enhanced by ensuring sufficient funding and resources from the EU are fed into them. The creation of a 

complementary forum or body on the global level could be considered as unnecessary in light of the 

existing networks and may prove difficult to be convincing to a sufficient number of third countries to 

ensure their participation. 

191 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Annex 1 Open Public Consultation Results 

Overview of respondents 

A 12-week public consultation related to the Waste Shipment Regulation (WSR) Impact Assessment was 

held between 7 May and 30 July 2020. The public consultation was split into two main sections. The 

first section contained general questions on the policy objectives of the review of the WSR and how to 

pursue them. The second section asked for more detailed views from stakeholders with a more in-depth 

knowledge of the WSR. The questionnaire was hosted on the EU Survey tool.  

The consultation elicited a total of 295 responses. As part of the initial screening of responses a number 

of stakeholders were re-categorised as a result of the nature of their organisation. This led to some 

business associations being categorised as such and not as NGOs as originally registered, environmental 

organisations being re-categorized as NGOs or public authorities and those in the ‘other category’ being 

redistributed to their correct delineation. 

The consequent breakdown of stakeholder responses by respondent type is provided below.  

Table 0.1 Type of respondents involved in the consultation 

Type of respondent 

Number of respondents 

Percentage of respondents 

Company/business organisation123 

116 

Business association124 

EU citizen 

Public authority 

77 

47 

36 

Non-governmental organisation 

17 

(NGO)125 

Trade union 

Academic/research institution 

Total 

1 

1 

295 

39% 

26% 

16% 

12% 

6% 

>0% 

>0% 

100% 

Responses were received from respondents in most Member States. The majority of these were received 

from Belgium (64), followed by Germany (45), Italy (38) and France (25). A detailed overview of the 

responses received by country is shown in the table below.  

123 Individual company or business 
124 Business trade associations 
125 Environmental non-governmental organisations 

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Table 0.2   Responses received by country 

Type of respondent 

Number of respondents 

Percentage of respondents 

Belgium 

Germany 

Italy 

France 

Netherlands 

Spain 

Austria 

Sweden 

Portugal 

United Kingdom 

Finland 

Greece 

Romania 

Bulgaria 

Lithuania 

Luxembourg 

Ireland 

Norway 

Poland 

Denmark 

Hungary 

Malta 

Slovakia 

Slovenia 

United States 

Andorra 

Czechia 

Estonia 

French Guiana 

Indonesia 

Switzerland 

Grand Total 

22% 

15% 

13% 

8% 

6% 

5% 

4% 

3% 

3% 

2% 

2% 

2% 

2% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

1% 

>0% 

>0% 

>0% 

>0% 

>0% 

>0% 

100% 

64 

45 

38 

25 

18 

14 

12 

10 

8 

7 

5 

5 

5 

4 

4 

4 

3 

3 

3 

2 

2 

2 

2 

2 

2 

1 

1 

1 

1 

1 

1 

295 

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Results 

The section below provides an overview of headline results from the online survey carried out so far, 

per specific objective under the study.  

Section 1 – General public 

Section 1 of the questionnaire addressed the three main objectives being addressed, with a number of 

questions being addressed against each objective. A summary of the responses is provided in the 

following section. 

First policy objective: the WSR should support the transition to a circular economy in the EU more 

effectively 

Questions under the first objective addressed five main sub-objectives that are addressed in the order 

in which the questions were posed in the questionnaire. 

Firstly, the link with the circular economy was addressed as shown in Figure 52 below. 

Figure 52 Responses to the statement ‘a review of the Waste Shipment Regulation should seek to more 
effectively support the transition to a circular economy 

The vast majority of respondents agreed or strongly agreed with the need for the WSR to support the 

transition more effectively to a circular economy. 

195 

050100150200250Strongly disagreeDisagreeAgreeStrongly agreeNo opinionNumber of responsesResponseA review of the Waste Shipment Regulation should seek to more effectively support the transition to a circular economyAcademic/research institutionBusiness associationCompany/business organisationEU citizenNon-governmental organisation (NGO)Public authorityTrade union 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Secondly, stakeholders were asked whether the review of the Regulation should seek to make the 

movement of waste easier within the EU when destined for preparation for reuse or recycling. 

Figure 53 Responses to the statement that a review of the Waste Shipment Regulation should seek to make the 
movement of waste easier within the EU when destined for preparation for reuse or for recycling 

As for the statement on the circular economy, a vast majority of respondents either agree or strongly 

agree with the statement. 

Thirdly, stakeholders were asked whether a review of the WSR should seek to make movements more 

difficult within the EU when destined for incineration with energy recovery. In contrast to the first two 

statements, a majority of stakeholders either strongly disagreed or disagreed with the statement as 

shown in Figure 54 below. 

196 

020406080100120140160180200Strongly disagreeDisagreeAgreeStrongly agreeNo opinionNumber of responsesResponseA review of the Waste Shipment Regulation should seek to make the movement of waste easier within the EU when destined for preparation for reuse or for recyclingAcademic/research institutionBusiness associationCompany/business organisationEU citizenNon-governmental organisation (NGO)Public authorityTrade union 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 54 Responses to the statement ‘A review of the Waste Shipment Regulation should seek to make the 
movement of waste more difficult within the EU when destined for incineration with energy recovery’ 

It should be noted that there is a general split in the stakeholders in responding to this statement. 

Company and Business Organisations and Business Associations represent the stakeholder groups most 

opposed to the statement. Conversely, NGOs and most EU citizens that responded either agree or 

strongly agree with the statement. Public authorities show split views on this matter. There are also a 

significant number of stakeholders of all categories that stated they had no opinion. 

Fourthly, stakeholders were asked whether the WSR should seek to make the movement of waste more 

difficult or even impossible within the EU when destined for disposal (e.g. incineration without energy 

recovery, landfilling). The results are shown in  

197 

0102030405060708090Strongly disagreeDisagreeAgreeStrongly agreeNo opinionNumbe of responsesResponseA review of the Waste Shipment Regulation should seek to make the movement of waste more difficult within the EU when destined for incineration with energy recoveryAcademic/research institutionBusiness associationCompany/business organisationEU citizenNon-governmental organisation (NGO)Public authorityTrade union 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 55 below, with a split in opinion – the majority of respondents indicating that they agree or 

strongly agree with the statement, but still with a large number of mainly industry related stakeholders 

disagreeing or disagreeing strongly with the statement. 

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Figure 55 Responses to the statement A review of the Waste Shipment Regulation should seek to make the 
movement of waste more difficult or even impossible within the EU when destined for disposal (e.g. 
incineration without energy recovery, landfilling) 

Finally, under the first objective, stakeholders were asked whether the review of the Regulation should 

seek to improve the efficiency of the procedures and administration for both competent authorities and 

companies shipping waste between Member States. As shown in below, the vast majority of 

stakeholders strongly agreed with the statement, with the remainder or respondents agreeing with the 

statement. 

199 

0102030405060708090100Strongly disagreeDisagreeAgreeStrongly agreeNo opinionNumber of responsesResponseA review of the Waste Shipment Regulation should seek to make the movement of waste more difficult or even impossible within the EU when destined for disposal (e.g. incineration without energy recovery, landfilling)Academic/research institutionBusiness associationCompany/business organisationEU citizenNon-governmental organisation (NGO)Public authorityTrade union 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 56 Responses to the statement ‘A review of the Waste Shipment Regulation should seek to improve the 
efficiency of the procedures and administration for both competent authorities and companies shipping waste 
between Member States’ 

Second policy objective: Restrict the export of EU waste to third countries 

The second policy objective against which stakeholders were provided with a number of statements to 

indicate their level of agreement concerned the restriction of export of EU waste the third countries. 

Stakeholders were posed with six statements against different restriction scenarios. The results of the 

consultation of stakeholders against these statements are provided below. 

The first statement concerned whether the review should seek to keep the current EU rules on export 

of waste unchanged but increase their enforcement. The responses are summarised below. 

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Figure 57 Responses to the statement A review of the Waste Shipment Regulation should seek to keep the 
current EU rules on export of waste unchanged but increase their enforcement 

A split in responses by stakeholder type is notable. NGOs and some industry stakeholders – notably 

those involved in the processing of wastes as secondary raw materials, disagreed with the statement 

that the current rules should be maintained and their enforcement increased. The industry stakeholders 

concerned frequently noted in their later responses to other questions the need for the WSR to more 

effectively support the circular economy and the need to simplify the WSR to this effect that could 

account for some of the level of disagreement in this stakeholder category. However, a majority of 

stakeholders agreed or strongly agreed with the statement. 

Next, stakeholders were asked whether, regarding export of waste to non-EU OECD countries the EU 

should ban the export of waste to such countries.  

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Figure 58 Responses to the statement Regarding export of waste to non-EU OECD countries ban the export of 
waste to non-EU OECD countries  

Here, a reversal in the trend from the previous statement can be seen, which is unsurprising given that 

those that had requested to maintain the present system are unlikely to support the kind of change 

envisaged by this statement. NGOs and citizens almost universally agreed or strongly agreed with the 

statement. It also likely reflects the fact that member countries of the OECD are generally perceived to 

apply waste treatment measures more akin to those of the EU than non-OECD countries. 

Thirdly, stakeholders were asked to which extent they agreed with the statement ‘Regarding export of 

waste to non-EU OECD countries the EU should ban the export of waste to non-EU OECD countries, 

unless there is clear evidence that it will be processed in an environmentally sound manner’. In 

contrast to the previous statement, this statement includes a proviso concerning environmentally sound 

management of wastes in the country of destination. This important qualifier results in a generally 

higher level of support compared to the previous statement as shown in  

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Figure 59 below. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 59 Responses to the statement ‘Regarding export of waste to non-EU OECD countries Ban the export of 
waste to non-EU OECD countries, unless there is clear evidence that it will be processed in an environmentally 
sound manner 

Next, stakeholders were asked their opinion with regard to the statement ‘Regarding export of waste to 

non-OECD countries the EU should only ban the export of waste to developing countries’. The responses 

to this statement are provided below. 

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Figure 60 Responses to the statement ‘Regarding export of waste to non-OECD countries the EU should only ban 
the export of waste to developing countries’ 

Here there was a large split in opinion. As per statement two under this objective, NGOs and citizens 

nearly universally agreed or strongly agreed with the statement. Those industry representatives that 

agreed or strongly agreed with the statement were generally involved in waste treatment, with those 

industries more involved in the manufacturing of products and often subject to extended producer 

responsibility requirements more likely to disagree or strongly disagree with the statement. 

The insertion of the same qualifier as for the OECD statements addressed earlier was then added to this 

non-OECD statement, with the new statement asking stakeholders the extent to which they agreed that 

regarding export of waste to non-OECD countries the EU should ban the export of waste to developing 

countries, unless there is clear evidence that it will be processed in an environmentally sound manner. 

The results of this statement are shown below. 

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Figure 61 Responses to the statement ‘Regarding export of waste to non-OECD countries only ban the export of 
waste to developing countries, unless there is clear evidence that it will be processed in an environmentally 
sound manner’ 

The largest group of stakeholders either agreed or strongly agreed with the statement, with a large 

number of industry stakeholders that had opposed a general ban being more supportive of a ban in 

cases where environmentally sound management (ESM) of processing was not apparent. 

Finally, stakeholders were asked their opinions with regard to the statement that the EU should only 

restrict the export of certain wastes to developing countries. Interestingly, proportionally stakeholders 

were slightly more supportive of the previous statement concerning ESM than a targeted restriction of 

certain wastes to developing countries as shown in  

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Figure 62 below. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 62 Responses to the statement ‘Regarding export of waste to non-OECD countries only Restrict the 
export of certain wastes to developing countries’ 

Third policy objective: Strengthen the enforcement of the Waste Shipment Regulation’s provisions 

The final objective that the general public was asked to provide its opinion concerned that of 

strengthening the enforcement of the WSR’s provisions. To this effect, stakeholders were asked to 

provide their opinion against two statements. 

The first statement concerned whether the review should seek to strengthen the enforcement of the 

Waste Shipment Regulation’s provisions in general. The responses were almost overwhelmingly in 

agreement with the statement as shown in  

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Figure 63 below. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 63 Responses to the statement ‘A review of the Waste Shipment Regulation should seek to Strengthen 
the enforcement of the Waste Shipment Regulation’s provisions’ 

Secondly, stakeholders were asked whether a review of the Waste Shipment Regulation should seek to 

improve the coordination at EU level of enforcement efforts by Member States against illegal shipment, 

for example by establishing a dedicated forum or body. 

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Figure 64 Responses to the statement ‘a review of the Waste Shipment Regulation should seek to improve the 
coordination at EU level of enforcement efforts by Member States against illegal shipment, for example by 
establishing a dedicated forum or body’ 

Once again, stakeholders overwhelmingly agreed or strongly agreed with this statement. 

Additional policy objectives and measures identified in the general public section of the 

consultation  

Following completion of the sections concerning the three main objectives identified by the Commission 

in respect to the revision of the WSR, the general public section of the questionnaire posed two final 

questions in an open box format. 

The first question asked what policy objectives in addition to those previously addressed should the 

review of the WSR pursue. Over 100 responses were provided to this question, with responses focussing 

on the following general themes: 

• 

• 

• 

• 

• 

• 

• 

The need to simplify waste codes currently in use under the Regulation – nine responses 

The need to enforce the proximity principle and address waste management as close to the 

place of its generation as possible – 13 responses 

Addressing plastic wastes more effectively – two responses 

Increasing extended producer’s responsibility– one response 

Prohibiting shipping for incineration – one response 

Reducing waste generation in the first place – four responses 

Improving consistency of implementation in the EU – 23 responses 

•  Greater support to be provided by Member State authorities in relation to implementing the 

provisions for pre-consented facilities – three responses 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

• 

Banning all shipments of waste destined for disposal – three responses 

Creating a registry of approved importers and exporters – three responses 

•  Making it simpler to allow shipments to take place by reducing the complexity of current 

shipment procedures – 27 responses 

• 

• 

• 

• 

• 

• 

Allowing the market to operate freely and regulate itself – 10 responses 

Providing for procedures to be undertaken in a single language (English) – two responses 

Creating an EU wide single market for waste – 23 responses  

Defining a single financial guarantee value for shipments subject to financial guarantees – one 

response 

Distinguishing between wastes and secondary raw materials – 17 responses 

Defining end of waste at the EU level – eight responses. 

The second question asked what measures in addition to those already listed should the review of the 

WSR include. The following new points were raised (beyond those addressed in response to the previous 

question): 

• 

Applying fines to public authorities that fail to process notifications according to the timings 

laid down in the Regulation 

• 

All waste to energy facilities in the EU should receive pre-consented status to reduce 

administrative burden. 

• 

EU inspection of non-EU countries on environmental and social grounds and to identify the 

destination of recycling residues. 

• 

Review hazardous waste requirements within the WSR specifically for waste products that are 

to be recycled or refurbished or parts harvested. Look at two levels of hazardous classification, 

those that are hazardous in their primary state and those that are hazardous following an 

• 

• 

• 

industrial process. 

Provide for notifications to have longer validity.  

Provide a list of pre-consented facilities for recycling and recovery (within EU) 

Establish uniform and, unambiguous definitions for Li-ion batteries at EU level: harmonise 

classification of undamaged Li-ion batteries as non-hazardous and avoid an unnecessary 

notification process for that waste product category.  

• 

To assign a specific status to EFTA countries in order to encompass these countries with the EU 

countries and not with OECD countries. 

• 

Limit the export of hazardous waste out of the country where the waste is collected unless 

that material could not be treated and recycled locally. This principle should concern all 

shipments, including intra EU. 

• 

The enforcement of the regulation should be supported by clearly defining the consequences in 

cases of breach and of attempt to circumvent the prohibition of exports and by providing for 

EU harmonised penal, administrative and/or customs sanctions in case of non-compliance. 

Effective deterrence would require fines and periodic penalty payments, for natural and legal 

persons, imposed either at national or EU level, to be established in the WSR. 

• 

The review should also favour the creation of an EU level body, as a one stop shop to contact 

in case of evidence of irregular waste management. 

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Section 2 – Expert stakeholder questionnaire 

The expert section of the questionnaire was structured similarly to the general public section, albeit 

under each of the three main objectives more specific objectives and measures were presented to 

stakeholders upon which stakeholders were able to state their preference. Despite the fact that the 

section was targeted at experts, nothing prevented non-experts from answering the questionnaire and 

whilst the total number of respondents was smaller than in Section 1, all stakeholder groups except 

trade unions had at least one representative that answered at least part of section 2, with business 

organisations, companies, NGOs and public authorities comprising the majority of those that responded. 

Challenge 1 - Ensuring a smoother functioning of the EU internal market 
for waste and supporting the transition to a circular economy 

Measure 1a – Align shipments with the waste hierarchy and existing EU legislation 

The results of the public consultation suggest that stakeholders have the greatest support for the 

following measures, and consider them as the most likely to be effective and proportionate in 

simplifying and reducing the administrative burden imposed by the WSR in its present form:  

• 

Simplifying notification procedures for intra-EU shipments of waste destined for reuse or 

recycling, and more in particular improving and harmonising the current provisions in relation 

to pre-consented facilities 

•  Narrowing the grounds for objections to shipments of waste for preparation for reuse or 

recycling. 

Whilst the other measures listed have received some support and are generally considered likely to be 

effective and proportionate, the limitation of shipments of waste for energy recovery is generally 

opposed by most business stakeholders. 

Figure 0.65 shows the breakdown of support for each sub-measure by stakeholder group. It shows the 

number of respondents who claimed that they either fully support or support the measure to a large 

extent. It is clear that there seems to be a preference for the three sub-measures outlined above across 

stakeholder groups. 

Companies and business associations seem to have a strong preference for the three options outlined 

above and seem be against considering options to limit shipments of waste to energy recovery and 

considering options to limit further or prohibit (with limited exemptions) shipments for disposal 

between Member States. Public authorities on the other hand seem to prefer sub-option 1a2 on 

simplifying notification procedures for intra-EU shipments of waste destined for reuse or recycling and 

determining contamination levels at the EU level in the context of classifying waste as hazardous or 

mixed. NGOs also support these two measures, as well as considering options to limit shipments of 

waste to energy recovery and considering options to limit or further prohibit shipments of waste. 

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Figure 0.65 

Support for sub-measures under measure 1a 

Note: Blank and do not know responses removed. 

Regarding estimated impacts of the measures, the first two sub-measures received great support from 

stakeholders (over 75%), whereas considering options to limits shipments of waste to energy recovery 

and limiting shipments for disposal between MS were considered ineffective by 51% and 37% of 

respondents, respectively.  

Measure 1b – simplification and reduction of administrative burden for intra-EU shipments of waste 

For measure 1B, the results from the consultation suggest that there is a strong call for the 

development of an Electronic Data Interchange (EDI) system to facilitate electronic notification and 

movement procedures for waste shipments, better monitoring of waste flows and to allow a smooth 

sharing of information between public authorities. In fact, 99% of companies, 97% of business 

associations, 100% of citizens and 100% of public authorities who replied to this question were in full 

support of in large support of the measure. A detailed breakdown regarding support for this measure is 

shown in Figure 0.66 below.  

214 

79%93%74%14%21%44%78%82%71%14%28%58%70%50%40%40%50%60%40%80%10%70%70%70%39%78%18%53%47%76%Introduce a newsimplified procedure forintra-EU shipments ofwaste destined topreparation for reuse orto recyclingIn order to encourage thefast track procedure thatis currently in art. 14 ofthe WSR establish clearconditions at EU level topre-consent facilities,together with theprinciple of mutualrecognition of thesefacilities across the EU bythe Member StateNarrow down thegrounds for objections toshipments of waste forpreparation for re-use orfor recycling (throughrevision of Article 12)Consider options to limitshipments of waste toenergy recovery.Consider options to limitfurther or prohibit (withlimited exemptions)shipments for disposalbetween Member States.Determine contaminationlevels at the EU level inthe context of classifyingwaste as hazardous ormixed: this can includethe development ofthreshold values forcontamination /mixturesof waste.Percentage support by stakeholder groupMeasure 1ABusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 0.66 

Support for sub-measures under Measure 1b 

Note: Blank and do not know responses removed. 

Regarding expected impacts of this measure, the majority of respondents (over 80% for all three sub-

measures) deemed this would be effective and proportionate.  

Measure 1c – harmonisation of interpretation, application and enforcement across Member States 

The results of public consultation suggest that stakeholders are most supportive of the following 
measures to create more coherence of EU legislation effectively and proportionately: 

• 

Providing further guidance to clarify links between the different types of classifications of 

waste (notably on the Waste Framework Directive, customs HS codes, Basel convention and the 

OECD decision). (Supported by 100% of citizens, 85% of companies, 88% of business 

associations, 80% of NGOs and 74% of Public Authorities.)  

• 

Establish structured exchange of information and experience between MS and at EU level, e.g. 

by creating a platform for MSs to share information. 

• 

Introduce the principle of mutual recognition of national classification in the WSR, to clarify 

whether a commodity is waste or not in case of shipments, including as regards the application 

of end-of-waste criteria. 

215 

97%72%76%99%68%89%100%40%67%90%11%10%100%47%61%Develop at EU level the conditions forthe Wunctioning of an Electronic DataInterchange (EDI) system to facilitateelectronic notification and movementprocedures for waste shipments,better monitoring of waste flows andto allow a smooth sharing of inforRethink the financial guaranteeprovisions/obligations: envisagepossible alternatives for the currentlyused and required systems. This mightinvolve an EU fund, an insurance-based system or other formats.Guidance could accompany thismeasure.Issue guidance on improving efficiencyand simplifying the implementation ofprovisions related to the prior writtennotification and consent procedures.Percentage support by stakeholder groupMeasure 1BBusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 0.67 

Support for sub-measures under Measure 1c 

Note: Blank and do not know responses removed. 

Whilst nearly all other measures listed received some support and were considered effective and 

proportionate (by >50% of stakeholders), the defining of rules to decide whether a commodity is 

classified as waste or not, or as hazardous or non-hazardous was generally not favoured or viewed as 

effective by stakeholders, especially by NGOs and public authorities who were against this measure.  

Measure 1d – Provide more relevant delegations to the Commission to adapt the Regulation over 

time to technical and policy progress. 

This measure would involve providing more relevant delegations to the Commission to adapt the 

Regulation over time to technical and policy progress. The results of the public consultation suggest 

that the majority of stakeholders support the objective of this measure. However, few were fully in 

favour of providing more relevant delegations to the Commission to adapt the Regulation over time to 

allow technical and policy progress. Most stakeholders believed it to be proportionate and effective. 

In particular, 27% of companies supported the measure fully, 26% to a large extent and 27% only to 

some extent. Full support of this measure was even lower for business associations with only 14% 

supporting the measure fully, 32% to a large extent and 30% only to some extent. Similar values were 

obtained for citizens and NGOs with 0% who claimed they do not support the policy measure at all. For 

216 

88%62%51%72%54%56%69%76%85%74%52%79%66%57%76%79%100%89%50%78%50%38%71%78%80%40%10%10%30%0%30%10%74%44%28%47%29%18%58%82%Provide furtherguidance to clarifythe links betweenthe different typesof classification ofwaste.Introduce in theWSR the principle ofmutual recognitionof nationalclassification onwhether acommodity is wasteor not in case ofshipments, includingas regards theapplication of end-of-waste criteria.Define rules to determine which Member State’s (dispatch or destination) decision would prevail to decide whether a commodity is classified as waste or not, including as regards the application of end-of-waste criteria.Develop guidanceon implementationof Article 28 tofoster a commoninterpretation onhow to deal withdisagreementsbetween MemberStates on whether acommodity is wasteor not, including asregards theapplication of end-of-waste criteria.Introduce in theWSR the principle ofmutual recognitionof national rules onwhether a waste isclassified ashazardous or not incase of shipments.Define rules to determine which Member State’s (dispatch or destination) decision would prevail to decide whether a waste is classified as hazardous or not.Develop guidance tofoster a commoninterpretationacross the EU MS onhow to deal withdisagreementsbetween MS onwhether a waste isclassified ashazardous or not.Establish structuredexchange ofinformation andexperiencesbetween MS and atEU level, e.g. bycreating a platformfor MS to shareinformation.Information caninclude bilateralagreements onwaste shipmentrelated topics, end-of-waste decisions.Percentage support by stakeholder groupMeasure 1CBusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

public authorities, 30% supported the measure fully or to a large extent, and 47% supported the 

measures only to some extent.  

Regarding expected impacts, the majority of respondents reported that they expected it 

either to effective and proportionate (58%), or effective and disproportionate (33%).  

Challenge 2 – Better guarantee waste shipped across borders are managed 
in an environmentally sound manner 

Measure 2a – stop exporting EU waste outside of the EU 

The sub-measures which received most support were work on the Basel Convention, for example 

considering the inclusion of additional waste streams in the Convention or reinforcing the Convention 

with regards to Environmentally Sound Management or even Circular Economy aspects like lifecycle 

approach policy and reviewing the current OECD framework governing transboundary movements of 

waste, specifically for EU exports to other OECD countries. These were mostly supported by NGOs, 

Public Authorities and Citizens. Business associations and Companies tended not to be in favour of 

measure 2a. With the greatest support from business associations on the option to maintain the current 

rules on both hazardous and green listed waste exports to third countries and focus on stronger 

enforcement measures (64% of respondents) and for companies on work on the Basel Convention, for 

example considering the inclusion of additional waste streams in the Convention or reinforcing the 

Convention with regards to Environmentally Sound Management or even Circular Economy aspects like 

lifecycle approach policy (59% support from respondents.) 

Figure 0.68 

Support for sub-measures under Measure 2a 

Note: Blank and do not know responses removed. 

217 

7%22%41%36%47%64%48%37%10%31%39%44%50%51%51%59%56%11%33%33%56%67%63%67%60%10%20%20%20%30%70%70%29%12%41%59%63%29%67%65%Introduce a ban onexports to non-EUcountries of allwaste.Introduce a ban onexport of all waste toall non-EU countries,with the exception ofexport of green listedwaste to countrieswhich (i) notify theCommission thatthey want to be ableto import waste fromthe EU and (ii)demonstrate thatthey comply withIntroduce a ban onexport of all waste toall non-EU, nonOECD countries, withthe exemption ofexport of green listedto countries which (i)notify theCommission thatthey  want to be ableto import waste fromthe EU and (ii)demonstrate thatthey complRequire that theprior informednotification andconsent procedureapplies for theexport of green listedwastes to non-OECDcountries outside theEU.Revisit the currentlegal regime definingthe right to exportgreen listed waste tonon-OECD countries,as set out in Art. 37of the WSR andRegulation (EC) 1418/2007: maintain thethrust of art. 37, butensure updatedinformation can beprovided in a morMaintain the currentrules on bothhazardous and greenlisted waste exportsto third countriesand focus onstrongerenforcementmeasures.Specifically for EUexport to other OECDcountries: review thecurrent OECDframeworkgoverningtransboundarymovements ofwaste, to assess if itis the mostadequate, when itcomes to regulatingsuch trade within theOECD with a view tomanaging wastes inWork on the BaselConvention: e. g.consider theinclusion ofadditional wastestreams in theConvention,reinforce theConvention asregardsEnvironmentallySound Managementor even CircularEconomy aspects likelifecycle approachpolicy.Percentage support by stakeholder groupMeasure 2ABusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

An overview of expected impacts with regards to effectiveness and proportionality of measures is 

shown in the graph below.  

Figure 0.69 

Views on expected impacts for sub-measures under Measure 2a 

Note: Blank and do not know responses removed. 

Measure 2b – verify ESM in destination countries 

Regarding sub-measures under measure 2b, aimed a verifying ESM in destination countries, the one 

which received most support from all stakeholders except citizens was to clarify what the EU considers 

as the environmentally sound management of waste, by including additional provisions on this point in 

the regulation or in implementing acts. The other two sub-measures also received significant support, 

especially from citizens, NGOs and public authorities. Details are outlined in the graph below.  

218 

30%20%11%13%7%7%0%9%24%20%13%17%4%1%7%4%4%13%26%16%33%41%24%21%0%10%20%30%40%50%60%70%Introduce a ban onexports to non-EUcountries of allwaste.Introduce a ban onexport of all waste toall non-EU countries,with the exceptionof export of greenlisted waste tocountries which (i)notify theCommission thatthey want to be ableto import wastefrom the EU and (ii)demonstrate thatthey comply withIntroduce a ban onexport of all waste toall non-EU, nonOECD countries, withthe exemption ofexport of greenlisted to countrieswhich (i) notify theCommission thatthey  want to be ableto import wastefrom the EU and (ii)demonstrate thatthey complRequire that theprior informednotification andconsent procedureapplies for theexport of greenlisted wastes to non-OECD countriesoutside the EU.Revisit the currentlegal regime definingthe right to exportgreen listed waste tonon-OECD countries,as set out in Art. 37of the WSR andRegulation (EC) 1418/2007: maintain thethrust of art. 37, butensure updatedinformation can beprovided in a morMaintain the currentrules on bothhazardous and greenlisted waste exportsto third countriesand focus onstrongerenforcementmeasures.Specifically for EUexport to otherOECD countries:review the currentOECD frameworkgoverningtransboundarymovements ofwaste, to assess if itis the mostadequate, when itcomes to regulatingsuch trade within theOECD with a view tomanaging wastes inWork on the BaselConvention: e. g.consider theinclusion ofadditional wastestreams in theConvention,reinforce theConvention asregardsEnvironmentallySound Managementor even CircularEconomy aspects likelifecycle approachpolicy.Measure 2AIneffectiveEffective, but disproportionateEffective and proportionate 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 0.70 

Support for sub-measures under Measure 2b 

Note: Blank and do not know responses removed. 

Regarding effectiveness of these measures, the majority of stakeholders deemed the first option to be 

effective and proportionate (80%), whereas for the second and third option this dropped to 49% and 61% 

respectively. In fact, for the latter two options many respondents seemed to expect that the measures 

would be ineffective, with 15% believing this for the option on the establishment of an EU agency to 

inspect and certify that waste management facilities in 3rd countries processing waste imported from 

the EU comply with EU requirements on the environmentally sound management” of waste, and 18% 

believing the option of introducing a guidance document outlining more detailed and stricter conditions 

governing the export of waste outside the EU to be ineffective. 

219 

55%41%45%67%42%54%71%100%88%90%50%30%94%82%83%Clarify what the EU considers as theenvironmentally sound management ofwaste, by including additional provisionson this point in the regulation or inimplementing acts.Consider the establishment of an EUagency or equivalent body designed toinspect and certify that wastemanagement facilities in 3rd countriesprocessing waste imported from the EUcomply with EU requirements on theESM of waste.Introduce in the WSR or in a guidancedocument more detailed and stricterconditions governing the export ofwaste outside the EUPercentage support by stakeholder groupMeasure 2BBusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Measure 2C  

Figure 0.71 

Support for sub-measures under Measure 2c 

Sub-measures under measure 2C received support mostly from citizens, business associations, 
public authorities and companies. NGOs seemed to be generally against these measures.  

Note: Blank and do not know responses removed. 

Regarding expected impacts on effectiveness for the measure, the majority of respondents deemed the 

measure to be effective and proportionate, with 78% claiming this for the first sub-measure and 84% 

claiming this for the second measure.  

Challenge 3 – Better prevent and address illegal shipments of waste 

Measure 3a – Further strengthen provisions on enforcement and inspections 

Stakeholders seemed to be mostly in favour of measures to further strengthen provisions on 

enforcement and inspections. Generally, public authorities, NGOs and citizens seemed to be more in 

favour with these compared to business associations and companies. A detailed breakdown regarding 

support for these sub-measures is shown in the table below.  

220 

64%72%65%68%75%75%20%20%71%75%EU should make additional efforts in the context ofmultilateral agreements to further clarify the matter regardinghow disputes between Member States and other Parties aresettled on whether a commodity is a waste or not, or whethera waste is hazardous.Development of guidance to foster a common interpretationacross EU Member States and third Parties on how to dealwith disagreements between Member States and third Partieson whether a commodity is waste or not, or whether a wasteis hazardous or not.Percentage support by stakeholder groupMeasure 2CBusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 0.72 

Support for sub-measures under Measure 3a 

Note: Blank and do not know responses removed. 

Regarding expected impacts on effectiveness for the measure, the majority of respondents deemed the 

measure to be effective and proportionate, with 78% claiming this for the first sub-measure, 81% 

claiming this for the second measure and 72% for the third measure.  

Measure 3b – Increase the priority of addressing illegal shipments of waste and strengthen EU and 

global cooperation 

Stakeholders seemed to be mostly in favour of measures to increase the priority of addressing illegal 

shipments of waste and strengthen EU and global cooperation. A detailed breakdown regarding support 

for these sub-measures is shown in the table below.  

221 

66%72%57%70%62%50%89%100%67%80%80%80%94%94%44%Increase the involvement and capacity of EU bodies (e.g.Europol, OLAF) to support the control and enforcementactions of Member States against illegal shipment ofwaste or against illegal treatment of legally shipped wasteEstablish through the WSR a forum, composed of lawenforcement and inspection agencies of the EU MS andthe Commission, and dedicated to: exchange information,share experiences, set out EU priorities, cooperate andpromote joint actions on the fight againImprove /specify reporting requirements for MemberStates regarding enforcement staffing and actionsPercentage support by stakeholder groupMeasure 3ABusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 0.73 

Support for sub-measures under Measure 3b 

Note: Blank and do not know responses removed. 

Regarding expected impacts on effectiveness for the measure, the majority of respondents deemed the 

measure to be effective and proportionate, with 85% claiming this for the first sub-measure and 74% 

claiming this for the second measure. 

222 

79%69%72%69%78%89%60%80%72%83%Improve existing guidance and develop additional guidance onimplementation and enforcement issues.Actions towards third countries to improve enforcement: support to projects and cooperation at bilateral, regional, and global levels, notably through the Basel Convention, World Customs Organisation, UN office on Drugs and Crime, Interpol…Percentage support by stakeholder groupMeasure 3BBusiness AssociationCompanyCitizenNGOPublic Authority 
 
 
  
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Annex 2 Stakeholder workshop report 

Workshop - Exploration of potential policy responses to review the Waste 
Shipment Regulation 

This annex summarises the proceedings of the two half-day workshops held on 23rd and 24th September 2020 

as part of the exploration of potential policy responses to review Regulation (EC) No 1013/2006 on shipments 

of waste (the WSR). Attendees were provided with: 

1.  a background paper in advance of the workshop; and 

2.  presentations at the workshop itself that were further explained by the consultants assisting 

the Commission in the assessment process. 

This report consolidates the background paper, the presentations that were made, and a summary of the 

proceedings. It was issued to workshop attendees for their comments and has been updated following receipt 

of those comments.  

The agenda was split across two mornings, with the first morning dedicated to examination of objectives 

concerned with the intra-EU shipment of waste and the second that considered extra-EU shipments of waste 

and enforcement.  

Day One attendees were comprised of: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

29 Member State representatives, including government ministries and competent authorities. 

21 Company / business organisations. 

11 Waste treatment associations. 

8 Environmental NGOs. 

6 recycling / materials trade associations. 

3 individual waste treatment companies. 

3 individual non-waste treatment / recycling companies. 

2 recycling / materials trade companies. 

5 other organisations (comprised of European Institution bodies and international bodies). 

Day Two attendees were comprised of: 

• 

• 

• 

• 

• 

• 

• 

• 

• 

31 Member State representatives, including government ministries and competent authorities. 

24 Company / business organisations. 

10 Waste treatment associations. 

8 Environmental NGOs. 

4 recycling / materials trade associations. 

3 individual waste treatment companies. 

3 individual non-waste treatment / recycling companies. 

2 recycling / materials trade companies. 

5 other organisations (comprised of European Institution bodies and international bodies). 

The full agenda and list of attendees are provided at the end of this annex. The summary follows the order of 

the agenda. The agenda followed the order of the background paper. 

223 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The meeting was hosted on WebEx and included the use of Sli.do to pose questions to attendees and to run 

polls. As a result of the setup of Sli.do, some attendees were listed as anonymous. Additionally, a small 

number of attendees noted that they could not access Sli.do during the workshop. Consequently, it is not 

possible to split the results of questions or polls by stakeholder group not to state that all stakeholders input 

into the polls run during the workshop. Where this is the case, the total numbers of respondents that did 

participate are listed. 

Workshop introduction and setting the scene 

The workshop was introduced by Wood with an overview of the two-half days agenda provided. Additionally, 

instructions were provided to attendees with regard to the method for providing input through a mix of 

interventions using WebEx (through verbal interventions and WebEx chat) and Sli,do. Verbal statements were 

recorded by the consultants and Sli.do input was captured using the analytics provided by the system. 

Attendees were made aware that a workshop report would be drafted and shared with participants for 

comment. This draft report represents that workshop report for comment. 

DG Environment of the European Commission provided an introduction from the Commission and set the 

context of the assessment presently being undertaken, emphasising in particular: 

• 

The important political attention paid to the question of the export of waste and the need to 

act on this issue through the revision of the waste shipment regulation; 

• 

The need to consider waste as a valuable resource in the context of the circular economy and 

for the waste shipment framework employed within the EU to function with this in mind. 

• 

The importance of environmentally sound management of waste, and in particular waste 

generated in the EU. 

• 

The importance of stakeholders playing an active role in the revision process, including in 

these two half-day workshops. 

The consultants gave an overview of the study in the context of the introduction provided by Mr Pellegrini as 

well as the general approach to assessing possible changes to the EU waste shipment regulatory framework 

that had resulted in three main objectives to any possible revision being identified, namely: 

• 

Ensuring a smoother functioning of the EU internal market for waste and supporting the 

transition to a circular economy 

• 

Better guaranteeing that waste shipped outside the EU is managed in an environmentally sound 

manner 

• 

Better preventing and addressing illegal shipments of waste 

It was noted that during the public consultation that additional issues relating to the present-day ineffective 

functioning of the WSR due to lack of clarity in some of the existing legal provisions should also be addressed 

in any possible revision of the Regulation. Attendees were also invited to raise any additional matters that 

they considered should be discussed during the workshop. The following points were raised: 

• 

An environmental NGO noted that an EEB study has recently been released on the relationship 

between the recent entry into force of the Basel Convention’s Ban Amendment and EU rules on 

the treatment of end-of-life vessels outside the EU.  

224 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

• 

A Member State’s representative noted that their workload is increasing but their staff levels 

are decreasing. With respect to the daily work (Notifications, illegal shipments etc.), as a 

result, the potential revisions of the WSR would be challenging for such authorities.  

• 

Another Member State’s representative pointed out that a number of issues raised in the 

background paper are suggesting approaches that do not properly reflect the content of the 

current WSR, or which might not be in line with international law (Basel, OECD, WTO). This 

point was supported by others, including a Member State’s representative and a waste 

treatment association.  

• 

A waste treatment industry’s representative noted that differences between hazardous and 

non-hazardous waste need to be clearly picked up in measures (and potential changes). 

Hazardous waste is well dealt with in the WSR, however non-hazardous waste is more 

problematic. Ideally there should be a clear distinction of which measures are relevant for 

hazardous or non-hazardous waste.  

Objective 1: Ensuring a smoother functioning of the EU internal market for 
waste and supporting the transition to a circular economy 

Specific objective 1a Alignment of the waste hierarchy, WSR and other EU legislation 

The starting point for this objective as described in the background paper and emphasised at the 

workshop is to see if and how the Regulation could incentivise shipments of wastes in the EU to 

operations that are higher up the waste management hierarchy. 

The first open discussion focussed on the following questions: 

1. 

should a lighter touch approach be applied for waste shipped in preparation for reuse and for 

recycling purposes? and  

2. 

should waste for energy recovery or landfilling be limited or prohibited respectively? 

On the lighter touch approach, a Member State’s representative outlined that green-listed wastes are 

already easy to ship, and this includes most wastes intended for recycling. Not applying the prior 

informed consent (PIC) procedure for hazardous waste intended for recycling would not be in line with 

the Basel Convention. This view was supported by two industry stakeholders, an environmental NGO, 

and a Member State that also considered that the level of protection offered by PIC should not be 

removed for such wastes. The environmental NGO also outlined that even for waste intended for 

treatments higher in the hierarchy (i.e. recycling and waste preparing for reuse) there is abuse of 

shipments and therefore they require checks, to ensure hazardous waste is not shipped. Four Sli.do 

responses supported this view, with one noting that proper regulation is required to protect 

environmental standards and one stating that a lighter touch could only be considered for non-

hazardous waste. A waste incineration association noted that the Waste Framework Directive (WFD) 

already aims to enforce the waste hierarchy and therefore further alignment with the WSR was not 

necessary. 

Two Sli.do responses supported alignment with the waste hierarchy. One noted that it could be 

facilitated by increasing the tonnage of shipments allowed for trials or tests in recycling  

plants. 

On the second question (energy recovery and landfilling), two Member States outlined that limiting 

shipment of waste is not possible due to certain Member States’ capacity to deal with waste. This is in 

line with the European Commission’s Communication on Waste-to-Energy, which acknowledged that “In 

225 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

justified cases, the cross-border shipments of waste could help to make optimal use of the waste-to-

energy capacity already available in a number of Member States”. As for landfilling, some Member 

States lack landfilling capacity (e.g. Austria for hazardous waste) and therefore need to ship it. One of 

those Member States noted that Articles 11 and 12 already allow Member States to restrict shipments of 

waste within the EU (Article 11 for shipment destined for disposal operations like landfilling, Article 12 

for shipments of waste for recovery), which should be enough. A waste treatment company and a Sli.do 

comment stated that a market for the products of reuse and recycling is required before the limitation 

or prohibition of waste streams can be considered. Two company / business organisations and a 

comment on Sli,do noted that some fractions cannot be recycled and require landfilling or energy 

recovery. Developing market capacity for recycling should therefore be the focus rather than limiting 

shipment to incineration facilities. A recycling association outlined that the WSR provides a procedural 

framework and should continue to focus on this. This was supported by a number of industrial 

organisations (Company / business organisations and a waste treatment trade association). 

This strong opposition to the prohibition of shipments destined for landfilling or energy recovery follows 

the public consultation’s answers, where limiting shipments of waste destined for energy recovery was 

the least favoured option and considered inefficient. 

However, one environmental NGO supported controls or limits of landfilling outlining that for plastics 

there needs to be more than just market forces. A Sli.do comment further supported energy recovery 

over landfilling. However, two organisations (a company/business organisation and an environmental 

NGO) noted that for toxic plastics landfilling is required, as recycling and energy recovery is a more 

environmentally damaging option.  

Stakeholders were asked in a Sli.do poll whether shipments of waste for waste to energy recovery or 

landfill should be limited or prohibited (see Figure 0-1). A Member State criticized this format of 

gathering input, as it did not allow for nuance and arguments. The largest group of stakeholders 

believed that both waste for energy recovery and landfilling should be prohibited or limited (22 

stakeholders, 34%). Other large groups thought only waste for landfilling should be prohibited (16 

stakeholders, 25%), or that neither should be prohibited or limited (16 stakeholders, 25%). This result is 

incoherent with the result of the public consultation, and with the input received when the floor was 

open on this question. 

226 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Figure 0-1 – Slido Poll: “Should shipments of waste for waste-energy recovery or landfilling be 
limited/prohibited?” (n=65) 

In another Sli.do poll, participants were asked how a ‘lighter touch’ procedure for waste destined for 

reuse or recycling would function in practice. A total of 31 stakeholders provided a response. 17 of 

these stakeholders suggested ways in which a ‘lighter touch’ could be implemented: 

• 

Pre-consented/certified facilities were outlined as an area where the lighter touch could 

apply (7 stakeholders). This should only be done for regularly audited and high-quality certified 

recovery facilities. One stakeholder suggested modelling this system on the European list in the 

Ship Recycling regulation; 

•  A focus on Annex VII was outlined as a means to apply the lighter touch approach (4 

stakeholders). Most stakeholders outlined that it should be mandatory to have this Annex 

included for shipments with a lighter touch. This assumes electronic submission and 

harmonised enforcement across MSs in the use of Annex VII. 

•  Other measures were suggested by six stakeholders. These include a variety of approaches 

including allowing free waste shipment within the internal market, solving inefficiencies of PIC 

procedure, and tacit consent. 

Eight stakeholders stated that they did not agree with a lighter touch approach. Three noting it should 

only not be done for plastic wastes, two outlining it should not include hazardous waste, one stating 

multiple procedures could cause confusion, one outlining the WFD already incentivises the waste 

hierarchy and therefore the WSR does not need to, and the final stakeholder noting removal of PIC 

procedure could incentivise illegal shipments. 

Specific objective 1b - simplification and reduction of administrative burden for intra-EU shipments 

of waste  

A number of provisions within the WSR have been identified as overly burdensome. This specific 

objective aims to reduce these costs and burden. Consequently, three main topics were discussed 

during the open floor discussion, namely the electronic data interchange (EDI), pre-consented 

facilities and amendment of the financial guarantee system.  

All stakeholders participating in the open discussion expressed interest in the introduction of EDI, 

whether on a voluntary or mandatory basis. The general view was that it would improve efficiency and 

transparency. A manufacturing industry stakeholder proposed the introduction of English as the 

common language for communication between Competent Authorities.  

227 

9%; 625%; 1625%; 168%; 534%; 2205101520255) Don’t know / no opinion4) No, to both3) Yes, waste for landfilling should be prohibited2) Yes, waste for energy recovery should be limited1) Yes, to both 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

The same stakeholder also expressed concern regarding the length of Annex II of the WSR (concerning 

information and documentation related to notification) and the extent of inconsistencies between 

documents required by different Competent Authorities. 

All the stakeholders who expressed their views during the open floor discussion were supportive of the 

clarification of the procedures relating to pre-consented facilities, partly because this would be 

helpful in the transition to a circular economy. The stakeholders were also of the opinion that these 

procedures required clear criteria under which these facilities could be considered as pre-consented. 

Some stakeholders (including one Member State – who offered their own criteria as a basis) suggested 

specific conditions: 

• 

• 

Facilities with good (several years), track record with enough data supporting this. 

Facilities that drop in standard (with regular inspections) could lose their status and/or be 

penalised 

Other criteria / approaches suggested that the facilities should be audited by the EU according to EU 

standards and that the procedure for this should be digital. Some stakeholders also suggested that for 

these recognised facilities of high standards the principle of mutual recognition could be introduced. 

One Member State’s representative suggested that a guidance document under the Correspondents’ 

Group could be sufficient in outlining rules for these pre-consented facilities.  

Most stakeholders participating in the open floor discussion were in favour of simplification of the 

financial guarantee system. Stakeholders suggested several potential changes to the financial 

guarantee system: 

•  An EU-wide fund was the most commonly suggested approach as, according to a Member State 

stakeholder it would allow for the widest coverage and offer the same level of protection as 

the current system. However, a Member State representative highlighted that if an EU-wide 

fund was being considered two court (German and CJEU) rulings126 should be considered. These 

decisions ruled out a nationwide (cross Lander) German ‘solidarity’ fund as it also illegal 

shipments that have not been notified.  

• 

The establishment of national funds was suggested by a Member State’s representative 

claiming that this would be possible under the current Art. 6. One Member State’s 

representative referred to a Court case (C389/00) that repealed a national initiative to that 

end in the past. It should be noted that in this case the national solidarity fund would have 

come on top of the current obligations in the WSR for individual companies. 

•  An Insurance-company based system: A member State’s representative pointed out that such 

an insurance system is already possible under Art. 6. One stakeholder, however, was not in 

favour of such insurance-based system, as they felt it could be taken advantage of by (illegal) 

waste traffickers. Instead they suggested a yearly rolling out system. The insurance-based 

system was also not favoured by another Member State‘s representative. 

Another Member State raised some concerns/reservations regarding the replacement of the current 

system of financial guarantees as Competent Authorities are currently the beneficiaries of the 

guarantees and they had doubts about being able to access the funds if alternatives were used.  

126 C-389/00 and BVerfG; 2 BvR 2335/95 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

A Sli.do poll asked stakeholders how the regime on pre-consented facilities could be streamlined. A 

total of 19 participants provided a response. A large range of options were suggested by stakeholders: 

• 

Longer validation periods for pre-consented facilities, was selected by 7 stakeholders. Most 

stakeholders felt this could reduce the costs and administrative burdens. 

•  A harmonisation of EU pre-consented standards was favoured by 5 stakeholders. This either 

took the form of ensuring mutual recognition of pre-consented facilities (2 stakeholders) or 

• 

• 

ensuring EU-level standards for facilities (3 stakeholders). 

EDI was mentioned as useful by 2 stakeholders. 

Simplifying financial guarantees was noted by 2 stakeholders. It was noted that financial 

guarantees can be the most time-consuming and costly aspect. One recommendation was to 

look at the work of the Fast-track Notification project within the North Sea Resources 

Roundabout. 

Other issues were raised by 3 other stakeholders. This included tacit consent, further EU auditing and 

fast-track notification. 

Stakeholders were asked in a Sli.do poll what their preferred solution for financial guarantees would be 

(see Error! Reference source not found.). Most stakeholders believed that an EU-wide fund should be 

created for financial guarantees (19 stakeholders, 43%).  

Sli.do Poll: “What would be the preferred solution for the financial guarantee?” (n=44) 

Following this Sli.do poll, if stakeholders selected “another solution” or had other suggestions they 

were able to provide an open response to explain their selection. A total of 16 stakeholders provided an 

answer. Some stakeholders did not provide other solutions, but instead listed justifications for EU-wide 

funding systems (3 stakeholders), insurance-based systems (2 stakeholders), keeping the current system 

(2 stakeholders), or other unrelated issues (4 stakeholders). The only alternative solutions included 

global funding systems, such as global bank guarantee systems (which were noted as being successfully 

applied in one MS), a global single rolling yearly procedure involving an EU fund, and an annual rolling 

financial guarantee.  

229 

16%; 723%; 1018%; 843%; 1902468101214161820d) The current regime should not be changedc) Another solution (please specify)b) Insurance-based systema) EU-wide fund 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific  objective  1c  -  harmonisation  of  interpretation,  application  and  enforcement  across 

Member States 

Under this specific objective, the possible measures presented to attendees include the introduction of 

new provisions to determine when a waste is no longer considered to be a waste under end-of-waste 

criteria, determining when a waste is considered as hazardous or contaminated/mixed, determining 

levels of contamination for classifying wastes and establishing a structed exchange of information on 

these matters. 

The open floor discussion included the issues of mutual recognition, harmonised classification across 

the EU, and the creation of contamination levels/guidance. This discussion mainly occurred on the first 

day workshop, however it was revisited at the end of the second day workshop. The text below contains 

discussions from participants across both days. 

On mutual recognition of the classification of waste between Member States, there was a wide range of 

opinions. Two Member States noted that they are content with the provisions already provided in 

Article 28 of the WSR (i.e. the most stringent interpretation prevails). They noted it was the most 

appropriate, fastest and functional approach. Another Member State was also unclear on new mutual 

recognition approaches, as they could (unconstitutionally) overrule the law in one Member State. 

Several industry associations noted that mutual agreement could lead to supporting the weakest 

definition (on what is potentially waste or hazardous). A waste treatment trade association outlined 

that allowing mutual recognition for only the strongest standards could be a way forward, citing the 

mutual recognition procedure for EoW in France.127 They, alongside a Sli.do comment, further noted 

that it should not be necessary for mutual recognition for hazardous waste, where article 7 of the WFD 

covers the definition of waste. However, two stakeholders (a company/business organisation and an 

environmental NGO) noted that EU level harmonisation is therefore preferable, as such legislation can 

create unfair competition or there can be two Member States with weak legislation. An environmental 

NGO noted that the provisions of art. 28 of the WSR or any form of mutual recognition should be the 

last resort. A waste recycling association outlined that mutual recognition was a key tool in reaching 

a functioning internal market for raw materials. This view was supported by another industry 

organisation.  

Stakeholders were asked in two Sli.do polls about the potential environmental impacts of introducing 

mutual recognition for the classification of 1) waste or non-waste, and 2) hazardous or non-hazardous 

waste (see Error! Reference source not found.). For both, workshop participants perceived slightly 

more positive environmental impacts than negative.  

127 Article L541-4-3, Paragraph IV https://www.legifrance.gouv.fr/codes/id/LEGIARTI000042176104/2020-07-31/  

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Sli.do Poll: “What would be the environmental impact of introducing mutual recognition for classification of a 
commodity as waste or non-waste and waste as hazardous or non-hazardous” (n=46 and n=45) 

When discussing the development of thresholds on contamination, a wide variety of opinions were 

expressed. Several stakeholders supported the concept of EU development of thresholds on 

contamination. Some stakeholders outlined issues they foresaw with the determination of 

contamination thresholds. A Member State’s representative outlined that determining contamination 

limit values could prove to be complex as such limits are hard to define. A better system may be to 

focus on what materials are allowed to be mixed without environmental risk. Another Member State 

further noted that although they would find contamination values useful, enforcement can be 

extremely difficult (should regulators be trained to dissect waste or take it back to facilities to 

calculate contamination limits?). An environmental NGO outlined the issue of contamination values 

relating to the plastic amendments from COP14. They will provide a report that has suggestions on how 

to deal with this issue. Another Member State outlined that for both waste plastics and metals it is 

unclear how to relate contamination limit values to the waste entries in the Basel Convention that do 

not refer in any way to such limit values. An environmental NGO supported the comment and further 

noted that enforcing clear separation of waste was the best way to deal with (avoid) contamination. 

However, one Member State’s representative outlined that more separation of wastes could be 

expensive, because of the increased movements of wastes.  

A Competent Authority noted that any decisions on contamination levels or classification of waste 

require guidance on a methodology how to enforce them.  

The further development of guidance documents for the harmonisation of contamination levels in 

the context of EU rules on waste shipments was supported by a variety of stakeholders. An 

environmental NGO and a company/business organisation outlined that proper interpretation via 

law/guidance documents/the correspondence group should be provided. A regional authority outlined 

that guidance is necessary as stakeholders cannot always know the different Competent Authorities’ 

views on waste shipment. Regardless of mutual recognition rules, this could confuse operators. A 

recycling industry association noted that guidance documents can support mutual recognition in 

harmonising diverging interpretations. 

Workshop participants were asked in a Sli.do poll what would be the best method for setting common 

thresholds for contaminated/mixed waste at the EU level (see Error! Reference source not found.). A 

231 

41%; 1942%; 1959%; 2658%; 27051015202530Classification of a commodity as waste or non-wasteClassification of waste as hazardous or non-hazardousPositive impactNegative impact 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

majority of stakeholders perceived that legally binding instruments (such as delegated acts by the 

Commission) as the most effective method (31 stakeholders, 69%).  

Sli.do Poll: “What is the best method for setting common thresholds for contaminated/mixed waste at an EU?” 
(n=45) 

When stakeholders selected other, or had other opinions, they were able to provide an open response 

to justify what the best method for setting thresholds would be. A total of 8 stakeholders provided a 

response, however most discussed either delegated acts, or guidance documents (3 each). Two 

stakeholders however stated that thresholds should be set by professional guidance documents 

established by the industry.  

Ships 

Addressed on Day Two of the workshop but included here for the purpose of subject matter, one 

environmental NGO noted the publication of the report “contradiction in terms” concerning the EU 

rules on the export of EU flagged end-of-life ships. This report highlights incoherence between the 

Basel Convention rules, especially the Ban Amendment that recently entered into force and has been 

implemented in EU law since decades, and the specific EU rules on ship recycling. 

Another environmental NGO further continued the discussion noting that there is no legal argument for 

exporting EU end-of-life ships to non-EU non-OECD countries. 

DG ENV responded that this is a question that is linking the Basel Conventions, WSR and the EU Ship 

Recycling regulation. Hence, as this issue may also have an impact on the latter regulation, this 

workshop is not the right forum to deal with this specific issue and will be discussed in the context the 

EU Ship Recycling Regulation.  

Levels of contamination of waste 

Originally intended to be addressed under the agenda of day one, the issue of levels of contamination 

of waste was added to the end of the agenda of day two due to insufficient time on day one to discuss 

it in any detail. 

The following points were raised by attendees: 

232 

13%; 618%; 869%; 31051015202530353) Other (please specify)2) Guidance documents1) Legally binding instruments (delegated acts by the Commission 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

A Member State’s representative noted that a discussion on limit values raises a number of 

considerations about the types of contaminants that may require different thresholds to be set. A more 

worthwhile approach may be to consider which materials can be mixed together without raising 

environmental concerns. This could work to the greater aim of assisting shipments of wastes within the 

EU for recycling by exempting such mixed wastes from notification processes. 

A second Member State’s representative stated that the new Basel entries containing the plastics 

contain wording that are not easy to interpret that demonstrate the need for unambiguous wording 

when it comes to any new rules. 

Am environmental NGO noted that there are really two issues here – contamination by hazardous 

materials that is addressed by the Basel Convention – and the plastic amendments that are difficult to 

implement given interpretation issues. The language used in Basel in this respect is very strict. The 

values of 0.5% should apply in such cases and BAN has a paper to this effect. 

A third Member State’s representative intervened to note that practically speaking nothing would be 

green listed if no contamination was allowed as there is generally always small levels of contamination. 

However, completely clarifying contamination levels for all wastes are practically difficult. It is useful 

to put further thoughts into this for all green listed waste. 

Concerning plastic wastes, and environmental NGO believed that in looking at implementation of the 

Basel amendments there are clearly difficulties in respect of mixtures. Issues such as labels on plastics 

will result in contamination which, in some cases cause difficulty in recycling. However, the arguments 

for no or weak limits for contamination generally come from those who have struggled to apply 

separate collection of wastes – a move to address contamination levels would encourage further 

segregation in future. 

A fourth Member State’s representative believed It important, in the secondary raw materials market, 

to consider levels of contamination in the context of future use. Furthermore, increasing levels of 

segregation will result in additional transport for the collection of those wastes. 

Basel Secretariat – The secretariat is organising a series of information sessions on the plastic waste 

amendments, including in relation to enforcement and implementation. The sharing of information 

through these sessions may be of assistance in relation to the work on contamination levels in the EU. 

A fifth Member State’s representative made the statement that in an ideal world it would be good to 

have set contamination levels. However, if a limit is introduced there are still difficulties in the field in 

enforcing those limits in inspections. Bringing a legal case on such shipments is also likely to be 

problematic. 

Specific objective 1d - better adapt to technical progress and stimulation of innovation 

Under this objective further delegation would be provided to the Commission to adapt aspects of the 

Regulation through Delegated Acts. In addition, it would include the development of Commission 

guidance and an EU wide online platform for sharing innovative practices and technical progress in the 

implementation of the WSR. During the open floor discussion with participants two main points were 

discussed, namely the use of delegated acts and limits on shipments intended for test trials.  

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With regards to the delegated acts, one MS was of the opinion that it should be possible to revise 

Annexes IIIA and B. Another MS pointed out that before relying upon delegated acts, it should be 

considered what these are being used for, as at the OECD and Basel Convention levels the amendment 

of annexes is already possible. He suggested that the Electronic Freight Transport Information 

Regulation could be used as an inspiration for the WSR as it relies upon a mixture of delegated and 

implementing acts.  

Regarding the limits on shipments of waste intended for test trials, a manufacturing industry 

association raised the point that innovation is hampered because of the limit for shipments of 

hazardous waste to 25kg (for research purposes) before requiring prior notification and consent. An 

environmental NGO responded that testing new technologies is not free from toxic and climate 

pollution (they raised the example of pyrolysis/gasification trials with a concerning lack of transparency 

on environmental impacts). 

At the end of the open floor session the consultants made a final assumption that all stakeholders seem 

to be in agreement on the suggestion that sharing of good practices is a positive approach and would be 

helpful in addressing some of the issues identified under specific objectives discussed.  

Stakeholders were asked on a Sli.do poll which aspects of the WSR would be best to address in 

delegated acts (see Error! Reference source not found.). Most stakeholders favoured delegated acts 

addressing adaptation to new digital opportunities (27 stakeholders, 77%). 

Sli.do Poll: Which aspects of the WSR would be best addressed through Delegated Acts? (n=35) 

If stakeholders selected “other” they were able to provide an open response. Three stakeholders 

provided a response. All three noted issues with delegated acts, rather than anything else. One 

provided a Norwegian example where a delegated act was perceived to create clarity, but in the end 

created more confusion on the issue. 

234 

9%; 377%; 2740%; 14051015202530Other (please specify)Adaptation to new digital opportunitiesChanges to the Annexes of the Regulation 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Day Two 

At the start of Day Two the consultants provided another introduction to the workshop for those 

attendees that had not taken part on the first day of the workshop. It was also noted, following on from 

Day One that the issue of ships and contamination of wastes would be added to the end of the agenda 

on Day Two. 

Objective 2: Better guaranteeing that waste shipped outside the EU is 
managed in an environmentally sound manner 

The consultants introduced objective two of the assessment of options to workshop attendees. Under 

this objective the following aims were identified: 

• 

To reduce export of waste from the EU to third countries in order to recover the economic 

value of such waste and to ensure impacts on the environment and climate change resulting 

from such export are avoided or minimised. 

• 

To verify the environmentally sound management (ESM) of wates exported from the EU to third 

countries. 

• 

To better classify waste that is shipped – noting that this had been subject to discussion on Day 

One. 

Discussions then moved on to the specific objectives under objective 2. 

3.1  Specific objective 2A – Stop or restrict export of waste outside the EU 

The specific objective here is to restrict exports outside the EU of waste that have potentially harmful 

environmental and health impacts in third countries or can be treated domestically within the EU. This 

should help ensure the environmentally sound management of waste in the EU and in third countries, 

possibly by focusing on countries of destination, problematic waste streams, and types of waste 

operations that are a source of concern. 

Attendees were asked for information concerning the environmental standards applied in third 

countries for the treatment of hazardous and non-hazardous wastes on Sli.do with the following 

responses were provided (and not necessarily agreed on by the group – rather these are individual 

responses). 

• 

• 

The treatment in third countries is insufficient. 

Third countries may have high rates of domestic waste mismanagement, revealing a potential 

conflict between recycling of imported wastes in third countries being favoured over effective 

management of domestic waste. 

• 

Third countries importing EU waste for recovery are aware of EU standards and information on 

the measures and standards applied to the treatment of EU wastes in third countries is 

generally known to exist, albeit it may not always be easy to access it. 

• 

Traceability projects are ongoing with end user consumer sites to be assessed by external 

auditors addressing environmental protection. 

• 

There is guidance that has been prepared in the context of the Basel Convention and OECD 

Decision that looks to promote ESM in third countries. 

•  One NGO made reference to the publications ‘The recycling myth 2.0: The Toxic After-Effects 

of Imported Wate in Malaysia’ ‘Discarded Communities on the Frontlines of The Global Plastic 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

Crisis’ ‘Plastic & Health: The Hidden Costs of a Plastic Planet’ ‘Illegal Trafficking of Plastic 

Waste: The Italy–Malaysia Connection’ ‘IMPEL (February 2020). WasteForce Crime Alert #5’ 

•  One MS noted that in the negotiations concerning the Basel amendments on plastic waste 

problems with the ESM of plastic waste in a number of OECD countries came to light. The 

export of its waste is mainly to its neighbouring countries, with the exception of Turkey. The 

(sometimes illegal) export of plastic waste to Turkey increased very rapidly since 2017, after 

several Asian countries closed their borders to various types of waste and the poor processing 

of this waste in Turkey received a lot of media attention in 2019 and generated various 

questions in political and public circles. 

• 

There are very different situations. Some facilities have high environmental standards, some 

do not. The EU cannot just decide yes or no to shipping waste. What is important is the quality 

of the treatment once there. 

•  One MS noted that for non-OECD countries, facilities quite often have import licences, ISO 

certificates, water pollution licences etc but none of these guarantee the ESM of the waste 

destined for those facilities. 

• 

recycling standards and technical specifications for high environmental performance exist: R2, 

e-stewards, WEEELabex, IEEE1680.2, IEEE1690.3, Canadian Stewardship programs, AS NZ 5377, 

UL2799 Zero Waste, CENELEC 50625 for WEEE - and for management systems EMAS, ISO14001. 

• 

Parties to the Basel Convention transmit information in the annual national reports on waste 

management facilities that may contain helpful information in respect to ESM in third 

countries. 

• 

It is counterproductive to restrict exports of Green List Waste outside of the EU when within 

the EU, the market for recycling of such waste in an economical manner needs to be fully 

developed. In addition, the attendee considered that ensuring the waste being exported in an 

environmentally sound manner is very difficult to prove particularly there is no clear protocol 

with scientific data that could support it. 

Attendees were presented with the five measures being considered in respect to the stopping or 

restriction of exports from wate from the EU to third countries as well as an overview of their likely 

impacts. 

• 

Sub-Measure 2a1: Maintain the current legal regime and facilitate its implementation – 

primarily by improving the operation of Regulation 1418/2007 by establishing a mechanism by 

which data is collected from third-countries but then placed onto an interactive web platform 

that can be updated without having to update the Regulation 1418/2007 itself. 

•  Measure 2a2: Ban export of all waste outside the OECD, except for third countries which notify 

the EU of their willingness and readiness to import such waste - Under this measure, the waste 

shipment regulation would set up a prohibition to export waste outside the OECD by default. 

This ban would apply except for 3rd countries which notify the Commission their willingness to 

import certain green-listed waste and demonstrate their ability to deal with them in an 

environmentally sound manner, according to criteria to be set out in the WSR (for example the 

notification of the domestic legislation on waste management, the notification of the facilities 

licensed to manage the waste in question, as well as compliance with the reporting obligations 

of the country concerned under the Basel Convention and status of implementation of 

technical guidelines on ESM adopted under the Basel Convention). If these countries comply 

with the criteria, the Commission should include them in a list of countries which would be 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

authorized to import waste from the EU. This list would be adopted through 

implementing/delegated act and regularly updated. 

Measure 2a3: Require that the export of green-listed waste outside the OECD is subject to the “prior 
written notification and consent” (PIC) procedure where it is allowed – Under this measure, each 
export 

• 

of green-listed waste will be conditional upon explicit authorization by countries of export and 

import, through the PIC procedure. This would not prevent countries prohibiting the import of 

waste from continuing to do so 

•  Measure 2a4: Restrict exports to OECD countries– By aligning the regime for OECD countries 

with the regime applying to other third-countries or requiring that the “prior written 

notification and consent” procedure is applied for some green-listed wastes which present 

particular challenges for their treatment (for example unsorted plastic waste). 

•  Measure 2a5 – Ban all exports of waste– Under this measure, a general prohibition to export 

waste to 3rd countries would be established through the WSR, with a possible transition period 

to phase in this prohibition (i.e. this ban would become effective two years after the entry into 

force of the revised version of the waste shipment regulation). 

Furthermore, one MS queried the level of information that would be provided under 2a1 and whether 

this would be held online, as well as questioning that keeping waste materials inside the EU would 

cause material values to increase was raised (this was later clarified that as a result of greater volumes 

of waste being retained the value of wastes in total would likely increase.) On social impacts, it was 

noted that the proposed changes would create employment and decrease dumping and burning of 

waste. It was also mentioned noted that ESM exists in some third countries and the impacts on such 

countries of the proposed measures (prohibition of export) should be considered.  

One Member State’s representative again raised concerns with regard to the legality of the measures 

proposed. By way of example, the Annex to Regulation 1418/2007 has four columns (A,B,C,D), of which 

the first three, providing for prohibition and applicable procedures, need to have a legal basis in a legal 

act and cannot just be on a website that could be changing daily. Competent Authorities need legally 

binding provisions to enforce. Furthermore, for 2a5 (ban all exports of waste), as well as 2a4: the OECD 

decision would not allow this. For those measures addressing non-OECD rules, WTO rules need to be 

taken into account. This argument was supported by other MS. The EU commission mentioned that this 

aspect will be legally clarified. 

One recycling association, supported by other business representatives, stated that they agree that 

exports of waste outside the EU that are not up to EU standards are not sustainable. However, in 

respect to the proposed measures two levels of analysis are required - legal and political/commercial. 

On the legal side this stakeholder agreed with remarks made considering legality of options. Concerning 

the issue of processed and un-processed wastes and the effects of what is being exported it is 

important to distinguish between hazardous and non-hazardous waste as processes are different. 

Thirdly, most of the EU economy is linear and only 20% of raw materials come from recycling from a 

number of streams. There should be sufficient demand for secondary raw materials before any bans are 

introduced, to avoid that the market for these markets will collapse. We need more measures to ensure 

products use recycled materials and incentives for such things. The key to focus on is to ensure that 

waste is not sent to places where it would be unsustainable. But to achieve this we need to ensure that 

237 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

we use more secondary raw materials within the EU. In support of this view, another stakeholder from 

the waste management sector stressed that the revision of WSR should distinguish between waste that 

has not been processed and is to undergo treatment operations outside the EU and waste to be traded 

on raw material market as a secondary material. 

An environmental NGO recalled that the main aim of the Basel Convention is to limit transboundary 

movement. Furthermore, the recent EU Circular Economy action plan noted that the EU should not 

export its waste challenges. Determining ESM for a facility far away, and not looking at the local 

context (local law, poverty etc.), is wrong and, therefore 2a5 is a better option for addressing this 

issue, in this stakeholder’s opinion. 

One Member State welcomed the measures proposed, particularly measure 2a2 – if foreign countries 

explicitly explain they want a type of non-hazardous waste then export should be possible. For 

problematic waste take back procedures need to still take place. A further Member State considered 

that improvements in the timeliness of information on rules for exporting waste to non-OECD countries 

would be beneficial. 

Another MS noted that control regimes are a complex issue, and consistency with international law is 

very important.  

Another Member State expressed its support for measure 2a5 banning the export of all wastes to all 

third countries. They believe, as noted in the Green Deal, that the EU must handle its own waste and 

keep as many secondary raw materials as possible for the circular economy. In this MS, industry is 

asking for export restrictions. New facilities are only going to materialise within the EU if a consistent 

flow of secondary raw materials is guaranteed. All international legal obligations should be followed, 

but solutions can be found. Furthermore, an export ban would further reduce illegal trade. Lastly, this 

MS considered the need for exemptions for regions or for waste streams was not required.  

A manufacturing industry representative considered that in principle the EU should impose a system 

that places burden of proof on exporters to ensure waste is treated sustainably. Also, the export of 

waste will contribute to the same European goals. Burden of proof would ensure that other countries 

have to prove EU standards in treating waste. One stakeholder considered that there remains a need for 

instruments that encourage secondary raw materials to be more accessible in the EU. However, the EU 

should follow international obligations as noted in the DE response. 

A waste treatment company noted the continued need for exports to take place given capacity 

restrictions and a lack of a market for the resulting product (e.g. in regard to paper). There needs to be 

due diligence and traceability to ensure exported wastes is subject to ESM and the company is working 

on developing some measures for this. 

An environmental NGO was concerned at the apparent discrepancy in discussing the lack of capacity of 

recycling right now in the EU that is also likely to be the case in third countries. They argued further 

that it should be avoided to off-load the waste to countries outside the EU because at the moment EU 

capacity is lacking. The WFD sets recycling targets until 2035 and there is a set of legislation to 

incentivize recycling within the EU. Even beyond recycling the CEAP plans to have further measures on 

waste prevention etc. The NGO considered it important to stop thinking in silos and just thinking of 

238 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

shipments when there is already an ambitious plan to deal with the capacity issue in the EU. Therefore, 

measure 2a5 is not just one measure but embedded in many measures that already exist.  

One MS considered the issue of ESM as important to be addressed. Given the restrictions already 

existing under Basel, the focus of measures should be on green listed waste, with several considerations 

(including legal) to be taken into account.  

Another MS also noted in a second intervention that it supported general export bans, because general 

risks to third countries from poorly managed EU wastes are high. This MS questioned whether retaining 

EU waste within the EU would cause the recycling market to crash and considered this unlikely.  

The following Sli.do polls were also undertaken in respect to this objective: 

What impacts would a ban on all export of waste from the EU to 3rd 
countries have on current treatment capacity in the EU?

Other – please specify in writing below

Impossible to say – Too many factors enter into 
consideration so any prediction would be uncertain

None – The EU could manage these wastes presently

Small – It would take less than 2 years to ensure that 
all wastes could be managed within the EU
Medium – it would take 2-5 years to ensure that all 
wastes could be managed within the EU
Large– it would take 5 years or more for the EU to be 
able to build sufficient capacity to handle the …

0

2

4

6

8

10

12

14

Under the responses to ‘Other’ it was noted that the additional text generally reflected on the concerns 

relating to treatment capacity within the EU and legal contradictions. 

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Exploration of potential policy responses to review the Waste Shipment Regulation 

What impacts would a ban on export of all waste outside the OECD, 
except for 3rd countries which notify the EU of their willingness to import 
EU waste and their ability to deal with it in a sustainable manner have on 
current treatment capacity in the EU?

Other – please specify in writing below

Impossible to say – Too many factors enter into 
consideration so any prediction would be uncertain

None – The EU could manage these wastes presently

Small – It would take less than 2 years to ensure that 
all wastes could be managed within the EU

Medium – it would take 2-5 years to ensure that all 
wastes could be managed within the EU

Large– it would take 5 years or more for the EU to be 
able to build sufficient capacity to handle the wastes 
currently exported to third countries

0

2

4

6

8

10

12

Under the responses to ‘Other’ it was noted that: 

• 

This could be a practical way to implement a certain guarantee exported (green listed) waste 

will be treated according to ESM. In the short term (years) there will be capacity problems with 

processing within the EU. Possible complication: the distinction between waste and non-waste. 

• 

In the spirit of a global circular economy, recoverable wastes are a resource and should not be 

subject to export bans as a matter of principle. Support was expressed for the free movement 

of all wastes for recovery, inclusive of the third countries, provided that those countries can 

handle and treat waste safely and can thus ensure the protection of the environment and 

human health. 

Would an approach that restricts exports based on the types of waste 
rather than a general export ban achieve the same aims to address 
environmentally sound management in third countries? 

I don’t know

No

Yes

0

2

4

6

8

10

12

14

16

18

20

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Exploration of potential policy responses to review the Waste Shipment Regulation 

If new restrictions on export outside the EU were put in place, which 
wastes should such restrictions apply to (you can choose more than one)?

35
30
25
20
15
10
5
0

Under other responses, batteries that are not currently listed (e.g. Li-ion) should be included, streams 

based on a risk assessment related to risks of increased illegal traffic, ships, electronic circuit boards, 

non-functional electronic equipment, wastes that cannot be treated in an ESM manner (based on 

criteria to be developed) and tyres were listed. It was acknowledged that certain waste streams 

currently sit outside of the WSR including end of life vessels. 

Specific objective 2b – Verify ESM in destination countries 

Attendees were presented the measures identified to better monitor the export of EU waste and their 

treatment in third countries. The two measures are: 

• 

Clarify the criteria to be taken into consideration to assess if waste treated in third countries 

are managed in an environmentally sound manner. This could require adding provisions 

referring to the conditions set out in Article 13 of the Waste Framework Directive, removing 

the reference to ‘broad equivalence’ in Article 49(2) and/or checking how the Basel guidelines 

on ESM contained in Annex VIII are applied in these countries. 

• 

The creation of a dedicated body at the EU level with the task to monitor export of waste as 

well as their treatment in third countries. This body will be responsible for performing checks 

on producers, holders, collectors, dealers, brokers, consignees and notifiers within the waste 

shipment process chain. 

In response to the slides presented: 

• 

Two Member State representatives noted that greater clarity on the criteria to assess ESM is 

helpful however performing the assessment will be difficult outside of the EU. Experience from 

the ship recycling regulation shows that checking facilities outside of the EU has a large time 

and cost burden. 

• 

Another Member State representative explained that Article 49 of the WSR is currently difficult 

to implement and it is worth considering potential options, however Article 13 of the Waste 

Framework Directive is not appropriate as it is mostly covered already in Article 49(1) of the 

WSR.  

• 

The same stakeholder notes that the Principle of Subsidiarity is important when considering the 

creation of a dedicated body at the EU level. In addition, the decision on a dedicated body at 

EU level needs to define what provisions are necessary first, then ask who best placed to take 

241 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

on those responsibilities. Following this it will be possible to determine if a dedicated EU body 

can help verify ESM. 

• 

Still the same stakeholder highlighted that Producer Responsibility Organisations (PRO) and EPR 

schemes have good potential drawing on experience from packaging law in Germany which has 

rules on ensuring packaging recycling targets are met. These national provisions include 

checking facilities outside the EU and might be consulted for inspiration for this review of the 

WSR.  

Two Sli.do polls were undertaken against this objective with the response showing that attendees were 

most in favour to add provisions referring to conditions set out in Article 13 of the Waste Framework 

Directive. In addition, stakeholders appeared to support the development of a dedicated EU body. 

What changes could be made to the WSR (notably Article 49) to ensure that exported 
wastes are managed in a sustainable manner in third countries?

No change necessary to the WSR on these issues

15%

Extend the role of Producer Responsibility
Organisations to verify that exported waste are…

Add provisions requiring to check how the Basel
guidelines on ESM contained in Annex VIII are…

Remove reference to ‘broad equivalence’ with EU 
standards in Article 49(2).

Add provisions referring to conditions set out in
Article 13 of the Waste Framework Directive.

38%

46%

27%

0%

20%

40%

Would you rather support the creation of a dedicated body at the EU level to verify that 
waste are managed in an ESM in 3rd countries or the allocation of this responsibility to an 
existing EU body?

Neither

30%

58%

60%

Extending responsibility of existing body

19%

Dedicated new body

52%

0%

20%

40%

60%

242 

 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Objective 3: Better preventing and addressing illegal shipments of waste 

Specific Objective 3a – Further strengthen the WSR’s provisions on enforcement and inspections 

Attendees were presented the measures identified to improve enforcement and inspection of waste 

shipments across the EU. The two measures are: 

• 

Strengthening of the WSR provisions in Article 50, with the aim to facilitate inspections, 

increase efficiency of enforcement operations and provide for deterrent sanctions, if it appears 

that the changes done through the changes in the WSR in 2014 on these questions are not 

sufficient, as well as on reporting of inspection plans so that more information can be made 

available at EU level and to other Member States for better cooperation against illegal 

shipments. 

• 

The creation of a dedicated body/forum at the EU level with the task to monitor and improve 

cooperation between EU Member States on waste shipment enforcement, by sharing best 

practices, intelligence and activities ongoing. This group could take the form of a Commission 

Expert Group bringing together those bodies relevant for enforcement of the WSR – namely 

competent authorities, customs authorities, Europol, OLAF and the judiciary of the Member 

States. This body would have no direct enforcement/inspection prerogatives. 

The following comments were provided from attendees: 

•  Member State representatives noted that IMPEL currently provide many tools to help inspection 

and enforcement for practitioners. There is overlap between the proposed EU forum and the 

tools provided by IMPEL, additionally, the Correspondence Group provide guidelines on 

enforcement. The representatives would prefer the use of these existing tools, rather than 

creating a new forum.  

• 

Representatives of IMPEL confirmed the overlap of their own work and the responsibilities 

envisaged by EU forum on inspection and enforcement. It was noted that IMPEL also produced a 

list of verified facilities in third countries. A key limitation of IMPEL is the lack of a legal 

mandate to act on behalf of the EU, voluntary participation and incomplete representation of 

EU Member States, however the stakeholder added that the EU forum will also be dependent 

on input from competent authorities who have limited capacity. 

• 

Administrative errors creating illegal shipment of waste was highlighted by stakeholders from 

Member States, trade associations and NGOs. . Improving legislation to avoid that 

administrative errors being classed as illegal activities would create greater capacity for 

addressing more concerning illegal issues. 

• 

An environmental NGO noted that current sanctions are not a strong deterrent, with low 

penalties and little jail time. A representative from a Member State explained that the 

prosecution process is creating a bottleneck impacting the legal action. The Commission noted 

that the EU Environmental Crime Directive is currently under evaluation and will inter alia 

address sanctions on environmental crime in general.  

The stakeholders were presented two polls on Sli.do relating to the two sub-measures. The questions 

and results are presented below. 

243 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Specific Objective 3b – Increase efficiency in the fight against illegal shipments of waste at EU and 

national levels and strengthen cooperation across the EU and with international partners 

Attendees were presented the measures to strengthen cooperation. The two measures are: 

• 

Improve enforcement and inspection across the EU by providing guidance documents on 

sanction and penalties, intelligence led inspection activities, prioritising action to address 

illegal waste shipments and efficient use of staff to maximise impact on illegal activities. 

• 

Enhance cooperation with inspection and enforcement bodies beyond the EUs borders by 

working closer with greater advocacy at a global level and financial support for bilateral, 

regional and global projects. 

The following comments were provided: 

• 

A Member State representative indicated that IMPEL already produced guidance on the related 

topics. Furthermore, the stakeholder questions who would be responsible for enhancing the 

244 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

cooperation, they suggest it should be done at the EU level and cannot be done individually by 

Member States. 

• 

Representatives from IMPEL highlight their key area of expertise in international collaboration 

and links to bodies beyond the EU. IMPEL has strong collaboration with countries in Africa and 

Asia with whom they have regular interactions. These interactions, however, are on an 

informal basis and IMPEL lacks an official mandate or strategy, but still these contacts could be 

used to enhance cooperation.  

• 

A Member State representative welcomed the strengthening of measures for illegal shipment, 

mainly concerning the procedure of take-back, and control and whilst requesting more specific 

provisions on inspections, supported deeper harmonization of inspections. However, the 

representative cautioned that strengthening control will not be achieved in practice without 

sufficient capacity of control authorities. 

• 

Attendees were presented several open questions on this objective in Sli.do, the responses to 

these are presented in Error! Reference source not found. below. 

Attendees were presented a poll on Sli.do relating to the sub-measures on providing guidance 

documentation.  

Slido Question 

Responses 

• 

Government institutions competent for environment protection, internal and foreign 

affairs 

Which inspection and 

• 

International organizations such as WCO, UNODC, UNEP, EUROPOL and INTERPOL as 

enforcement bodies 

well as with organisations in targeted destination countries outside the EU.  

beyond EU borders 

• 

Regional and national organisation such as African Network, Asian Network and UK 

should we be working 

authorities. 

with? 

• 

• 

The EU missions in non-OECD countries could play a role. 

Consider  Basel  Regional  Centres  to  support  verifications  and  communication  with 

countries of destination, but they haven’t proven very helpful over the years.  

245 

 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

What could 

complement existing 

initiatives to improve 

enforcement against 

illegal waste? 

• 

The  UNODC  Container  Control  Programme.  Sometimes  international  actions  take 

place under INTERPOL and WCO, but these are not well coordinated at EU level among 

Env Inspectors, Customs and Police.  

• 

Legal clarity and harmonisation on issues such as contamination levels and “under 

jurisdiction” 

• 

The definition of “illegal shipment” put forward in the Waste shipment  regulation 

(article  2,  paragraph  35)  there  is  a  possibility  to  classify  shipments  with  false  or 

incomplete Annex VII or contracts as “illegal shipments”. This can push policy makers 

to believe that the issue is bigger than it currently is, and risk imposing over-stringent 

policies  on  traders  as  well  as  slowing  down  detection  of  “real”  illegal  shipments 

• 

• 

• 

• 

compared to those only with fill in issues. 

Greater cooperation among EU Member States and green NGOs  

Better guidance for inspectors and control bodies 

Greater tracking and more attention to green listed wastes  

Restrict brokers to operate only in EU countries, or to prohibit them to sell to brokers 

or traders outside the EU (meaning it is only possible to sell directly to processing 

facilities when outside of the EU).  

• 

On the EU platform, a list of brokers and traders should be made available. Clear 

criteria when and how traders and brokers can be suspended from this list (and thus 

in operating in the EU) should be made up.  

• 

Interim  processing  of  waste outside  the  EU  should  also  be  prohibited.  This  is  only 

needed if waste can still be exported outside the EU. In case a waste transport is not 

accompanied with an Annex VII document, the transport should be considered illegal.  

• 

Greater  cooperation  with  NGOs  that  have  specialised  insight  on  waste  flows  and 

business  practices  -  e.g.  NGO  Shipbreaking  Platform  has  successfully  collaborated 

with several enforcement authorities and provided crucial information that has led 

to investigations and charges. 

• 

Create a level playing field between all the actors of each MS in order to have more 

homogeneity inside the EU and to have actors who would be more environmentally 

concerned. 

• 

Increase  resources  of  the  judiciary,  funded  a  specialty  environmental  crime 

department 

• 

Legal mandated EU network/agency/body, like EMSA. Alternatively give IMPEL a legal 

basis and require Member State competent authorities to take part in specified TFS 

activities. 

• 

• 

Differing national interpretation on issues such as waste and non-waste. 

Capacity  and  cooperation  of  Competent  Authorities  (both  on  EU-side  as  in  third 

What are the likely 

countries). Authorities often do not have the time or resource to commit to this. It is 

barriers to improving 

difficult to get permission from senior managers to participate in such activities. 

international 

• 

It is performed by only some Member States independent from the EU, a legal EU 

cooperation? 

body would really be the solution for this. 

• 

• 

Lack of political will, trade agreements and industry obstructions. 

Lack of resources, expertise and language skills. 

246 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Additional issues considered during the workshop 

Two further points were added to the end of the second days agenda. These discussions are captured in 

Section 2.3 of this report. 

Next Steps:  

DG ENV and the consultants thanked the attendees for their active participation over the two days and 

were notified that a workshop report would be shared with participants for comment. 

DG ENV ended the meeting by notifying attendees that its aim is to continue the development of its 

impact assessment and to table a legislative proposal to revise the WSR in Spring 2021 and the work 

undertaken as part of the workshop will play a part in this process. 

Workshop Agenda 

Day One – 23 September 2020 – 9:30-13:00 CET 

Time 

9:30 

9:40 

9:50 

10:05 

10:25 

11:05 

11:45 

11:50 

12:25 

Session 
Welcome and instructions 

Project team  
Introduction and workshop context  

European Commission  
Overview of study by Wood and Trinomics - status of activities performed 

Project team 

General presentation of main challenges linked to the WSR 

Introduction and interactive discussions with participants 
Objective 1 – Intra-EU shipments of waste - How to ensure a smoother functioning of the EU 
internal market for waste and support the transition to a circular economy model.  

Presentation of the challenge by the project team 
Specific objective 1.1 – Better align rules governing intra-EU shipments of waste with the waste 
hierarchy and with existing EU legislation. 

Introduction to the challenge and interactive discussion with attendees on measures to address it 
Specific objective 1.2 – Simplify and reduce administrative burden linked to the implementation 
of the WSR. 

Introduction to the challenge and interactive discussion with attendees on measures to address it 

5-minute comfort break 
Specific objective 1.3 – Harmonise interpretation, application and enforcement across Member 
States. 

Introduction to the challenge and interactive discussion with attendees on measures to address it 
Specific objective 1.4 – Adaptation to technical progress 

Introduction to the challenge and interactive discussion with attendees on measures to address it 

12:50 

Summary of the session 

13:00 

End of first morning session 

247 

 
 
 
 
 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Day Two – 24 September 2020 – 9:30-13:00 CET 

Time 

9:30 

9:40 

10:00 

10:45 

11:30 

11:35 

11:50 

12:35 

12:45 

13:00 

Session 
Welcome and instructions 

Project team  
Objective 2 – Extra-EU shipments of waste - How to better guarantee that waste shipped outside 
the EU are managed in an environmentally sound manner  

Presentation of the challenge by the project team 
Specific objective 2.1 – Stop or restrict export of EU waste to third countries 

Introduction to the challenge and interactive discussion with attendees on measures to address it 
Specific objective 2.2 – Verify Environmentally Sound Management (ESM) in destination countries 

Introduction to the challenge and interactive discussion with attendees on measures to address it 

5-minute comfort break 
Objective 3 – Better prevent and address illegal shipments of waste  

Presentation of the challenge by the project team 
Specific objective 3.1 – Further strengthen the WSR’s provisions on enforcement and inspections 
and strengthen cooperation across the EU and with international partners 

Introduction to the challenge and interactive discussion with attendees on measures to address it 
Additional issues that stakeholders may wish to raise 

Attendees can raise additional issues that have not been addressed in the workshop 

Closing remarks from the project team and the European Commission 

Close of workshop 

Workshop Attendees  

Day One 

Attendee 

number 

Organisation 

Stakeholder category (our assessment) 

1 

2 

3 

4 

5 

6 

7 

8 

9 

Inspectorate of environment and spatial planning of 

Republic of Slovenia 

Member State 

The Association of Medical Device Reprocessors (AMDR) 

Recycling / materials trade association 

Association of Independent Secondary Raw Materials 

Processors (ANSDS) 

Waste treatment trade association 

Home Appliance Europe (APPLiA) 

Company / business organisation 

Italian non-ferrous metals association represent the 

Italian non-ferrous metals producers, transformers and 

Company / business organisation 

recyclers (Assomet) 

Austrian Mining and Steel Association, Austrian Non-

Ferrous Metals Federation 

Basel Action Network 

Company / business organisation 

Environmental NGO 

Public Waste Agency of Flanders (OVAM) 

Member State 

Bureau of International Recycling (BIR Aisbl) 

Waste NGO 

10 

11 

12 

CEMBUREAU 

Cepi 

Cerame-Unie 

Company / business organisation 

Company / business organisation 

Company / business organisation 

248 

 
 
 
 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Attendee 

number 

Organisation 

Stakeholder category (our assessment) 

13 

14 

15 

16 

17 

18 

19 

20 

21 

CEWEP - Confederation of European Waste-to-Energy 

Plants 

Waste treatment trade association 

CIEL - Center For International Environmental Law 

Environmental NGO 

Country Administrative Board of Norrbotten 

County Administrative Board of Gävleborg 

Danish Environmental Protection Agency 

Member State 

Member State 

Member State 

Derichebourg 

DigitalEurope 

Company / business organisation 

Company / business organisation 

EBRA (European Battery Recycling Association) 

Recycling / materials trade association 

European Environment Agency 

European Institution Body 

22-23 

European Environmental Bureau (EEB) 

Environmental NGO 

24 

25 

European Electronic Recyclers Association (EERA) 

Waste treatment trade association 

Environmental Investigation Agency (EIA) 

Environmental NGO 

26-27 

Environment & Resources Authority Malta 

28-29 

Environment Agency of Iceland 

Estonia Environmental Board 

Member State 

Member State 

Member State 

30 

31 

32 

33 

Environmental Investigation Agency 

Environmental NGO 

Environmental protection agency ( Lithuania) 

Member State 

European Suppliers of Waste-to-Energy Technology 

(ESWET) 

Waste treatment trade association 

34-35 

European Association for Coprocessing (EUCOPRO) 

Waste treatment trade association 

36-38 

European Recycling Industries’ Confederation (EuRIC ) 

Waste treatment trade association 

39 

40 

41 

42 

43 

44 

EUROFER - The European Steel Association 

Company / business organisation 

EUROGYPSUM 

Eurometaux 

Euromines 

European Aluminium 

Company / business organisation 

Company / business organisation 

Company / business organisation 

Company / business organisation 

European Carbon and Graphite Association (ECGA) 

Company / business organisation 

45-47 

European Chemical Industry Council (Cefic) 

Company / business organisation 

48-50 

European Commission 

European Institution  

51 

52 

53 

54 

55 

European Furniture Industries Confederation 

Company / business organisation 

European Precious Metals Federation (EPMF) 

Company / business organisation 

European Remanufacturing Council 

Waste treatment trade association 

EUROSHORE INTERNATIONAL 

Company / business organisation 

European Federation for Waste Management and 

Environmental Services (FEAD) 

Waste treatment trade association 

56-57 

Federal Environment Ministry, Germany 

Member State 

58-59 

Federation of the European Sporting Goods Industry 

Company / business organisation 

60 

Fédération professionnelle des entreprises du recyclage 

(FEDEREC) 

Recycling / materials trade association 

61-62 

European Federation of Glass Recyclers (FERVER) 

Recycling / materials trade association 

63 

64 

65 

Finnish Environment Institute 

Member State 

Finnish Scrap dealers Association  

Recycling / materials trade association 

Association of Circular Economy Enterprise (FISE 

UNICIRCULAR ) 

Waste treatment trade association 

66-67 

Geminor 

Waste treatment company 

249 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Attendee 

number 

Organisation 

Stakeholder category (our assessment) 

68 

Global Alliance for Incinerator Alternatives (GAIA) 

Environmental NGO 

69-71 

Hazardous Waste Europe 

Waste treatment trade association 

72 

73 

74 

Hellik Teigen AS 

Waste treatment company 

Hessian Ministry of the Environment, Climate 

Protection, Agriculture and Consumer Protection 

Member State 

Hungarian Waste Management Federation (HOSZ) 

Waste treatment trade association 

75-76 

IKEA 

77 

IMPEL 

78-81 

INTERPOL 

Company / business  

European Competent Authority Group 

International Agency 

Irish Ministry of Environment 

Ministerstvo životního prostředí / Ministry of 

Environment, Czechia 

Ministry of Economy and Sustainable Development 

Croatia 

Ministry of Environment - FRANCE 

Ministry of Environment - PNTTD (French competent 

authority) 

Member State 

Member State 

Member State 

Member State 

Member State 

MINISTRY OF ENVIRONMENT AND ENERGY - GREECE 

Member State 

82 

83 

84-85 

86 

87 

88 

89 

90 

Ministry of Environment and Food of Denmark 

Ministry of the Environment of Estonia 

91-92 

National TFS Office, Dublin City Council 

Member State 

Member State 

Member State 

93 

94 

95 

NL - Ministry of Infrastructure and Water Management 

Member State 

Norwegian Environment Agency 

Member State 

PAPREC 

Recycling / materials trade company 

96-97 

Plastics Recyclers Europe 

Recycling / materials trade association 

98 

99 

100 

101 

PlasticsEurope 

POLYECO S.A. 

Company / business organisation 

Waste treatment company 

Portuguese Environment Agency 

Member State 

Portuguese Permanent Representation to the EU 

Member State 

102-103 

Repak 

104 

RHI Magnesita 

Environmental NGO 

Company / business  

105-106 

State Environmental Service of Latvia 

Member State 

107 

108 

Steel Impex 

SUEZ 

109-111 

Swedish EPA (Naturvårdsverket) 

112-114 

Trinomics 

115 

UNEP/SECRETARIAT OF THE BASEL, ROTTERDAM AND 

STOCKHOLM CONVENTIONS  

116-117  WOOD Plc 

118-119  WVMetalle 

Recycling / materials trade company 

Company / business  

Member State 

Consultant 

International Body 

Consultant 

Company / business organisation 

120 

Zero Waste Europe 

Environmental NGO 

250 

 
 
 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Day Two 

Attendee 

number 

1 

Organisation 

Stakeholder category 

Inspectorate of environment and spatial planning of 

Republic of Slovenia 

Member State 

2-3 

Ambiendura 

Company / business organisation 

4 

5 

6 

7 

8 

9 

10 

11 

12 

13 

14 

Association of Independent Secondary Raw Materials 

Processors (ANSDS) 

Aperam 

Waste treatment trade association 

Company / business organisation 

Home Appliance Europe (APPLiA) 

Company / business organisation 

Italian non-ferrous metals association represent the 

Italian non-ferrous metals producers, transformers and 

Company / business organisation 

recyclers (Assomet) 

Austrian Mining and Steel Association, Austrian Non-

Ferrous Metals Federation 

Basel Action Network 

Company / business organisation 

Environmental NGO 

Public Waste Agency of Flanders (OVAM) 

Member State 

Bureau of International Recycling (BIR Aisbl) 

Waste NGO 

CEMBUREAU 

Cerame-Unie 

CEWEP - Confederation of European Waste-to-Energy 

Plants 

Company / business organisation 

Company / business organisation 

Waste treatment trade association 

15-16 

CIEL - Center For International Environmental Law 

Environmental NGO 

17 

18 

19 

20 

21 

22 

23 

Country Administrative Board of Norrbotten 

County Administrative Board of Gävleborg 

Danish Environmental Protection Agency 

Member State 

Member State 

Member State 

Derichebourg 

DigitalEurope 

Company / business organisation 

Company / business organisation 

EBRA (European Battery Recycling Association) 

Recycling / materials trade association 

European Environment Agency 

European Institution Body 

24-25 

European Environmental Bureau (EEB) 

Environmental NGO 

26 

Environmental Investigation Agency (EIA) 

Environmental NGO 

27-28 

Environment & Resources Authority Malta 

29-30 

Environment Agency of Iceland 

Estania Environmental Board 

Member State 

Member State 

Member State 

31 

32 

33 

34 

Environmental Investigation Agency 

Environmental NGO 

Environmental protection agency ( Lithuania) 

Member State 

European Suppliers of Waste-to-Energy Technology 

(ESWET) 

Waste treatment trade association 

35-36 

European Association for Coprocessing (EUCOPRO) 

Waste treatment trade association 

37-40 

European Recycling Industries’ Confederation (EuRIC ) 

Waste treatment trade association 

41 

42 

43 

EUROFER - The European Steel Association 

Company / business organisation 

Eurometaux 

Euromines 

Company / business organisation 

Company / business organisation 

251 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Attendee 

number 

Organisation 

Stakeholder category 

44 

45 

46 

European Aluminium 

Company / business organisation 

European Automobile Manufacturers' Association – ACEA     Company / business organisation 

European Carbon and Graphite Association (ECGA) 

Company / business organisation 

47-49 

European Chemical Industry Council (Cefic) 

Company / business organisation 

50-52 

European Commission 

European Institution  

53 

54 

55 

56 

57 

European Furniture Industries Confederation 

Company / business organisation 

European Precious Metals Federation (EPMF) 

Company / business organisation 

European Remanufacturing Council 

Waste treatment trade association 

EUROSHORE INTERNATIONAL 

Company / business organisation 

European Federation for Waste Management and 

Environmental Services (FEAD) 

Waste treatment trade association 

58-59 

Federal Environment Ministry, Germany 

Member State 

60-61 

Federation of the European Sporting Goods Industry 

Company / business organisation 

62 

Fédération professionnelle des entreprises du recyclage 

(FEDEREC) 

Company / business organisation 

63-64 

European Federation of Glass Recyclers (FERVER) 

Recycling / materials trade association 

65 

66 

67 

68 

Finnish Environment Institute 

Member State 

Finnish Scrap dealers Association  

Recycling / materials trade association 

Association of Circular Economy Enterprise (FISE 

UNICIRCULAR ) 

Waste treatment trade association 

Fédération Nationale des Activités de la Dépollution et 

de l’Environnement (FNADE) 

Company / business organisation 

69-70 

Geminor 

Waste treatment company 

71 

72 

73 

German Environment Agency 

Member State 

Glencore 

Company / business organisation 

Global Alliance for Incinerator Alternatives (GAIA) 

Environmental NGO 

74-76 

Hazardous Waste Europe 

Waste treatment trade association 

77 

78 

79 

80 

81 

Hellik Teigen AS 

Waste treatment company 

Hessian Ministry of the Environment, Climate 

Protection, Agriculture and Consumer Protection 

Member State 

Hungarian Waste Management Federation (HOSZ) 

Waste treatment trade association 

IKEA 

IMPEL 

Company / business  

European Competent Authority Group 

82-85 

INTERPOL 

International Agency 

86 

87 

88-89 

90 

91 

Irish Ministry of Environment 

Ministerstvo životního prostředí / Ministry of 

Environment, Czechia 

Ministry of Economy and Sustainable Development 

Croatia 

Member State 

Member State 

Member State 

Ministry of Environment - FRANCE 

Member State 

Ministry of Environment - PNTTD (French competent 

authority) 

Member State 

252 

Exploration of potential policy responses to review the Waste Shipment Regulation 

Attendee 

number 

Organisation 

Stakeholder category 

92 

93 

94 

MINISTRY OF ENVIRONMENT AND ENERGY - GREECE 

Member State 

Ministry of Environment and Food of Denmark 

Member State 

Ministry of the Environment of Estonia 

Member State 

95-97 

National TFS Office, Dublin City Council 

Member State 

98 

99 

NL - Ministry of Infrastructure and Water Management 

Member State 

Norwegian Environment Agency 

Member State 

100 

PAPREC 

Recycling / materials trade company 

101-102 

Plastics Recyclers Europe 

Recycling / materials trade association 

103 

104 

105 

106 

PlasticsEurope 

POLYECO S.A. 

Company / business organisation 

Waste treatment company 

Portuguese Environment Agency 

Member State 

Portuguese Permanent Representation to the EU 

Member State 

107-108 

Repak 

109 

RHI Magnesita 

Environmental NGO 

Company / business  

110-111 

State Environmental Service of Latvia 

Member State 

112 

113 

Steel Impex 

SUEZ 

Recycling / materials trade company 

Company / business  

114-117 

Swedish EPA (Naturvårdsverket) 

Member State 

118 

The County Administrative Board of Stockholm 

Member State 

119-120 

Trinomics 

121 

UNEP/SECRETARIAT OF THE BASEL, ROTTERDAM AND 

STOCKHOLM CONVENTIONS  

122-123 

WOOD Plc 

124 

Zero Waste Europe 

Consultant 

International Body 

Consultant 

Environmental NGO 

253 

 
Exploration of potential policy responses to review the Waste Shipment Regulation 

Annex 3: List of references 

Books / papers / reports 

Access Economics https://www.environment.gov.au/system/files/resources/5cc6a848-a93e-4b3f-abf7-

fc8891d21405/files/waste-and-recycling-employment.pdf, The Department of the Environment, Water, 

Heritage and the Arts, 2009. 

Bassi, S., Boldrin, A., Faraca, F., and Astrup, T. F., Extended producer responsibility: How to unlock the 

environmental and economic potential of plastic packaging waste?, Resources, Conservation and 

Recycling, 162, 2020. 

Bishop, G., Styles, D., Lens, P., Recycling of European plastic is a pathway for plastic debris in the 

ocean, Environment International, 2020. 

Cascadia, Recycling and economic development: a review of existing literature on job creation, capital 

investment, and tax revenues, King Country Linkup, 2009. 

CIEL, Earthworks, Healthy Babies Bright Futures, IPEN, TEJAS, UPSTREAM, GAIA Plastic & Health: The 

Hidden Costs of a Plastic Planet, 2019. 

Clavreul, J., Baumeister, H., Christensen, T. H., and Damgaard, A., An environmental assessment 

system for environmental technologies, Environmental Modelling & Software, 60, 2014, pp. 18-30. 

Cogut, A, Open burning of waste: A global health disaster, R20 Regions of Climate Action, 2016.  

DEFRA, Energy from waste A guide to the debate, 2014.  

Dutch Government, Annex IX “additional questionnaire for reports by Member States pursuant to Article 

51(2)” to European Commission “Regulation (EC) No 1013/2006 of the European Parliament and of the 

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255 

Exploration of potential policy responses to review the Waste Shipment Regulation 

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256 

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transboundary shipment of hazardous waste and other waste in the Member States of the European 

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https://ec.europa.eu/eurostat/web/products-eurostat-news/-/DDN-20200416-1  

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EF datasets http://lcdn.thinkstep.com/Node/  

Eurostat ENV_WASGEN 

https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_wasgen&lang=en 

Eurostat ENV_WASTRT https://appsso.eurostat.ec.europa.eu/nui/show.do?dataset=env_wastrt&lang=en 

Eurostat: WShipR https://ec.europa.eu/eurostat/statistics-

explained/index.php/Waste_shipment_statistics 

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1.344113 

OECD (2021) database on Transboundary Movements of Wastes  

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effects-of-imported-plastic-waste-in-malaysia/  

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regions-in-the-sustainable-development-scenario-2000-2040  

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https://www.legifrance.gouv.fr/codes/id/LEGIARTI000042176104/2020-07-31/ 

https://www.statista.com/statistics/281050/major-target-countries-for-steel-scrap-imports/  

The New York Times (2018) “In Sweden, Trash Heats Homes, Powers Buses and Fuels Taxi Fleets”. 

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World Bank (2020) What a Waste Global Database - Country level dataset   

https://www.wto.org/english/tratop_e/envir_e/envt_rules_exceptions_e.htm 

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Annex 4 List of CN codes used in the 
determination of waste flows 

Eurostat 

present CN-

Description of CN-code (label) 

code 

26201100 

Hard zinc spelter 

39151000  Waste, parings and scrap, of polymers of ethylene 

39152000  Waste, parings and scrap, of polymers of styrene 

39153000  Waste, parings and scrap, of polymers of vinyl chloride 

39159011  Waste, parings and scrap, of polymers of propylene 

39159013 

Parings and scrap, of acrylic polymers 

Type of waste for the 

purpose of this study 

Non-ferrous metal wastes 

Plastic wastes 

Plastic wastes 

Plastic wastes 

Plastic wastes 

Plastic wastes 

Waste, parings and scrap, of addition polymerization products (excl. 

39159018 

that of polymers of ethylene, styrene and vinyl chloride and 

Plastic wastes 

propylene) 

parings and scrap, of addition polymerization products (excl. that of 

39159019 

acrylic polymers, polymers of ethylene, styrene and vinyl chloride 

Plastic wastes 

and propylene) 

39159080 

39159090 

Waste, parings and scrap, of plastics (excl. that of polymers of 

ethylene, styrene, vinyl chloride and propylene) 

Waste, parings and scrap, of plastics (excl. that of addition 

polymerization products) 

39159091 

Parings and scrap, of epoxide resins 

39159093 

Parings and scrap, of cellulose and its chemical derivatives 

39159099 

Parings and scrap, of plastics (excl. that of addition polymerization 

products, epoxide resins, cellulose and its chemical derivatives) 

Parings and other waste of leather or of composition leather, not 

Plastic wastes 

Plastic wastes 

Plastic wastes 

Plastic wastes 

Plastic wastes 

41152000 

suitable for the manufacture of leather articles; leather dust, 

Textile wastes 

powder and flour 

47071000 

47072000 

47073010 

Recovered "waste and scrap" paper or paperboard of unbleached 

Paper and cardboard 

kraft paper, corrugated paper or corrugated paperboard 

wastes 

Recovered "waste and scrap" paper or paperboard made mainly of 

Paper and cardboard 

bleached chemical pulp, not coloured in the mass 

wastes 

Old and unsold newspapers and magazines, telephone directories, 

Paper and cardboard 

brochures and printed advertising material 

wastes 

Waste and scrap of paper or paperboard made mainly of mechanical 

47073090 

pulp (excl. old and unsold newspapers and magazines, telephone 

directories, brochures and printed advertising material) 

Paper and cardboard 

wastes 

47079010 

47079090 

Unsorted, recovered "waste and scrap" paper or paperboard (excl. 

Paper and cardboard 

paper wool) 

wastes 

Sorted, recovered "waste and scrap" paper or paperboard (excl. 

waste and scrap of unbleached kraft paper or kraft paperboard, or 

of corrugated paper or corrugated paperboard, that of paper or 

Paper and cardboard 

paperboard made mainly of bleached chemical pulp not colured in 

wastes 

the mass, that of paper or paperboard made mainly of mechanical 

pulp, and paper wool) 

261 

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Eurostat 

present CN-

Description of CN-code (label) 

code 

50030000 

50031000 

50039000 

Silk waste, incl. cocoons unsuitable for reeling, yarn waste and 

garnetted stock 

Silk waste, incl. cocoons unsuitable for reeling, yarn waste and 

garnetted stock, neither carded nor combed 

Silk waste, incl. cocoons unsuitable for reeling, yarn waste and 

garnetted stock, carded or combed 

51031010 

Noils of wool or of fine animal hair - not carbonised 

51031010 

Noils of wool or of fine animal hair - carbonised 

51032000 

Waste of wool or of fine animal hair, incl. yarn waste (excl. noils 

and garnetted stock) 

51032010 

Yarn waste of wool of fine animal hair 

51032091 

51032099 

Waste of wool or of fine animal hair, non-carbonised (excl. yarn 

waste, noils and garnetted stock) 

Waste of wool of fine animal hair, carbonised (excl. yarn waste, 

noils and garnetted stock) 

Type of waste for the 

purpose of this study 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Waste of coarse animal hair, incl. yarn waste (excl. garnetted stock, 

51033000 

waste of hair or bristles used in the manufacture of brooms and 

Textile wastes 

brushes, and of horsehair from the mane or tail) 

52021000 

Cotton yarn waste, incl. thread waste 

52029100 

Garnetted stock of cotton 

Textile wastes 

Textile wastes 

52029900 

Cotton waste (excl. yarn waste, thread waste and garnetted stock) 

Textile wastes 

53013000 

Flax tow and waste, incl. yarn waste and garnetted stock 

53013010 

Flax tow 

53013090 

Flax waste, incl. yarn waste and garnetted stock 

55051010 

55051030 

55051050 

55051070 

Waste of staple fibres of nylon or other polyamides, incl. noils, yarn 

waste and garnetted stock 

Waste of staple fibres of polyesters, incl. noils, yarn waste and 

garnetted stock 

Waste of acrylic or modacrylic staple fibres, incl. noils, yarn waste 

and garnetted stock 

Waste of polypropylene staple fibres, incl. noils, yarn waste and 

garnetted stock 

Waste of synthetic staple fibres, incl. noils, yarn waste and 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

Textile wastes 

55051090 

garnetted stock (excl. that of polypropylene, acrylic, modacrlyic, 

Textile wastes 

55052000 

polyester, nylon and other polyamide staple fibres) 

Waste of artificial staple fibres, incl. noils, yarn waste and 

garnetted stock 

Textile wastes 

Worn clothing and clothing accessories, blankets and travelling rugs, 

household linen and articles for interior furnishing, of all types of 

63090000 

textile materials, incl. all types of footwear and headgear, showing 

Textile wastes 

signs of appreciable wear and presented in bulk or in bales, sacks or 

similar packings (excl. carpets, other floor coverings and tapestries) 

Used or new rags, scrap twine, cordage, rope and cables and worn-

out articles thereof, of textile materials, sorted 

63101000 

Textile wastes 

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Eurostat 

present CN-

Description of CN-code (label) 

Type of waste for the 

purpose of this study 

code 

63101010 

63101030 

Used or new rags, scrap twine, cordage, rope and cables and worn-

out articles thereof, of wool or fine or coarse animal hair, sorted 

Used or new rags, scrap twine, cordage, rope and cables and worn-

out articles thereof, of flax or cotton, sorted 

Used or new rags, scrap twine, cordage, rope and cables and worn-

Textile wastes 

Textile wastes 

63101090 

out articles thereof, of textile materials, sorted (excl. flax, cotton, 

Textile wastes 

63109000 

70010010 

70010091 

wool or fine or coarse animal hair) 

Used or new rags, scrap twine, cordage, rope and cables and worn-

out articles thereof, of textile materials (excl. sorted) 

Cullet and other waste and scrap of glass (excl. glass in the form of 

powder, granules or flakes) 

Cullet and other waste and scrap of glass; glass in the mass - optical 

glass 

Textile wastes 

Glass wastes 

Glass wastes 

70010099 

Cullet and other waste and scrap of glass; glass in the mass - other 

Glass wastes 

71123000 

Ash containing Precious metal or Precious-metal compounds 

Non-ferrous metal wastes 

Waste and scrap of gold, incl. metal clad with gold, and other waste 

and scrap containing gold or gold compounds, of a kind used 

71129100 

principally for the recovery of Precious metal (excl. ash containing 

gold or gold compounds, waste and scrap of gold melted down into 

Non-ferrous metal wastes 

71129200 

unworked blocks, ingots, or similar forms, and sweepings and ash 

containing Precious metals) 

Waste and scrap of platinum, incl. metal clad with platinum, and 

other waste and scrap containing platinum or platinum compounds, 

of a kind used principally for the recovery of Precious metal (excl. 

ash containing platinum or platinum compounds, waste and scrap of 

platinum melted down into unworked blocks, ingots, or similar 

forms, and sweepings and ash containing Precious metals) 

Waste and scrap of silver, incl. metal clad with silver, and other 

waste and scrap containing silver or silver compounds, of a kind used 

Non-ferrous metal wastes 

71129900 

principally for the recovery of Precious metal (excl. ash, and waste 

Non-ferrous metal wastes 

and scrap of Precious metals melted down into unworked blocks, 

ingots or similar forms) 

72041000  Waste and scrap, of cast iron (excl. radioactive) 

Ferrous metal wastes 

Waste and scrap of stainless steel, containing by weight >= 8% nickel 

72042110 

(excl. radioactive, and waste and scrap from batteries and electric 

Ferrous metal wastes 

accumulators) 

Waste and scrap of stainless steel (not containing >= 8% nickel, 

72042190 

radioactive, or waste and scrap from batteries and electric 

Ferrous metal wastes 

accumulators) 

Waste and scrap of alloy steel (excl. stainless steel, and waste and 

72042900 

scrap, radioactive, or waste and scrap from batteries and electric 

Ferrous metal wastes 

accumulators) 

72043000 

Waste and scrap of tinned iron or steel (excl. radioactive, and waste 

and scrap of batteries and electric accumulators) 

Ferrous metal wastes 

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Eurostat 

present CN-

Description of CN-code (label) 

code 

Type of waste for the 

purpose of this study 

Turnings, shavings, chips, milling waste, sawdust and filings, of iron 

72044110 

or steel, whether or not in bundles (excl. such items of cast iron, 

Ferrous metal wastes 

72044191 

72044199 

alloy steel or tinned iron or steel) 

Trimmings and stampings, of iron or steel, in bundles (excl. such 

items of cast iron, alloy steel or tinned iron or steel) 

Trimmings and stampings, of iron or steel, not in bundles (excl. such 

items of cast iron, alloy steel or tinned iron or steel) 

Waste and scrap of iron or steel, fragmentised "shredded" (excl. 

slag, scale and other waste of the production of iron and steel; 

radioactive waste and scrap; fragments of pigs, blocks or other 

Ferrous metal wastes 

Ferrous metal wastes 

72044910 

primary forms of pig iron or spiegeleisen; waste and scrap of cast 

Ferrous metal wastes 

iron, alloy steel or tinned iron or steel; turnings, shavings, chips, 

milling waste, sawdust, filings, trimmings and stampings; waste and 

scrap of primary cells, primary batteries and electric accumulators) 

Waste and scrap of iron or steel, not fragmentised "shredded", in 

bundles (excl. slag, scale and other waste of the production of iron 

and steel; radioactive waste and scrap; fragments of pigs, blocks or 

other primary forms of pig iron or spiegeleisen; waste and scrap of 

cast iron, alloy steel or tinned iron or steel; turnings, shavings, 

chips, milling waste, sawdust, filings, trimmings and stampings; 

waste and scrap of primary cells, primary batteries and electric 

accumulators) 

Waste and scrap of iron or steel, not fragmentised "shredded", not in 

bundles (excl. slag, scale and other waste of the production of iron 

and steel; radioactive waste and scrap; fragments of pigs, blocks or 

other primary forms of pig iron or spiegeleisen; waste and scrap of 

cast iron, alloy steel or tinned iron or steel; turnings, shavings, 

chips, milling waste, sawdust, filings, trimmings and stampings; 

waste and scrap of primary cells, primary batteries and electric 

accumulators) 

Ferrous metal wastes 

Ferrous metal wastes 

Remelting scrap ingots of iron or steel (excl. Products whose 

chemical composition conform//or ferro-alloys) 

Ferrous metal wastes 

'Waste and scrap, of refined copper (excl. ingots or other similar 

unwrought shapes, of remelted refined copper waste and scrap, 

ashes and residues containing refined copper, and waste and scrap 

of primary cells, primary batteries and electric accumulators) 

Waste and scrap, of copper-zinc base alloys "brass" (excl. ingots or 

other similar unwrought shapes, of remelted waste and scrap of 

Non-ferrous metal wastes 

72044930 

72044990 

72045000 

74040010 

74040091 

copper-zinc alloys, ashes and residues containing copper-zinc alloys 

Non-ferrous metal wastes 

and waste and scrap of primary cells, primary batteries and electric 

accumulators) 

Waste and scrap, of copper alloys (excl. of copper-zinc alloys, ingots 

or other similar unwrought shapes, of remelted waste and scrap of 

74040099 

copper alloys, ashes and residues containing copper alloys, and 

Non-ferrous metal wastes 

waste and scrap of primary cells, primary batteries and electric 

accumulators) 

264 

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Eurostat 

present CN-

Description of CN-code (label) 

code 

75030010 

Waste and scrap, of non-alloy nickel (excl. ingots or other similar 

unwrought shapes, of remelted non-alloy nickel waste and scrap, 

ashes and residues containing non-alloy nickel, waste and scrap of 

primary cells, primary batteries and electric accumulators) 

Waste and scrap, of nickel alloys (excl. ingots or other similar 

Type of waste for the 

purpose of this study 

Non-ferrous metal wastes 

75030090 

unwrought shapes, of remelted nickel alloys waste and scrap, ashes 

Non-ferrous metal wastes 

and residues containing nickel alloys) 

Turnings, shavings, chips, milling waste, sawdust and filings, of 

76020011 

aluminium; waste of coloured, coated or bonded sheets and foil, of 

Non-ferrous metal wastes 

a thickness "excl. any backing" of <= 0,2 mm, of aluminium 

Waste of aluminium, incl. faulty workpieces and workpieces which 

have become unusable in the course of production or processing 

(excl. slag, scale and other waste from the production of iron or 

76020019 

steel, containing recyclable aluminium in the form of silicates, 

Non-ferrous metal wastes 

ingots and other primary forms, of smelted waste or scrap, of 

aluminium, ash or the residues of the production of aluminium, and 

waste in heading 7602.00.11) 

Scrap of aluminium (excl. slags, scale and the like from iron and 

steel production, containing recoverable aluminium in the form of 

76020090 

silicates, ingots or other similar unwrought shapes, of remelted 

Non-ferrous metal wastes 

waste and scrap, of aluminium, and ashes and residues from 

aluminium production) 

Lead waste and scrap (excl. ashes and residues from lead production 

78020000 

"heading No 2620", and ingots or other similar unwrought shapes, of 

remelted waste and scrap, of lead "heading No 7801" and waste and 

Non-ferrous metal wastes 

scrap of primary cells, primary batteries et electric accumulators) 

Zinc waste and scrap (excl. ash and residues from zinc production 

79020000 

"heading 2620", ingots and other similar unwrought shapes, of 

remelted waste and scrap, of zinc "heading 7901" and waste and 

Non-ferrous metal wastes 

scrap of primary cells, primary batteries and electric accumulators) 

79031000 

Zinc dust 

79039000 

Zinc powders and flakes (excl. grains of zinc, and spangles of 

heading 8308, and zinc dust) 

Tin waste and scrap (excl. ash and residues from the manufacture of 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

80020000 

tin of heading 2620, and ingots and similar unwrought tin produced 

Non-ferrous metal wastes 

81019700 

81029700 

81033000 

from melted tin waste and scrap of heading 8001) 

Tungsten waste and scrap (excl. ash and residues containing 

tungsten) 

Molybdenum waste and scrap (excl. ash and residues containing 

molybdenum) 

Tantalum waste and scrap (excl. ash and residues containing 

tantalum) 

Magnesium waste and scrap (excl. ash and residues containing 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

81042000 

magnesium, and raspings, turnings and granules graded according to 

Non-ferrous metal wastes 

size) 

81053000 

Cobalt waste and scrap (excl. ash and residues containing cobalt) 

Non-ferrous metal wastes 

265 

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Eurostat 

present CN-

Description of CN-code (label) 

code 

81060010 

81073000 

81083000 

81093000 

81102000 

81110019 

81121300 

81122200 

81123040 

81124010 

81125200 

81129210 

Unwrought bismuth; bismuth powders; bismuth waste and scrap 

(excl. ash and residues containing bismuth) 

Cadmium waste and scrap (excl. ashes and residues containing 

cadmium) 

Titanium waste and scrap (excl. ash and residues containing 

titanium) 

Zirconium waste and scrap (excl. ash and residues containing 

zirconium) 

Antimony waste and scrap (excl. ash and residues containing 

antimony) 

Manganese waste and scrap (excl. ash and residues containing 

manganese) 

Beryllium waste and scrap (excl. ashes and residues containing 

beryllium) 

Type of waste for the 

purpose of this study 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Chromium waste and scrap (excl. ash and residues containing 

chromium and chromium alloys containing > 10% by weight of nickel) 

Non-ferrous metal wastes 

Germanium waste and scrap (excl. ashes and residues containing 

germanium) 

Unwrought vanadium; vanadium powders; vanadium waste and scrap 

(excl. ash and residues containing vanadium) 

Thallium waste and scrap (excl. ashes and residues containing 

thallium) 

Unwrought hafnium "celtium"; hafnium powders; hafnium waste and 

scrap (excl. ash and residues containing hafnium) 

Niobium "columbium", rhenium, gallium, indium, vanadium and 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

81129221 

germanium waste and scrap (excl. ashes and residues containing 

Non-ferrous metal wastes 

these metals) 

81129239 

81129250 

81129291 

81130040 

Niobium "columbium" and rhenium waste and scrap (excl. ash and 

residues containing these metals) 

Gallium and indium waste and scrap (excl. ashes and residues 

containing these metals) 

Unwrought vanadium; vanadium powders (excl. ash and residues 

containing vanadium) 

Waste and scrap of cermets (excl. ashes and residues containing 

cermets) 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

Non-ferrous metal wastes 

266