Shipping waste in and out of the EU, answered

The two regimes in practice:

• Notification; the full procedure. Every competent authority along the route has to give written consent before the first truck moves, and there has to be a financial guarantee in place.
• Annex VII; the green-list route. A single information document travels with the load. No consent, no guarantee, but the contract between the person arranging the shipment and the recovery facility still has to exist and be produceable.

The classification is the whole game. A green-list code that turns out to be contaminated, or a mixture that has no single entry, drops you into the notification regime retroactively; and by then the waste has already crossed a border.

The Dutch inspectorate advises submitting at least three months before the first intended shipment. That is not padding. The sequence is:

1. You submit to the competent authority of the country where the transport starts.
2. That authority forwards it to the other countries involved.
3. The country of destination assesses whether the notification is complete. Anything missing sends it back and the clock has not started.
4. Once it is complete, every authority involved has thirty days to issue a decision.
5. You may not move anything until all of them have consented.

The practical consequence for a trader is that a notification is not something you arrange around a deal. It is something that has to exist before the deal, or the deal has to be written to survive a three-month wait.

You cannot finish filling in a notification until the notifier, the producer, the carriers, the consignee, the facility and any downstream processor all have their own registered account. Each of those is a separate organisation that has to act, and none of them are waiting for your email.

The financial guarantee has to cover the cost of taking the waste back and disposing of it if the shipment cannot be completed as intended. It is calculated on the whole quantity covered by the notification, not on a single load.

Before this, every member state ran its own arrangement and a notification crossing three countries could mean three ways of doing the same thing. The system replaces that with one channel for notification documents and movement documents.

Two things are worth knowing if you are registering now:

• Registration itself is quick; an organisation can normally be registered within a working day, and you can start preparing a notification as soon as you are registered. Submission waits until the authority has approved the registration.
• The interconnection between the central system and national systems has been the difficult part. It was discussed at the Commission's waste expert group in March 2026 and it is the reason for the Annex VII arrangement in the next answer.

The reason is the interconnection problem: exchanging Annex VII documents between the central system and national software was not ready in time. Several European trade bodies representing recycling and the glass, metals and plastics sectors wrote jointly asking for at least a one-year transition after the launch.

What that means for you: green-list shipments carry on much as before for the rest of 2026, and then change. If you move green-list waste in volume, 1 January 2027 is a date to prepare for now, not in December.

One distinction is worth holding on to, because it decides what you can rely on. The transition is an enforcement position, not an amendment to the regulation. Germany’s environment ministry has stated that no sanctions will be imposed between 21 May and 31 December 2026 where the documents are completed on paper and enclosed on paper with the shipment. That is a national position taken in concert with the Commission’s proposal; so check what your own competent authority has said rather than assuming the same tolerance everywhere.

This is the change that alters how you plan rather than how you file. A green-list load that used to be documented on the morning of collection has to be entered two working days ahead, by the person who arranges the shipment.

The three exceptions are the tell. They are exactly the things nobody knows two days out:

• Fixed in advance: the waste and its code, the parties, the facility, the route, the recovery operation, the contract.
• May follow, at the latest before the shipment starts: the actual quantity, the carrier or carriers, and the container identification number where one applies.

Working days, not days. A Thursday collection means Tuesday; a public holiday in the week moves it again. For traders who buy and load inside forty-eight hours, this is the provision that reaches into the commercial side of the business; the paperwork deadline now sits before the truck is booked.

The sequence, because the two dates do different things:

• 21 May 2026; non-hazardous plastic waste to OECD countries stops being a green-list shipment and becomes a notified one. Same destination, a far heavier procedure.
• 21 November 2026; export to non-OECD countries is prohibited. Clean single-polymer waste under Basel code B3011 was still possible in the intervening months, but only with notification and consent.

After November the prohibition holds for a minimum of two and a half years, with the possibility of derogations for individual countries later. Non-OECD countries wanting to receive non-hazardous EU waste have had to apply for eligibility, and the first requests came in during 2025.

The practical effect is a redirection of volume rather than a paperwork change. Material that used to go to refining hubs in Asia now has to stay inside the EU or move within the OECD, and shipments within the OECD go through prior notification and consent.

Individual member states may apply the amended list earlier than November, so the date to check is the national one, not only the European one.

Against that sits the Battery Regulation's own target: 80% of the lithium in waste batteries has to be recovered by 2031. The export restriction and the recovery target push the same way; European processing capacity has to absorb both.

This is the part that changes who you can sell to. It is no longer enough that the receiving country permits the import; the specific installation has to meet requirements, and there are audit obligations attached from that date.

The audit is not a one-off. It has to have been carried out no more than two years before the export and be renewed every two years, and a facility can be required to undergo an ad-hoc audit in between if information comes to light that it no longer complies.

For anyone whose route depends on a single overseas offtaker, the work to start now is not paperwork but a second outlet. An audit that fails in 2027 leaves the material with nowhere to go.

A shipment counts as illegal in more situations than most people expect; not only moving without consent, but also moving in a way that does not match what was notified: a different quantity, a different route, a different facility, or waste whose composition turns out not to match the description.

That last case is the one that catches traders. The description came from the supplier, the analysis was done on a sample, and the load that arrives is not what the paper says. The obligation still sits with the notifier.

What each one governs is different, which is why neither cancels the other:

• The waste regime decides whether the shipment needs notification or an Annex VII document, and which competent authorities have to agree to it moving.
• The animal by-product regime decides hygiene, traceability and what the material may end up in. Category 3 may go to biodiesel; feeding it to ruminants and farmed fish is prohibited.

Traders who treat this as an either/or end up with one set of papers and a load that is stopped for missing the other.

In practice buyers do have a preference and they say so, usually because of what their own downstream customer or scheme audit expects. That preference is a commercial fact, not a legal one, and it is worth asking about early rather than discovering it at loading.

What is worth checking before you agree terms:

• Which document does the receiving facility need in order to book the material in.
• Whether the certification scheme in play adds its own requirement on top; a delivery note or proof of sustainability is a third document again, and it is not a substitute for either of these.
• Who fills in which boxes, and who signs. Amendments to a filled-in Annex VII after the truck has left are a routine source of delay.

Both documents are being digitised; separately. This is the part that catches people who assume one change covers both:

• Annex VII moves into DIWASS, the waste system, on 1 January 2027, with the two-working-day deadline that comes with it.
• The commercial document belongs to TRACES, the animal-health system, where its electronic form is called a DOCOM. Its model was amended by Commission Implementing Regulation (EU) 2025/1379 of 15 July 2025, which also digitalised record keeping: where you obtained the commercial document through TRACES, you are no longer required to keep a separate copy of it.

Two regimes, two systems, two timetables, and no connection between them. A consignment that is both waste and a category 3 animal by-product needs its paperwork in both, and being compliant in one says nothing about the other.

The entries that come up most for used cooking oil and related streams:

• 20 01 25; edible oil and fat, in the municipal waste chapter. The default for oil collected from restaurants and kitchens.
• 02 03 04; materials unsuitable for consumption or processing, from the food industry chapter. Used where the material comes out of production rather than out of a kitchen.
• 19 08 09; grease and oil mixture from oil/water separation containing edible oil and fats. For material recovered at a treatment plant.

A code from chapter 07 is a different product, not a different opinion. Entries in that chapter cover residues from the manufacture of fats, soaps and detergents; which is where soapstock and acid oils sit, not kitchen-collected UCO. If one side of a deal is quoting a chapter 07 entry and the other a chapter 20 entry, the two are describing different materials, and the specification needs settling before the paperwork does.

End-of-waste is not a commercial preference. The material has to meet the conditions: it is commonly used for a specific purpose, there is a market for it, it meets the technical requirements and applicable standards, and its use has no overall adverse environmental or health impact. Some streams have EU-wide criteria; most do not, and are then decided nationally, case by case.

The consequence for a trade is worth being blunt about: if it turns out to be waste and it moved as a product, it moved illegally. That is not a paperwork correction afterwards; it triggers the take-back regime and the financial consequences that go with it.