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.

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.

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.