NGOs demand a stronger ban on waste exports, a better alignment with waste treatment hierarchy and fairer shipments for reuse
Brussels, 17 November 2021 –
The revised Waste Shipment Regulation proposal  tabled today by the European Commission is a welcome step forward, but more needs to be done to mitigate the consequences of EU waste exports, warns the European Environmental Bureau (EEB).
The text aims to bring EU waste shipment policy more in line with the waste treatment hierarchy and sound environmental waste management, two guiding principles of EU waste policy. However, derogations and insufficient distinction between material recycling and lower forms of recovery risk watering it down, according to Europe’s largest network of environmental NGOs.
The revised text may temporarily divert a bit more waste to OECD countries rather than non-OECD ones, but it will not make it harder to export waste, and it will not ensure that valuable resources remain in the system within the EU. The EEB advocates for a strict ban, which would be easier to enforce, and would create additional pressure to cut waste generation and virgin resource consumption in the EU.
Stéphane Arditi, Director of Policy Integration and Circular Economy at the EEB, said: “Shipping waste outside the EU is not only an unfair delegation of our duty to manage our own waste and an obstacle to waste prevention. It is also a missed opportunity to turn waste into secondary raw materials, reducing our dependence on imported natural resources and eventually making the EU a secondary raw material exporter.”
Within or outside the EU, exports for waste disposal are prohibited by default, but the text seems to miss a distinction between shipments for reuse and recycling, and shipments for lower forms of recovery, such as incineration . This makes it as easy to export materials to another EU or OECD country for incineration as for reuse or recycling, which is at odds with the waste hierarchy.
For enforcement purposes, the proposal also distinguishes between shipments for reuse and shipments of waste, but neglects the fact that products shipped for reuse will at some point reach their end of life and would need to be managed in the receiving country. For items such as electronics and possibly textiles and cars in the future, consumers pay so-called Extended Producer Responsibility (EPR) fees to support correct collection, recycling and waste disposal. However, if the fees paid by consumers do not follow the products when they are shipped for reuse, they will unduly remain with producers in the exporting countries, instead of helping receiving countries manage the waste treatment stage.
In 2020, EU exports of waste to non-EU countries reached 32.7 million tonnes, an increase of three quarters (+75%) since 2004. The largest share of this waste was sent to Turkey (13.7 million tonnes), followed by India (2.9 million tonnes), the UK (1.8 million tonnes), and Switzerland (1.6 million tonnes), Norway (1.5 million tonnes), Indonesia and Pakistan (1.4 million tonnes) .
The EEB, the Rethink Plastic alliance and Break Free From Plastic have repeatedly urged the Commission to intervene and halt the significant health, environmental and social burden of EU waste, and notably plastics, on receiving countries .
Hazardous waste exports mostly remain within the EU: in 2018, 7.0 million tonnes of the hazardous waste exports from EU Member States were shipped to another member state, corresponding to approximately 91% of the total exports .
Over the next 12 to 18 months, the Waste Shipment Regulation proposal will be discussed by the Environment Committee of the European Parliament as well as with member states representatives within the Council, according to the Ordinary Legislative Procedure. The EEB warns that the present loopholes may lead to the proposal to be weakened.