FEAD points out the importance of the waste shipment regulation (WSR) „to ensure safe shipments of waste, traceability and to guarantee an appropriate treatment of waste at its final destination.
In the letter, the federation makes clear that it sees the shortcomings not in the WSR itself, but in „inconsistencies or problem of interpretation with other related pieces of the legislation or with differences of enforcement within the EU member states“.
The letter lists the concerns, which include among others:
* Provisions on hazardous waste have to be clearly distinguished from non-hazardous waste
* The WSR should limit mandatory waste codes to reduce administrative burdens and make harmonisation even easier
* The type and number of documents required by the notification procedure should be fixed
* The frequent delays (between 2 and 10 months in average) for the notification procedure should be reduced
* The pre-consent procedure should be harmonised in the EU through a single procedure for the validation of the pre-consented facilities.
* A clear distinction between administrative mistakes and illegal shipments is needed to ensure that an incorrectly filled Annex VII should not automatically make it an „illegal“ shipment.
* The procedure for repatriating shipments between member states should be simplified while the normal procedure applied today (new notification to be introduced by the notifier) should become the exception.
You can read FEADs position on the evalution of the waste shipment regulation here.