The movement of waste for recycling across borders is governed by the regulation (EC) No 1013/2006 on shipments of waste. The transboundary shipment of waste such as RDF (Refuse Derived Fuel) or SRF (Solid Recovered Fuel) are examples of transport that requires procedures of prior written notification and consent. Hence, the producers or brokers – so-called notifiers – need to apply for permits for the export of the materials in the country of origin.
The existing TFS regulation is important because it allows for the supervision and control of waste shipments, and ensures that the movement, recovery, or disposal of waste is environmentally sound.
Processing time increases
The waste market in Europe has in the past two years been affected by COVID-19 and the ongoing war in Ukraine, leading to reduced waste volumes in the EU. Consequently, some of the “importing countries” of waste have become “exporting countries”, and vice versa, leading to new international streams.
As a result of this, authorities of the EU/EEA have recently been flooded with notifications on the transboundary movement of waste. The processing time of notifications has been significantly extended in several countries: For instance, in Poland, the time of proceeding has been prolonged by 4 months, and in Sweden an additional 3 months has become normal. The processing of notifications in countries such as Denmark, Italy, and the UK have also been highly extended.
Although authorities presumably are trying their best, this situation is now creating challenges for the whole value chain of recyclables and waste-derived fuels in many countries. Some countries do better than others, but this also depends on whether the responsibility for issuing consents is on many local or one central authority.
Another big challenge is the restrictive nature of the regulations: The notification process is full of formalities and the notifier is obliged to provide detailed documents and shipment records. A significant part of notifications is currently being prepared by notifiers who do not have experience in such a complicated process, which is yet another reason why administrative procedures are prolonged.
Allocating more resources for this important task is increasingly important. This will secure more, qualified manpower to handle the growing number of applications. An aspect that also could improve today’s situation, is to introduce a “fast track” for entities with extensive experience, that are submitting dozens of notifications with the same parameters every year.
A replacement of the current regulations
As an international logistics operator, we see that the industry is best served by making the regulations simpler. However, the changes suggested for improving the current EU regulations do not necessarily promise a speedier transport process.
Among the suggestions, is the establishment of a group at the EU level which will cooperate on and the enforcement of the regulations. The Commission thereby hopes to strengthen regulations relating to supervision and sanctions, which also include a ban on sending waste to countries outside the OECD. Another expected change is that greenlisted waste resources, such as paper and cardboard, in time also will need to be prenotified.
If these and other suggestions are passed in a new regulation, we can expect tighter control of transfrontier shipments. Such a complex regulation may, in the worst case, lead to a situation where the processing time gets extended further.
Economic growth and globalization have led to a worldwide increase in waste. If more of this waste is to become useful resources (RDF, SRF, waste wood, paper, and plastic), all coming legislation needs to create the right conditions for building a circular economy. Improving the conditions for and speeding up transboundary shipments of waste resources is an important step towards a more sustainable Europe.