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Transfrontier waste shipping – what you need to know

Transfrontier waste shipping – what you need to know

Exporting waste overseas, also known as transfrontier shipping, is the process of moving waste between different countries.

Increases in recycling has resulted in more commercial and household waste being exported as a useful resource, meaning that transfrontier waste shipping is becoming more common for some waste management businesses.

Waste is commonly only exported for reuse or recovery, it doesn’t get exported overseas for disposal, such as landfill.

Regulations are applicable from the point of the waste being loaded to the point of its disposal at the facility of its destination. There are stringent rules in place and if they are not followed, the waste operator may be prosecuted, fined or even imprisoned.

If you, as a waste business owner or manager, wish to either import or export waste, you will be subject to the The Transfrontier Shipment of Waste (Amendment) Regulations 2014. Whilst this is a lengthy piece of legislation, its intentions are to protect the environment and human health.

Its first introduction in 2007, updated the former European legislation, introducing a more universal list of waste codes. This was to, at the time, simplify the procedures for ‘notifiable and non-notifiable waste.’

Benefits to waste business owners:

Economic effect on business

In a Parliamentary Sustainable Resource Group conference, MP Dan Rogerson stated how waste is now classed as a valuable resource, “…as with any resource, trade with other countries is important and makes a meaningful contribution to the UK economy.”

The conditions of the economy have an impact on all business small, medium and large. For smaller business, upswings in the economy are likely to have a positive impact on them quicker as they would have been likely to suffer more in a weaker economic climate.

Avoidance of landfill tax:

The landfill tax or levy was introduced as an additional cost of transporting waste to landfill. Commonly, the tax is calculated by volume or weight. With the burden of its additional cost to waste business owners, it is often the case that it is more cost effective to transport overseas.

High demand

Just six years ago, the UK exported no waste-derived fuel. Now it exports 887,465 tonnes overseas, highlighting it vast increase.

In undeveloped countries, purchasing recyclables is a common way to generate income, as producing consumables from virgin materials costs a lot more. Increasingly, thousands of tonnes of recyclate including metals and paper are working their way to international markets, with China currently being the largest.

When demand increases with supply that remains stable, the equilibrium price goes up, which is good news for business owners. However, in the case of waste, whilst the supply has been increasing steadily, this may shift as more people are becoming ethically-conscious and recycling rates and reuse are on the rise.

Increase in waste export products

With the increase of waste exports, there will be a positive domino effect on other relevant businesses within the industry. For example, business owners in the waste balers, compactors, shredders and consumables sectors will generate business by heightened demand for them in the UK.

Notifiable waste

Notifiable waste is hazardous and could be considered as harmful to the environment or human health and therefore must be strictly controlled. A ‘notification control’ is required to gain consent to export this type of waste.

Shipping what could be considered as notifiable waste without the correct prior consent is a criminal offence.

Types of hazardous (notifiable) waste include:

  • Asbestos
  • Batteries
  • Containers shipping hazardous waste
  • Chemicals (for example printing toners and brake fluid)
  • Equipment that includes ‘ozone depleting substances’ such as fridge freezers
  • Oils
  • Pesticides

Source: Hazardous waste (www.gov.uk/dispose-hazardous-waste)

Green List waste

Green list waste usually applies to the shipping of non-hazardous waste and has lower levels of control and regulations than notifiable waste.

Green list waste has a different classification as it is usually referred to a material that can be:

  • Converted into a raw material
  • Reused to generate energy

To export Green List waste, you must:

  • Ensure it is definitely ‘Green List’
  • Check the facility is in a country that accepts ‘Green List’
  • Ensure the facility is reputable and the waste will be recovered in an ‘environmentally sound manner’
  • Enter into a mutual contract with the receiver, which must be in specific terms
  • Complete an Annex VII form

Annex VII form

A very complicated yet relevant document, the Annex VII needs to be completed and signed. It must provide comprehensive details and information on:

  • Everybody involved in moving the waste
  • The waste itself
  • The recovery operation
  • The recovery facility

The form must accompany the waste on its journey and be kept for three years. Regulators may ask to see the documents at any time.

RDF Export

According to the EA, RDF export from the UK has increased by 750,000 tonnes in 2014. The EA also published figures that show by the end of 2014, the amount of RDF shipped overseas exceeded 2,373,611 tonnes.

However, the RDF Export Industry Group has highlighted that they believe there is ‘…no environmental benefit to domestically processing the refuse-derived fuel currently being exported from the UK.’

To export RDF, it is important that in its production, the ‘Waste Hierarchy’ is followed. This ensures that only ‘true’ residual, treated waste is shipped overseas.

European Waste Hierarchy

The European Waste Hierarchy refers to the five steps of the Waste Framework Directive (article 4):

  1. Prevention– can the waste be prevented and is there any way to reduce its generation
  2. Reuse and preparation for reuse– Can the products be given a ‘second life’ before they become waste?
  3. Recycle – Can any of the waste be recycled for other purposes?
  4. Recovery – is there any way that it can be recovered?
  5. Disposal – the final processes of disposal (including incineration, gasification and landfill) 


Whilst waste may be classed as Green List, it may not be exported as such, if there is the risk of contamination by other materials that could risk:

  • Changing non-hazardous waste to hazardous waste
  • Change its classification (waste code)
  • Prevent its recovery in an otherwise environmentally sound process

Waste transfer between OECD countries

The OECD (Organisation for Economic Co-operation and Development) Decision is a definition classing the ‘transboundary movement’ of waste as being “any movement of wastes from an area under the national jurisdiction of a member country to an area under the national jurisdiction of another member country”.

OECD countries are 30 democracies which have joined together to address the challenges of globalisation, such as economic, social and environmental impacts.

The 30 OECD Members are: Australia, Austria, Belgium, Canada, the Czech Republic, Denmark, Finland, France, Germany, Greece, Hungary, Iceland, Ireland, Italy, Japan, Korea, Luxembourg, Mexico, the Netherlands, New Zealand, Norway, Poland, Portugal, the Slovak Republic, Spain, Sweden, Switzerland, Turkey, the United Kingdom and the United States (Source: Guidance manual for the control of transboundary movements of recoverable wastes: http://goo.gl/86Z6e7)

The OECD Decision is applicable only to where both the country of export and import are OECD Members.

Movement of waste between non-OECD countries

Only specific non-hazardous waste can be exported to some non-OECD countries. These must be under Green List control. All other types of waste exports are either banned or heavily restricted and subject to notification.

The Basel Convention

For countries that aren’t OECD to transfer hazardous waste for either export or to import from, they have to adhere to the Basel Convention, an international treaty for the ‘Control of Transboundary Movements of Hazardous Wastes and their Disposal.’ The treaty was intended to reduce the movement of hazardous waste between countries, especially from developed to under-developed countries.

The core aims of the Basel Convention are to:

  • Reduce the generation of hazardous waste
  • Restrict hazardous transboundary waste movement
  • Provide regulation for transboundary movement

(Source: Basel Convention: http://goo.gl/Dk2Lwa)

Illegal waste shipping

According to the EA; Belgium, Poland, the Netherlands and Thailand have all received illegal waste from the UK. The EA is also currently investigating a number of alleged waste exports to Brazil since 2009.

The EA takes the illegal shipping of waste very seriously. Earlier this year, the director of an electronic goods shipping company in the UK, received an 18 month suspended sentence for attempting to export electric waste illegally to West Africa.

The court heard how over the period of 22 months, the company illegally exported six shipping containers containing WEEE (Waste Electrical and Electronic Equipment). Some of the containers held hazardous waste, which was being shipped to countries outside of the OECD.

Upon inspection of the containers, the EA determined that the containers were classified as waste and contained WEEE, including fridge freezers with harmful components and cathode ray tubes (from televisions).

Under EU law, WEEE must not be shipped to countries that do not have the infrastructure to treat the waste in a way that doesn’t pose harm or risk to the environment or human health.

Unfortunately, this scenario isn’t an isolated incident, with an increasing number of waste business owners being prosecuted for illegal waste exportation.

Duty of Care

As an exporter of waste, you have a ‘duty of care’ which lasts from the duration of your dealings with the waste. This is from the moment you produce it until the moment it is passed onto another licensed waste business.

It is also your responsibility to monitor how that business deals with your waste, even after the transition of the waste. If you suspect that another business is not treating the waste ethically or how they are supposed to be, it is also your ‘duty of care’ to report them to the authorities.

The Duty of Care also requires that the waste to be exported is described in such a way that promotes the safety and handling of the material. Each waste has a code and this must be listed along with a description that identifies its waste properties.

Rules for exporting waste

Rules and regulations regarding exporting waste start from the very point of its loading until it has been fully recovered at the facility of its destination.

This is probably one of the most important factors for waste business owners to remember: responsibility is yours throughout the whole duration of the process. If at any point during this time, the rules and regulations are not followed, you risk prosecution.

The rules for exporting waste depend on the following factors:

  • The treatment planned
  • The country it is destined for
  • The transport route
  • The type of waste

If you are considering exporting waste, it is imperative to remember that there are an array of guidelines and legislation. Always seek advice from the relevant authorities and consider employing the services of a consultant to make sure that as a waste business owner, you are complaint and within the scope of the law.

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