Permit procedure or shipment of green waste

As a general rule, a permit is required for transfrontier shipments of waste. Transfers of non hazardous, so-called green list waste within the OECD area, for the purpose of recovery, constitute an exception to this rule.
The waste exporter is obliged to verify whether a permit is required for the waste shipment (the so-called notification procedure) or whether the green list waste procedure is applicable. If waste subject to a permit is exported without such permit, the operator may be punished according to the Waste Act.

If a waste export from Finland is subject to a permit, approvals from waste shipment authorities in the country of destination, and any potential countries of transit, are required in addition to the waste shipment permit granted by the Finnish Environment Institute.   In the case of green list waste, a movement document in accordance with Annex VII of the EU Regulation on shipment of waste shall be enclosed with the shipment. Furthermore, the notifier and the consignee shall enter a contract fulfilling certain terms.

When planning a shipment of waste, it is recommended to obtain procedure instructions from the competent authority in the country of dispatch.

Factors affecting the shipment procedure

1. Classification of waste

The need for a waste shipment permit is set forth in EU Regulation No 1013/2006 on shipments of waste. The classification of waste types according to the appendices of the regulation is based on their properties. The basis of the classification is formed by the OECD Council Decree and the appendices to the Basel Convention, where the lists of waste are laid down in Annex III (green list waste) and IV.

In order to determine whether a permit is required or not, it is important for the waste dispatcher to know under which appendix the waste to be shipped is listed. Green-listed waste includes all types of waste that do not pose any likely risk to the environment when shipped from one country to another for recovery. Examples of such waste include scrap metal, waste paper, and untreated wood. As a general rule, these may be shipped from one OECD member state to another without a separate permit procedure. Waste listed in Appendix IV always require a permit. Furthermore, the permit procedure is applied to all kinds waste types not mentioned in said lists.

2. Recovery or disposal

The need for a permit also depends on whether the waste is intended for recovery (e.g. metal recycling) in the country of destination, or for disposal (e.g. landfill).  The export of waste for purposes of disposal always requires a permit, regardless of whether or not it contains hazardous properties.

3. Country of destination

The country of destination affects the need for a waste shipment permit.

The export of waste for disposal outside the EU/EFTA region is prohibited. The export prohibition of hazardous waste for purposes of recovery applies to countries outside the EU and OECD.

The shipment of green list waste (Appendix III, list B) into a country outside the OECD for purposes of recovery is provided for in Regulation 1418/2007 (latest amendment 733/2014). The classification of the waste according to the Basel Convention or the OECD Decree determines whether its export is prohibited, requiring a permit, subject to the so-called green waste procedure, or governed by specific regulations that apply in the country of destination. 

China has implemented new import restrictions for certain wastes from 1 January 2018. China forbids the import of several wastes, for example mixed plastics waste, unsorted waste paper, and waste textile materials. Regulation 1418/2007 does not yet include these wastes. The exporter is responsible to know the regulations which concern the waste to be exported.

The Dutch authority has a summary concerning the import regulations in China in the following link: Chinese regulations on incoming waste

Published 2013-09-09 at 13:14, updated 2019-08-30 at 14:46