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Transfrontier shipments of waste

Transfrontier shipments of waste are regulated globally, and their control is based on international agreements and regulations. Waste shipments from one country to another either require permits from the authorities of all countries involved in the shipment, or a lighter, so-called green waste shipment procedure is followed. Waste shipments may also be entirely prohibited.
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Plastic pipes taken out of use.
Decommissioned plastic pipes © Hannele Nikander

Shipments are controlled to ensure that waste is properly treated and that the shipment does not pose a risk to the environment or to human health. In addition, regulation allows countries to prohibit or restrict the export or import of waste.

Procedures for international shipments of waste

As a rule, waste shipments from one country to another require a waste shipment permit. The so-called green waste shipment procedure, which is lighter than the permit procedure, is followed in certain non-hazardous waste shipments, for instance for recovery within the EU or the OECD. In some cases, exporting or importing waste may also be entirely prohibited.

The waste exporter is obliged to investigate

  • whether a permit is required for the shipment of waste (so-called notification procedure),
  • whether the so-called green listed waste shipment procedure is applied, or
  • whether the shipment is prohibited.

The choice of the correct procedure is influenced by the classification, processing (recovery or disposal) and the receiving country. In addition, the import and export restrictions of the Waste Act must be taken into account. 

  • According to the Waste Act, waste recovery refers to activities primarily resulting in waste used in a production plant or elsewhere in the economy in such a way that it replaces substances or objects otherwise used for that purpose, including the preparation of waste for such purposes.
  • The disposal of waste, on the other hand, refers to landfilling, incineration without energy recovery or other comparable activities that are not waste recovery, although the secondary consequence of the activity is the recovery of the substance or energy contained in the waste, including the preparation of waste for disposal.

Waste recovery and disposal are defined in more detail in Annexes 1 and 2 of the Waste Decree (978/2021).

The exporter is responsible for following the correct procedure and for the proper organisation of the shipment, but the legislation also imposes obligations on the recipient, the processor and the transporters of the waste.

Export of waste for recovery

Depending on the situation, the export of waste for recovery may be subject to a permit (notification procedure), or a lighter so-called green waste shipment procedure must be followed. Sometimes exports may also be completely prohibited. The waste exporter is obliged to determine the procedure to follow in the export. Waste shipments that do not comply with these procedures may result in a penalty laid down in the Waste Act.

The procedures for shipments of waste are defined in the EU regulation 1013/2006 on shipments of waste. Issues that affect the selection of the procedure are discussed below.

What is exported?

In the selection of the correct export procedure, the classification of waste in accordance with the EU regulation on shipments of waste is essential. In the EU regulation on shipments of waste, waste is classified in different annexes based on their properties. The classification is based on the decision of the OECD Council and the Annexes to the Basel Convention, from which the lists of waste are derived as Annex III (so-called green list of waste) and Annex IV to the regulation on shipments of waste. It is important for the waste exporter to know in which annex the waste to be shipped is listed, in order to determine whether a waste shipment authorisation is required or whether the green waste shipment procedure is followed.

The so-called green list of waste (Annex III of the Regulation) includes waste for which shipments from one country to another for recovery are unlikely to pose a risk to the environment. Such waste includes metal scrap, waste paper and untreated wood waste. As a rule, they may be shipped from one EU or OECD member state to another according to the green waste shipment procedure.

Waste from the list of waste in Annex IV is always subject to the notification procedure. Waste not included in these lists shall be subject to the notification procedure.

What is the destination?

The country receiving the waste influences the planning of waste shipments. The procedure for shipping waste outside the EU and OECD countries may differ from the procedure for shipping similar waste between EU or OECD countries. The receiving country also affects the conditions of the shipment. For example, under the regulation on shipments of waste, waste classified as hazardous may not be exported to countries outside the EU or the OECD, or the receiving country may have prohibited the import of waste.

When exporting ‘green’ waste to a country outside the EU or the OECD, the shipment procedures required by the country of destination will be verified in Commission Regulation (EC) No. 1418/2007. The Basel or OECD category of waste determines whether the export of waste is subject to a prohibition, authorisation (notification procedure) or so-called green waste shipment procedure. Any regulations of the destination country must also be taken into account.

When waste is shipped outside the EEA, the exporter must also be able to demonstrate that the processing of the waste takes place under conditions that largely meet the requirements of EU environmental legislation.

Export restrictions in the Waste Act on the export of mixed municipal waste for which the municipality is responsible

As a rule, no special justification is needed for the export of waste for recovery in another country. In accordance with Section 32 of the Waste Act (646/2011), exports of waste for which the municipality is responsible are an exception, in which case the grounds laid down in Section 109 of the Waste Act are required for exports. When applying for an export permit, the Finnish Environment Institute requires that the company submits appropriate grounds for export in its application.

Section 109 of the Waste Act lists the conditions below. Exports may be permitted, if one of them is met.

  1. Finland does not have technical or economic conditions or the necessary facilities for the processing of waste in an acceptable manner;
  2. waste is handled significantly better in terms of environmental protection than in Finland;
  3. waste is treated in a manner that should be acceptable from the point of view of environmental protection in Finland and which is considerably more advantageous in terms of total costs than processing in Finland;
  4. the shipment is carried out in order to experiment with a new processing method or for other experimental activities; or
  5. the shipment of non-hazardous waste is based on regional cooperation in waste management between the municipalities of Finland and Sweden or Finland and Norway.

The Finnish Environment Institute is of the opinion that ‘considerably more advantageous in terms of total costs’ as mentioned in Section 3) refers to at least 60% lower overall costs. In addition to processing costs, transport costs and authorities’ fees for processing permits are included in the total costs.

The Finnish Environment Institute monitors the generation and processing of mixed municipal waste. A prerequisite for granting export permits is compliance with the requirements of the Waste Act.

Code of practice

Waste shipment permits from the Finnish Environment Institute and the waste shipment authorities of the country of destination and any transit countries (notification procedure) are required for the shipment of waste requiring a permit from Finland. The waste exporter must apply for a waste shipment permit. See the instructions for applying for a waste shipment permit here.

In the case of a shipment of green waste, the waste shipment must include a form, Annex VII of the EU regulation on shipments of waste. In addition, the shipment organiser and the recipient must enter into an agreement that meets certain conditions. Instructions for so-called green waste shipments are available here.

If you are unsure which procedure to follow when exporting, please contact the Finnish Environment Institute. Any national procedural requirements in reception and transit countries should be determined directly by the competent authority of the country concerned.

Export of waste for disposal

Exports of waste for disposal always require waste shipment permits (notification procedure) issued by both the Finnish Environment Institute and the waste recipient country and any waste shipment authorities in transit countries. Exports of waste for disposal in another EU or EFTA country are entirely prohibited.

The waste exporter is obliged to ensure compliance with the procedures required for waste shipments and to apply for a waste shipment permit. Waste shipments in which the required procedures have not been followed may be subject to a penalty laid down in the Waste Act.

Export restrictions in the Waste Act

The grounds laid down in Section 109 of the Waste Act (646/2011) are always required for the export of waste for disposal. When applying for an export permit, the Finnish Environment Institute requires that the company submits appropriate grounds for export in its application.

Section 109 of the Waste Act lists the conditions below. Exports may be permitted, if one of them is met.

  1. Finland does not have technical or economic conditions or the necessary facilities for the processing of waste in an acceptable manner;
  2. waste is handled significantly better in terms of environmental protection than in Finland;
  3. waste is treated in a manner that should be acceptable from the point of view of environmental protection in Finland and which is considerably more advantageous in terms of total costs than processing in Finland;
  4. the shipment is carried out in order to experiment with a new processing method or for other experimental activities; or
  5. the shipment of non-hazardous waste is based on regional cooperation in waste management between the municipalities of Finland and Sweden or Finland and Norway.

The Finnish Environment Institute is of the opinion that ‘considerably more advantageous in terms of total costs’ as mentioned in Section 3) refers to at least 60% lower overall costs. In addition to processing costs, transport costs and authorities’ fees for processing permits are included in the total costs.

Code of practice

Waste shipments from Finland to another country for disposal require a waste shipment permit from the Finnish Environment Institute and the waste shipment authorities of the recipient country and any transit countries (notification procedure). The permit is applied for by the waste exporter. See the instructions for applying for a waste shipment permit here.

Import of waste for recovery

In the country of origin, the waste exporter is obliged to determine the procedure to follow for the shipment of waste and, where necessary, to apply for a permit for the shipment of waste. Waste shipment permits from the Finnish Environment Institute and the waste shipment authorities of the country of origin and any transit countries are required to import waste that requires a permit (notification procedure). For the purposes of so-called green waste shipments, the exporter ensures that the necessary documents have been drawn up and that the shipment document is included in the shipment.

The recipient of the waste must ensure, for their part, that the exporter has the necessary information about the facility receiving the waste and the intended processing of the waste in the country of origin. The recipient of the waste must sign an agreement required for waste shipments with the exporter. The recipient also has obligations related to the reception of waste batches.

Code of practice

See general instructions for importing waste here. Separate instructions for receiving waste batches are available here.

Import of waste for disposal

Importing waste for disposal always requires waste shipment permits from the Finnish Environment Institute and the waste shipment authorities in the country of origin and any transit countries (notification procedure). The waste exporter applies for a waste shipment permit by submitting the application to the competent authority in the country of dispatch.

Import restrictions in the Waste Act

In accordance with Section 110 of the Waste Act (646/2011), the import of waste for disposal requires that the disposal of waste generated in Finland is not prevented or delayed due to the import. The Finnish Environment Institute always ensures this in connection with processing the application. In addition, pursuant to Section 110 of the Waste Act, in the case of a shipment of waste for disposal in Finland, the acceptance of the shipment requires that:

  1. hazardous waste is incinerated in a specialised plant;
  2. the waste is treated biologically or physicochemically; or
  3. the placement of waste in the ground, on soil or in specially designed landfills, or incineration of non-hazardous waste is based on regional cooperation in waste management between Finnish and Swedish or Finnish and Norwegian municipalities.

Code of practice

The recipient of the waste must ensure, for their part, that the exporter has the necessary information about the facility receiving the waste and the intended processing of the waste in the country of origin. The recipient of the waste must also sign an agreement required for waste shipments with the exporter. The recipient of the waste also has obligations related to the reception of waste batches.

See general instructions for importing waste here. Separate instructions for receiving waste batches are available here

Waste or product?

The procedures for international shipments of waste do not apply to shipments of materials classified as products. It is the responsibility of the exporter to prove, where appropriate, that the material is not waste. In some cases, the authorities of different countries may have differing views on the classification. In this case, the policy of the strictest authority is always followed, in which case the shipment of material classified as a product may also require compliance with waste shipment procedures. For example, in the following cases, the view on the classification should be established for all countries involved in the shipment.

Termination of the classification as waste (End of Waste, EoW)

The classification as waste may end and the waste may cease to be waste if the requirements laid down in Section 5 b of the Waste Act (646/2011) are met.

Currently, the EU's End of Waste (EoW) criteria are defined for the following waste fractions: iron, steel and aluminium scrap, glass cullet and copper scrap. The classification of other waste as waste may also cease if the competent authority has decided in its decision that the substance or object has ceased to be waste as a result of the recovery operation.

Each batch of EoW produced or imported into the EU shall be subject to a declaration of conformity. The declaration shall be sent to the next holder of the EoW consignment and, on request, to the supervisory authority. The templates for the declaration of conformity are attached to each regulation.

The EU EoW criteria are applicable only in the EU, and national EoW decisions are valid only in the country where they were issued. In transfrontier shipments of waste, the operator must ensure the position of the authorities of all the countries concerned on the end of the classification as waste.

Commission regulations on the criteria for End of Waste defined by the EU:

In Finland, the national criteria for end-of-waste classification are defined for crushed concrete. 

By-products

The so-called side-products generated in the production process, produced in addition to the main product of the process, can be defined as by-products. A by-product is not waste as referred to in the Waste Act, and thus it is not subject to the provisions laid down in the Waste Act or under it. The criteria for assessing the by-product are defined in Section 5(a) of the Waste Act. The need to comply with waste shipment procedures for by-products must be determined before they are shipped from one country to another.

Used products such as vehicles, tyres, spare parts or electrical and electronic equipment

When shipping used products such as vehicles, tyres, spare parts or electrical and electronic equipment from one country to another, the exporter must be able to demonstrate that they are suitable for re-use and are not exported as waste.

Vehicles, tyres, spare parts or electrical and electronic equipment may be classified as waste unless there is sufficient evidence that they are functional, suitable for their original purpose as such or that the vehicles are fit for road traffic with no more than minor repairs. The supervisory authority may request a report on the matter, which must be submitted by the given deadline. If the report has not been provided or is incomplete, the transport or shipment is treated as an illegal waste shipment. The restrictions on the import of second-hand products in the receiving country must be determined before export.

Below are instructions and forms for exporting used products and end-of-life vehicles and catalysts classified as waste. 

Used electrical and electronic equipment

    Used vehicles, automotive spare parts, used tyres, end-of-life vehicles and catalytic converters

     Authority in Finland

    In Finland, the Finnish Environment Institute carries out the official duties related to the international shipments of waste. Official duties include the processing of waste shipment permits and making decisions, supervision of waste shipments and inspections in cooperation with the customs, police and regional authorities, training and counselling on international waste shipments and acting as an EU contact person for waste shipments.

    Information on Finland's transfrontier waste shipments

    As a rule, the permits required for waste shipments are valid for one year, and approximately 200 permits are issued each year. Approximately 10,300 individual waste shipments were made under permits in 2021.

    Valid waste shipment notifications 1.3.2024 (pdf, 278 KB)

    National report on waste shipment inspections and illegal waste shipments in 2020 in accordance with Section 51(2) of the Waste Shipment Decree.

    Waste Shipment Regulation Section 51(2) report (pdf, 158 KB)

    Contacts for additional information

    The Finnish Environment Institute is the competent authority for international waste shipments in Finland. For questions related to international waste shipments, please contact wasteshipments@syke.fi.

    Other contact details are available on the Contact persons and information for waste shipments page.

    Publisher

    Finnish Environment Institute (Syke)