Making E-Waste Shipments Work for Recycling
Joint Statement - EERA & FEAD on OECD/Basel changes for e-waste
Moving e-waste and recovered materials across borders is an important part of a functioning circular economy. Specialist treatment and recovery facilities are not available in every country, and some recycling processes require sufficient volumes to operate efficiently and recover valuable secondary materials.
In October 2022, EERA published a joint response with FEAD on the incorporation of amendments to the Basel Convention into the OECD Decision. We supported stronger controls to prevent untreated e-waste from being shipped to countries without appropriate treatment infrastructure, while calling for shipment procedures that allow legitimate recyclables to reach environmentally sound recovery facilities efficiently.
Why efficient cross-border shipments matter
E-waste contains complex combinations of metals, plastics and other materials. Recovering these resources effectively can require specialist technologies and sufficient economies of scale.
We therefore stressed the importance of maintaining access to professional treatment and recovery facilities across borders, including for e-waste generated in countries without the necessary domestic infrastructure. The response also highlighted the importance of these facilities for recovering secondary materials, including critical raw materials.
The challenge was to strengthen controls over problematic shipments without creating barriers that could make legitimate recycling routes unnecessarily difficult or expensive.
The pressure on the Prior Informed Consent system
Changes to Basel Convention e-waste classifications were expected to substantially increase the number of shipments requiring Prior Informed Consent (PIC).
Our joint survey with FEAD showed that the existing system was already under pressure. Members reported backlogs of three to six months and, in some cases, a year or more before receiving an initial response or final approval from competent authorities.
These delays have practical consequences. Materials may need to remain in storage for longer, potentially affecting their quality and increasing operational, environmental and health and safety pressures at recycling sites.
Making pre-consent work in practice
Pre-consented recovery facilities should benefit from accelerated notification procedures because their treatment operations have already undergone additional assessment. Yet our survey found that some countries had no process for facilities to obtain pre-consented status, while the status was not always recognised when individual shipments were assessed
We called for:
Pre-consent procedures to be available across OECD countries
Simplified, digital and transparent applications
An accurate, up-to-date online database of pre-consented facilities
Clear fast-track procedures recognised by competent authorities
Better training and resources for authorities handling e-waste notifications
For shipments to pre-consented facilities, we proposed a maximum assessment period of one calendar month for the competent authority of dispatch and ten working days for the destination authority.
Reducing financial and administrative burdens
The PIC process can impose significant financial and administrative costs on legitimate operators. Members reported having to maintain multiple financial guarantees for concurrent notifications, often covering different routes for the same secondary materials. Survey respondents reported obligations for global guarantees exceeding €1 billion in total each year, tying up substantial amounts of capital.
We called for a simpler, risk-based approach to financial guarantees, including the possibility of a single guarantee covering multiple active movements by the same notifier. Guarantees should also be released automatically once final treatment has been confirmed.
Administrative charges added another layer of cost and uncertainty. Members reported fees ranging from €1 per tonne to more than €18,000 for a 12-month notification, with charges sometimes imposed by the countries of dispatch, transit and destination.
We therefore called for reasonable, transparent and harmonised administrative charges, proportionate to the actual work involved and the environmental risk of the shipment.
Digitalising waste shipment procedures
Digitalisation was central to our recommendations. We called for a single secure digital platform covering the different stages of a transboundary movement, including pre-notification, confirmation of arrival and confirmation of final treatment.
Such a system could reduce administrative work, improve transparency around fees and approval procedures, and help authorities monitor the performance of the system. We pointed to the electronic data interchange approach being developed under the revised EU Waste Shipment Regulation as a potential model for wider international shipments.
Keeping legitimate recycling routes open
Stronger controls should prevent environmentally harmful shipments without blocking access to appropriate recycling infrastructure.
We therefore called for clarity that imports from non-OECD countries into OECD countries would remain possible where environmentally sound treatment and recovery capacity was available. This was particularly relevant where countries lacked the scale or specialist infrastructure required to recover materials domestically.
Within Europe, we also argued for simplified procedures for movements of e-waste and derived components or fractions, particularly where materials were destined for professional or pre-consented facilities operating under established environmental controls.
EERA and FEAD called for
EERA and FEAD called for a waste shipment system that focuses regulatory effort where environmental risks are greatest, while making legitimate recycling movements faster and more predictable.
This would require greater harmonisation of PIC procedures across Europe, effective fast-track processes for pre-consented facilities and competent authorities with sufficient resources and expertise to process notifications efficiently. Financial guarantees and administrative charges should be proportionate to actual risk, while digitalised procedures should reduce duplication and improve transparency.
The system should also provide greater flexibility for legitimate transport routes and carriers and ensure continued access to specialist recovery facilities capable of delivering environmentally sound treatment.
The underlying principle was straightforward: stronger environmental control does not require greater administrative complexity. A more consistent, digital and risk-based system could strengthen oversight of problematic and illegal shipments while allowing recyclable materials to move efficiently to the facilities best equipped to recover them.
About the joint response
The European Electronics Recyclers Association (EERA) and the European Waste Management Association (FEAD) published this joint response in October 2022. It reflects the Basel Convention, OECD and EU waste shipment discussions taking place at that time.
Read the original document for the detailed evidence and recommendations.
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