Feed-Back to the public consultation from the working group “Fast Track Notifications”
Introduction
Efficient cross-border shipments of recyclable materials are important to Europe's circular economy, particularly where specialised treatment capacity is located in another Member State. However, complex notification procedures, differences in national interpretation and uncertainty over waste classification can create barriers for companies moving secondary resources across borders.
In January 2022, the North Sea Resources Roundabout (NSRR) Fast Track Notifications Working Group submitted feedback to the European Commission's public consultation on the proposed recast of the Waste Shipment Regulation. EERA and EuRIC participated actively in the working group.
The response focused on pre-consented recovery facilities and how harmonised fast-track procedures could simplify shipments between compliant European recyclers. It addressed mutual recognition of pre-consent, notification timelines, digitalisation, waste classification and financial guarantees, while maintaining environmentally sound treatment and regulatory oversight.
Background: the NSRR Fast Track initiative
The North Sea Resources Roundabout was established to address barriers to the cross-border movement of secondary resources. Initiated by the Netherlands, the United Kingdom, France and Flanders, the five-year agreement was signed in March 2016 to facilitate trade and transport of secondary resources in the North Sea region.
Fast Track Notifications became the initiative's fifth case following a request from WEEE recycling companies in the Netherlands and Austria for simpler and more predictable shipment procedures. Public and private sector experts from the Netherlands, Austria and France formed a working group to develop practical solutions.
The group developed common criteria for pre-consented facilities, explored mutual recognition between competent authorities and examined harmonised notification procedures. Flemish and UK representatives and the European Commission observed the work, while EERA and EuRIC participated in the discussions. This experience formed the basis of the group's 2022 consultation response.
Why pre-consented facilities matter
The working group viewed pre-consented recovery facilities as central to simplifying shipments between compliant recyclers. It welcomed the Commission's proposal to reduce the administrative burden for shipments to facilities already assessed for receiving and treating notified waste.
The group argued that wider use of pre-consent could benefit both competent authorities and recyclers. Authorities could process notifications more efficiently because the receiving facility had already been assessed for environmentally sound treatment, while recyclers could benefit from shorter and more predictable procedures.
Reducing the administrative workload associated with compliant shipments could also allow competent authorities to devote more resources to tackling illegal waste exports. Pre-consent was therefore presented as a way to combine effective regulatory oversight with proportionate procedures for compliant recycling operations.
Harmonising pre-consent across the EU
The working group argued that pre-consent would deliver its full benefits only if it operated consistently across Member States. It welcomed common conditions for granting pre-consented status, mutual recognition and harmonised requirements for shipments to these facilities.
Clear criteria would give competent authorities in countries of dispatch greater confidence that waste sent to a pre-consented facility would receive environmentally sound treatment, reducing the need to reassess the receiving facility for individual notifications.
The response considered the proposed seven-year validity period reasonable, while recommending arrangements to prevent later notifications from being constrained by an approaching expiry date. It also accepted that authorities should be able to revoke pre-consent, but called for clearly defined grounds. The group ultimately sought EU-wide recognition and implementation of the Fast Track concept.
Faster notification procedures
Drawing on the Fast Track pilot between the Netherlands and Austria, the working group supported shorter and more predictable timelines for shipments to pre-consented facilities. It considered a response period of seven working days for competent authorities after receiving notification information reasonable, together with a maximum 30-day period from submission of the notification request.
The response also proposed allowing notification requests and related correspondence, at least for shipments to pre-consented facilities, to be submitted in English. Together, these measures were intended to make procedures faster and more consistent while retaining the regulatory controls applicable to notified waste shipments.
Digitalising waste shipment procedures
The working group welcomed the Commission's move towards modernised and digitalised waste shipment procedures. It argued that an EU-wide digital system could help establish standardised and harmonised business processes as well as replace paper documentation.
The response supported digital management of Prior Informed Consent notifications, pre-consent procedures and shipment documentation. During the transition, when paper and digital systems might operate in parallel, it proposed digitally formatted and signed PDF notification documents, digital signatures and electronic movement documents.
Where competent authorities already operated databases, the group also proposed electronic submission of proof of delivery and proof of treatment. The objective was to ensure that digitalisation simplified procedures rather than adding another administrative layer.
Simplifying waste classification
The working group identified waste classification as another source of complexity. It highlighted the reclassification of mixed plastic waste as an example of how rapid regulatory changes could disrupt recycling value chains, leaving recyclable material accumulated in some countries while facilities elsewhere lacked feedstock.
The response questioned the need for multiple waste coding systems for intra-EU shipments and called for greater harmonisation and simplification. It welcomed clearer classification guidance but stressed the importance of making guidance available when rules change.
For recyclable waste destined for pre-consented treatment facilities, the group proposed reducing the number of coding systems required, making classification more predictable while maintaining appropriate shipment and treatment controls.
Financial guarantees for fast-track shipments
The working group identified financial guarantees as one of the most costly and time-consuming parts of the notification process. Based on its survey of competent authorities, it reported that guarantees had been required in only 1 in 10,000 cases, while estimating that more than €1 billion in capital was immobilised through the system across the EU.
The group argued that this burden was disproportionate, particularly for pre-consented facilities that were already permitted and assessed and received material from known sources.
It therefore asked the Commission to consider Fast Track or pre-consented shipments as a distinct category for which financial guarantees could be abolished, substantially reduced or simplified, potentially through a European fund. These figures and proposals reflect the working group's 2022 consultation response.
Key recommendations
Establish clear, harmonised EU-wide criteria for granting pre-consented status and ensure mutual recognition by Member States.
Implement the Fast Track concept consistently across EU competent authorities.
Apply faster notification procedures, including a seven-working-day response period and a 30-day overall timeframe.
Allow notification requests and related correspondence for pre-consented shipments to be submitted in English.
Accelerate digitalisation, including digital signatures, electronic documentation and electronic proof of delivery and treatment.
Simplify and harmonise waste classification and coding, particularly for recyclable materials destined for pre-consented facilities.
Review financial guarantee requirements for Fast Track shipments, including options to abolish, reduce or simplify guarantees for pre-consented facilities.
Expected impact
The proposals aimed to make shipments to pre-consented recovery facilities faster, more predictable and less administratively burdensome while maintaining environmental controls. For recyclers, harmonised pre-consent, shorter timelines, digital procedures, simpler classification and proportionate financial guarantees could improve access to specialised treatment capacity across the EU.
For competent authorities, common criteria and recognised pre-consented facilities could reduce resources spent on routine notifications and allow greater focus on enforcement against illegal waste exports. More broadly, the proposals sought to support European recycling value chains through a more harmonised framework for legitimate intra-EU shipments of secondary resources.
About the consultation response
The NSRR Fast Track Notifications Working Group prepared the response in January 2022 for the European Commission's public consultation on the proposed recast of the Waste Shipment Regulation. It drew on practical experience from the North Sea Resources Roundabout and its Fast Track pilot. EERA and EuRIC participated actively in the discussions.
The document reflects the Waste Shipment Regulation proposals and policy context of 2022 and should be read in that historical context.
Read the full response
Read the full consultation response for the working group's detailed proposals on pre-consented facilities, notification procedures, digitalisation, waste classification and financial guarantees under the proposed recast of the Waste Shipment Regulation.
Related Publications:
