Environment Agency reverses pre-notification for paper grades to Indonesia mistake


A requirement that exports of paper grades to Indonesia needed to be pre-notified has been withdrawn by the Environment Agency.

In recent weeks, exporters of paper grades to Indonesia were suddenly surprised to find that both the National Packaging Waste Database (NPWD) and Waste Export Control Tool (WECT) were displaying that these were notifiable (known as Amber List), when previously they had been Green List and not needing to be notified.


When the transition period ended on leaving the European Union, the UK had adopted all the previous regulations on exports of waste materials. But somehow in the regulations transition, exports of paper grades to Indonesia suddenly became notifiable.

This meant that paper and cardboard exporters were unable to send material to Indonesia because a notification agreement was not in place between UK and Indonesia. It also meant that exporters could not claim PERNs on these exporters.

However, following representation from The Recycling Association and exporters to Defra and the Environment Agency, the latter has now admitted the websites contained “inaccuracies” and reversed the measures. In a statement to exporters, the Environment Agency said:

“Thanks for bringing to our attention the issue of B3020 paper to Indonesia being stated as Notifiable on the WECT tool which is a change from our previous position.

“We have reviewed the various amendments of the Green List Waste Regulations 1418/2007 and traced B3020 travelling to Indonesia through each set of legislation.  The consolidated version of the Regulations which is published on the Commissions website appears to contain inaccuracies in the entry for Indonesia.  It is also clearly stated that this Consolidated set of Regulations is not legally binding.

“In our view waste code B3020 is listed in column (d) of the entry for Indonesia on the official Regulation Amendments. Exporters of this waste from England will need to comply with Art 18 controls and also with the applicable controls in the country of destination. We advise exporters to check with the Competent Authority of destination before carrying out any such exports to ensure that the applicable controls are complied with as there may be other local controls.  Exporters should also check with the relevant Competent Authority if they are exporting from Wales, Scotland or Northern Ireland.

“We are in the process of updating the Waste Exports Control Tool to reflect this, and have carried out further checks to ensure no further transposition issues have occurred.  We will ensure that it is clear that the WECT tool has been updated and the changes that apply.

“Defra are leading on the consultation with non OECD countries to establish the controls for B3011 plastics which will be captured in updated legislation in due course.  If there are further amendments to the controls implemented for this or any other wastes we will engage with Industry to allow as much notice for preparation as possible.

“This outcome means that this issue should not impact the issue of PERN evidence where legally exported.”


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