FEAD criticises Norway proposal on putting recycled plastics on export amber list


Waste management federation FEAD has criticised Norway’s proposal given at the Basel Convention on how recycled plastics will be classified for export. 

While FEAD has welcomed Norway’s ambition to address the marine plastic issue, it said that the proposal is going to miss the objective, and risks hindering the development of an EU market for plastic waste by raising administrative burdens and the costs of shipping the waste.  


FEAD has said to reduce the amount of refuse going into the oceans, an effective enforcement of waste management legislation, an expansion of waste collection and treatment infrastructure, and dissemination of information and best practise, is needed.  

While a large quantity of non-hazardous plastic crosses the boarders within the EU under the aforementioned waste entry and under the application of the green procedure for recovery, an additional number of transfers would then be subject to notification. 

From this, there would be an increase in the administrative burden for the notifiers and administrators, without any positive environmental impact within the EU, according to FEAD. 

To stop this, FEAD has called for: 

  • A robust impact assessment since the Norwegian proposal could negatively impact plastic recycling and recovery 
  • Complementing measures to generate European demand for recycled materials and investment in recycling capacities  
  • A sufficient lead in time to allow new recycling infrastructure to be built 
  • A clear commitment by the EU to limit delays for notified shipment 
  • Consideration to be given to intra EU trade.  

In early November 2018, Norway submitted a revised proposal to amend annexes II, VIII and IX of the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal.  

With the proposal, plastic waste will fall into three categories under the Basel Convention: 

  • A single polymer uncontaminated plastic waste 
  • Plastic waste requiring special consideration for all plastics not covered by entry AXXXX of Annex VIII or B3010 of Annex IX 
  • Hazardous plastic waste. 

All waste that doesn’t comply with B3010 has to be registered on the “amber list” and exporters will have to apply the notification procedure.

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