FEAD says that green list exports of recyclate are “essential” following EU vote to introduce notification


European waste management trade association FEAD said that green list exports of recycled materials are “essential” and that insisting on a notification will put a burden on non-EU countries.

Following the European Parliament’s vote to require consent on exports of recyclable materials, FEAD said in a statement that it remains “essential to safely ship non-hazardous ‘green listed’ waste, which is a commodity, beyond EU borders to be integrated as secondary raw materials in manufacturing processes. The extreme administrative burden that is intended to be put on third countries to be able to receive such ‘green listed’ waste will have a disproportionate deterrent effect, while sound environmental management, transparency, and traceability can be equally and sufficiently ensured through audit procedures”.


FEAD also warned about the proposed ban on exports of plastics outside of the EU by 2027.

It said in the statement: “FEAD favours positive rules that allow for safe and traceable shipments of plastic waste within the EU, considering the specificities of the EU single market and the EU waste management industry, and outside the EU to the countries where industries using them are located…

“…In this case, the Basel Convention COP 14 already introduced new and strict waste codes for plastics to enhance the control of the transboundary movements of plastic waste, which entered into force in 2021, and that have led to a factual decrease in exports. Exporting those plastic wastes does not negatively impact the environment, while not doing so will result in the lack of recycling opportunities because there is not enough demand for it within the EU.

“Within the EU, facilities are becoming highly specialised, and no Member State has all the facilities to treat all waste streams. Removing references to the EU plastic waste codes will lead to certain plastic wastes no longer being classified as ‘green-listed waste’ and being consequently subject to the prior-informed consent procedure with its associated heavy administrative burdens and costs.

“In the EU, collection, sorting and recycling often occur in different Member States, meaning that plastic waste shipments that are currently destined for intra-EU trade and recycling will be severely affected by these significant new hurdles. Long-term and uncertain controls present a barrier to the recycling and recovery markets in the EU, which is counterproductive to the goal of circular economy.”

FEAD president Claudia Mensi added: “While we are pleased with the steps taken by the European Parliament towards an EU single market for waste, it is important to recognise that it was also a missed opportunity for needed improvements, such as the reinforcement of pre-consented facilities.

“In terms of exports, we must avoid a de facto ban, and work with a more nuanced waste-stream-specific approach and reasonable administrative burdens for third countries. Non-hazardous ‘green listed’ waste is a commodity and, when there is no sufficient demand in the EU, it must continue to be possible to ship it outside the EU, where it will be reincorporated in manufacturing processes.”