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EU Waste Shipment Regulation should not incentivise landfills capacity.


19 Nov 2021



To safeguard sustainable treatment of waste in Europe, the proposed new waste shipment Regulation needs clear rules for intra-EU shipments.

ESWET welcomes the Commission’s proposal to revise the waste shipment Regulation to reduce waste exports and treat municipal waste in Europe under EU standards, but calls for coherent and clearer rules for intra-EU shipments.

Under EU law, high environmental standards apply to waste treatment, which must be in line with the waste hierarchy. The waste chain is integrated, meaning that it relies on several interdependent links:

  • Reuse for the waste that cannot be prevented;
  • Recycling for the waste that cannot be reused;
  • Treating non-recyclable waste in Waste-to-Energy facilities;
  • And landfilling for the ultimate fraction of waste that cannot be treated otherwise.

In this context, the role of the waste shipment regulation is to ensure the safe transfer of waste to treatment facilities, the choice of the most appropriate treatment solution being determined by other legislative texts and national waste management plans.

While a proximity principle should apply for treatment of waste, unnecessary obstacles to intra-EU shipments of municipal solid waste could disrupt national waste management chains and its mission to prevent waste-related pollution.

For instance, if there is no Waste-to-Energy plant in a border region, and non-recyclable waste can no longer be properly treated in the neighboring country, then it is likely to end up in the local landfill, which would be contrary to the logic of the waste hierarchy.

ESWET thus invite the Commission and co-legislators to carefully reconsider the impact of restrictions on intra-EU shipments of municipal solid waste and to clarify the rules applicable to transfer of waste to EFTA countries that are also applying EU environmental standards. It is essential for the Waste Shipment Regulation to support the safe transfer of waste without hampering its optimal treatment as prescribed in other pieces of EU legislation.



The Environmental Defense Fund
Manager, EU Energy Transition
Deutsche Gesellschaft für Internationale Zusammenarbeit GIZ GmbH
Senior Policy Advisor and team coordinator (m/w/d)
International Organization for Migration
AVRR Counsellor
European Union Agency
EU trilingual Communication Officers
GIZ GmbH (Deutsche Gesellschaft für Internationale Zusammenarbeit)
Junior Communications Advisor (m/w/d) for Get.Invest
European Heat Pump Association
Communications Officer
Confederation of the European Bicycle Industry (CONEBI)
Public Affairs Officer
European Institute of Peace
Senior Accountant