Frequently asked questions
Penalties for not having a waste transport permit in Europe can vary significantly across Member States, as each country is responsible for implementing and enforcing the European Waste Shipment Regulation (EC) No 1013/2006 through its national laws. The specific nature and severity of penalties are determined by the individual legal and regulatory frameworks of each Member State. Most commonly used penalties are as follows:
fines (the most common penalty for violations related to waste transport without the necessary permits; the amount can vary widely depending on the country, the severity of the violation, and whether it is a repeat offense)
imprisonment (in some cases, particularly for severe or repeated violations, individuals responsible for unauthorized waste shipments may face imprisonment)
confiscation of waste (the unauthorized shipment may be seized or confiscated by authorities)
suspension or revocation of waste transport licence (companies involved in illegal waste transport activities may have their operating licenses suspended or revoked, preventing them from continuing their operations)
administrative sanctions (these can include prohibitions on certain activities, obligations to take specific actions – like training or audits – or other administrative measures)
Unfortunately not. The Regulation (EC) No 1013/2006 on shipments of waste serves as a foundational guideline for Member States within the European Union, outlining the procedures and controls for the transboundary shipment of waste. While it establishes a comprehensive framework at the EU level, Member States have the autonomy to develop and enforce their own specific rules and requirements for permits related to international waste transport, building upon the principles and standards set out in the regulation. This allows individual countries to tailor their waste management policies to better suit national environmental objectives and conditions, provided they adhere to the regulation’s minimum requirements. As a result, while the regulation sets the baseline for waste shipments across the EU, the specifics of permit issuance and additional controls can vary from one Member State to another, reflecting their unique legislative and regulatory approaches to managing waste transport.
You’ve come to the right place! Whether your aim is – for example – to deliver waste from Poland to Germany or if you’re about to sign a contract for waste transport between other EU Member States, we’re here to provide comprehensive assistance. With almost a decade of experience in the field, our expertise covers the intricacies of applying for waste transport permits within the European Union, ensuring that your waste management operations comply with all necessary regulations and standards.
Regulation (EC) No 1013/2006 on shipments of waste. This regulation implements the Basel Convention’s guidelines within the EU and includes provisions from the OECD Decision regarding waste destined for recovery operations. It outlines procedures and control regimes based on the waste’s destination, origin, and type, with specific emphasis on hazardous waste. The regulation aims to ensure that waste shipments are managed in an environmentally sound manner, protecting both the environment and human health. For the most accurate and current information, consulting the latest updates to this regulation is recommended.
The Basel Convention on the Control of Transboundary Movements of Hazardous Wastes and Their Disposal. It’s an international treaty designed to reduce the movements of hazardous waste between nations, especially from developed to less developed countries (LDCs). It was adopted on 22 March 1989 and entered into force on 5 May 1992. The convention aims to protect human health and the environment against the adverse effects resulting from the generation, management, transboundary movements, and disposal of hazardous and other wastes.
OECD Decision. The OECD Council adopted the Decision on the control of transboundary movements of wastes destined for recovery operations, known as the OECD Decision, on 30 March 1992. This Decision has been revised and updated several times to reflect changes in waste management practices, environmental considerations, and the regulatory landscape. The most notable update to the Decision was made in 2001, which further refined the controls and classifications of wastes moving across borders for recovery operations among OECD member countries. These updates ensure that the Decision remains relevant and effective in promoting environmentally sound management practices for the transboundary movement of recyclable wastes.
Most important document would be a permit to transport waste to the specific country. To obtain it you’ll have to register as waste carrier or send the appropriate application to the respecting authority of the country you’d like to deliver waste to.
Second document would be an Annex VII document which is a crucial form related to the transboundary shipment of non-hazardous waste (also called “green waste” as outlined under the Regulation (EC) No 1013/2006). This document is filled in and signed when shipping regular waste, serving as a shipment document. It is essential for the consignor to ensure that this document accompanies the transport at all times. Upon request, this document must be presented to authorities supervising the waste shipment to confirm that the waste will be handled in an environmentally sound manner at its destination. The document and any accompanying contract must be available to be presented to the authorities monitoring waste shipments on demand.
You certainly need a permit to transport waste to the specific country. To obtain it you’ll have to register as waste carrier or send the appropriate application to the respecting authority of the country you’d like to deliver waste to.
For the transport of hazardous waste internationally in Europe, you also need to provide documents such as a notification form, consent from all relevant authorities, a movement document, a contract between the waste producer and the disposer, and proof of insurance or financial guarantee. These documents ensure compliance with EU regulations and the Basel Convention, safeguarding environmental and public health. Consult us for the most current information concerning requirements and detailed procedures.
The A-Schild is a legally required sign in Germany for vehicles transporting waste as part of their business activities. It applies to both hazardous and non-hazardous waste, regardless of the quantity, to ensure proper waste management oversight. This sign must be visibly displayed on both the front and rear of the vehicle. While specific to Germany, it highlights the importance of regulatory compliance in waste transport within Europe.
When transporting hazardous waste through Europe, your truck needs to be equipped with ADR plates and markings that indicate the transport of hazardous materials. These include orange plates on the front and rear of the vehicle, and hazard identification numbers (HIN) or UN numbers that specify the type of hazardous materials being transported. Additionally, vehicles must carry appropriate safety equipment, and drivers need to have an ADR training certificate. Each country may have specific additional requirements, so it’s important to check the national regulations of the countries you’ll be passing through.
Green-List Waste refers to non-hazardous waste that poses minimal risk to the environment and human health, allowing for easier cross-border movement within the EU and OECD countries. Amber-List Waste includes waste that can be hazardous under certain conditions and requires more stringent controls, including prior notification and consent procedures, to ensure safe handling and disposal. The key difference lies in the level of environmental risk and the regulatory controls applied to their transboundary movement.
Yes, neutralizing documents to conceal the origin or destination of waste during transport in Europe is generally against the law. European regulations require transparency in waste transport to ensure traceable and safe management of waste, adhering to environmental protection standards. Compliance with these regulations is mandatory to prevent legal repercussions.
Yes, if you’re transporting waste to or through Poland, you must register the transport in the SENT System (System for Electronic Transport Supervision) as mandated by the National Tax Administration in Poland. This applies to all waste imports into Poland and covers both road and rail transports. The SENT system is part of Poland’s efforts to monitor and regulate the movement of sensitive goods, including waste, to counteract illegal activities and ensure compliance with environmental regulations.
Being charged with illegal waste transport in Europe can lead to severe penalties, including hefty fines, legal sanctions, and potentially imprisonment. The exact consequences depend on the specific laws of the country involved and the nature of the violation, such as the type of waste and the extent of environmental harm caused. It underscores the importance of adhering to all regulatory requirements for waste transport to avoid significant legal and financial repercussions.
Yes, drivers transporting hazardous waste must have ADR training. This training ensures they are knowledgeable about handling hazardous materials safely, understand the legal requirements, and can take appropriate actions in case of an emergency. It’s a legal requirement for ensuring the safety of the transport process, the environment, and public health.
It all depends on the country you’d like to deliver waste to. Sometimes all it takes is just one document and you’re good to go. Some other time you end up with long list of documents. And they must be prepared in a specific way, otherwise you’ll have to redo them or start the whole registration procedure anew. And in the end you’re spending days if not weeks to meticulously prepare them only to find out you forgot one signature or you put wrong information in wrong section. Discouraging, isn’t it? To make sure you’re well prepared for the transports to come, let us take care of everything for you.
That’s possible. Check if the code you see looks like this:
15 01 02 or 150102
The 6-digit code is structured to provide specific information about the waste material, based on its source, composition, and potential hazards. Here’s a breakdown of what these digits represent:
- The first two digits indicate the major category of the waste, essentially describing the industry or process that generated the waste. For example, codes starting with “15” relate to wastes geneated from used packaging, wiping cloths, filter materials and protective clothing not otherwise specified.
- The next two digits provide further detail within that category, specifying the type of process or specific operation that produced the waste. This level of detail helps in identifying the waste more precisely within its broader category.
- The final two digits are used to specify the waste material even more closely, often indicating its specific composition or particular characteristics. This level of specificity helps in determining the appropriate handling, treatment, and disposal methods for the waste.
For more details you can consult the Waste Shipment Regulation
Waste codes starting with “A” or “B” are part of a system designed to classify wastes based on their hazardous characteristics and their suitability for transboundary movement. The letters “A” and “B” precede numerical codes in two distinct lists within the Convention:
- List A (Annex VIII): The “A” codes are associated with wastes that are presumed to be hazardous across all jurisdictions that are party to the Basel Convention. These wastes are subject to the Convention’s full range of controls and require notification and consent before they can be transported across international borders. The presumption of hazardousness is based on the characteristics of the waste, such as being flammable, toxic, corrosive, or ecotoxic. The list aims to provide clear guidance on which wastes are considered hazardous to facilitate regulation and ensure proper handling.
- List B (Annex IX): The “B” codes identify wastes that are not presumed to be hazardous. They are generally not subject to the same stringent controls as List A wastes for transboundary movements. These wastes are considered less likely to pose significant risks to human health and the environment, if they are managed properly. The inclusion of a waste in List B does not automatically mean it is non-hazardous in all circumstances. It means that under normal conditions, the waste is not classified as hazardous according to the Convention.
The use of “A” and “B” to start the waste codes is a straightforward way to differentiate between these two categories of wastes under the Basel Convention, facilitating international communication and regulatory processes related to the movement and management of hazardous and non-hazardous wastes across borders. This classification system helps countries and waste handlers determine the appropriate procedures for notification, consent, and handling of waste shipments to protect human health and the environment from the potential dangers of improperly managed waste.
Yes, it’s mandatory to keep the proof of registration as waste carrier with you during transport activity.
Various waste can be transported on the same trailer, provided they are not physically mixed together. And if there’s no risk of cross-contamination. It’s essential that each type of waste is separately classified, described, and quantified on the accompanying waste documentation. This approach ensures that each type of waste is managed appropriately without the need for separate trailers, as long as the segregation and documentation guidelines are followed correctly.
The fact that you’re transporting waste with just one trailer doesn’t matter. If you want to transport different kinds of waste on the same trailer, you need to make sure that the waste is secured to prevent the cross-contamination. For each type of waste you have on your trailer, you need one Annex VII document.
In some cases the registration will cover both kinds of waste (hazardous and non-hazardous) without the need of mentioning the precise waste code. Such is the case for Germany, Netherlands and Denmark, while in Sweden you have an option to choose the exact waste codes. Same goes for Belgium (Brussels region) and Italy. If you pick some waste codes and decide to expand their list later on, the update fee may be imposed.
Some waste licenses are valid for 1 year, some for 3 or 10 years or indefinitely. It all depends on the country where you applied for such permit. For example when you register as waste carrier in the Netherlands, you’ll be allowed to transport waste there for as long as you want, unless the conditions change (so you’ll have to keep an eye out for any changes in national waste law). But when you apply for waste license in Belgium, in Flemish region, your permit will be valid 10 years. And many things can happen during that time. On the other hand, if you decide to transport waste to Wallonie, the permit there would be valid for 5 years. In some instances the validity period can vary depending on the scope of the permit (for non hazardous waste it will be indefinite, but for hazardous waste – 3 years; that’s how it is in Sweden).