Cross-border shipments of waste within the EU

The cross-border transportation of waste is an increasingly important aspect of the global economy. This article presents basic information on the procedures and documents necessary to obtain a permit for the transboundary movements of waste. To make it as easy as possible for you to assimilate the information on this topic, we have compiled a list of short and concrete tips that are ready to be put into practice!

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9 tips on how to organise cross-border waste shipments

Shipments of waste - e.g. wind turbine blades (more on this below) - between countries requires an understanding of, and compliance with, numerous rules. All for, to ensure safety and environmental protection. Let us therefore start with this, how to organise the transport of waste between two EU countries. 

What do you need to take care of even before just transporting the waste?

1. Ensure that the facility that will accept the waste has the appropriate permits for the disposal and recovery of waste. Check that the transport operator has the appropriate consents i permits (of which: required registrations in the Polish SENT and PUESC systemsif the carriage is to Poland).
2. Prepare application for transboundary waste shipment permit (Annex 1A). The application must include: details of the notifier, the carrier and the facility receiving the waste, as well as details of the waste shipment. The notifier - which is usually the entity that intends to recycle - must also demonstrate financial guaranteewhich will cover the costs of waste disposal and recovery and any additional costs associated with the shipment. There are many more requirements in this respect, as the application contains many annexessuch as confirmation of the aforementioned financial guarantee or invoices for waste shipments. It is therefore worth enlisting the support of a lawyer specialising in waste shipment procedures.
3. Submit the application and its annexes to the relevant authorities of the countries involved in the carriage: country export, imports and possible country transit. The authority of the country of export shall forward the application and documents to the authorities of the country of import and the country of transit. The authorities of the importing country and the country of transit have 30 days to consent or refuse to consent to a shipment of waste. The authority responsible for issuing consents for waste shipments in Poland is Chief Inspector of Environmental Protection. In Germany, this will be the relevant office unit, usually the environmental department of the respective state.
4. Obtain authorisation for shipments of waste from the authorities of the importing and transit countries. 
5. Inform the carrier and the facility receiving the waste on the authorisation obtained.

Transport of waste between EU countries

1. Fill out transport form (Annex 1B) and give it to the transporter who will be responsible for the waste shipment.
2. Carry out the transport of waste in accordance with the procedure as specified in the permit obtained and in accordance with the regulations in force. 
3. The carrier shall provide transport document to the notifier and the authority of the country of import upon delivery of the waste to the receiving facility. 
4. The facility receiving the waste must provide the notifier with confirmation of receipt of waste (Annex 1C), which will provide evidence of the movement and transfer of the waste.

But it is not everything! 

Cross-border waste shipments and the procedure involved continue long after the shipment has reached its destination. As a notifier, you must additionally bear in mind at least two very important obligations. Firstly, withthe proclaimer must keep documents relating to the shipment of waste for at least three years.

In addition, pon the completion of the disposal or recovery of waste, the facility that accepts the waste should issue to the notifier certificate of disposal or recovery (Annex 1D). This document will confirm that the process has been carried out correctly. The pThe submission of a certificate of disposal or recovery, on the other hand, will enable the notifier to exemption from financial guarantee.

What about waste in the form of wind turbine blades? Cross-border waste shipments within the EU

It is also worth noting some additional pointswhich may affect the waste shipment process in the form of wind turbine blades across the border: 

1. Ensure shovels are properly secured and prepared for transport. They may need to be disassembled if their dimensions exceed those permitted for road transport. In this case, proper protection and packaging of the individual blade parts is key. 
2. Some countries may have their own regulations for the transport of abnormal loads, such as wind turbine blades. Before transporting, check local regulations for the transport of abnormal loadsas well as any size or weight restrictions. 
3. If you use different modes of transport (e.g. road, rail, sea), ensure that all carriers are registered in the relevant systems and comply with the regulations and requirements staged by different countries and modes of transport. 
4. Cooperate with customs officialsto meet any customs obligations that may be associated with the movement of waste across the border. In the case of wind turbine blades, it is worth checking whether they are exempt from customs duties. 
5. Keep detailed records all stages of movement wind turbine blades across the border to ensure compliance with regulations and to facilitate possible inspections.

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