Green-listing certain waste for the purposes of shipments to recovery between Member States

146 submissions in the snapshot (136 from organisations), portal total 146. Feedback list on the portal.

51 of 136 organisation submissions analysed; the model reads them as: opposes 2 supports 6 wants changes 41 2 held back for review (low confidence). 85 without readable text, so not analysed.

• Duesenfeld GmbH Company, DEU model reads as: supports source
  • Include metallic and polymer film fractions from battery recycling in the Green List.

    Die metallischen und polymeren Folienfraktionen aus dem Batterierecycling sollten aufgrund ihrer Stabilität, ihrer stofflichen Verwertbarkeit und ihres nicht gefährlichen Charakters in die Grüne Liste gemäß Verordnung (EU) 2024/1157 aufgenommen werden.

  • Harmonize classification of battery recycling fractions as non-hazardous Green List waste to facilitate cross-border shipment.

    Eine harmonisierte Einstufung dieser Fraktionen als Abfälle der grünen Liste würde die innergemeinschaftliche Verbringung zu spezialisierten Recyclinganlagen erleichtern, Rechtssicherheit schaffen und den Kreislauf strategisch wichtiger Metalle (Ni, Co, Cu, Al, Li) stärken.

• Fenix Metals Sp. z o.o. Business association, POL model reads as: wants changes source
  • Include six specified tin waste streams in Annexes IIIA or IIIB of Regulation 2024/1157 to enable shipment within the EU based on general information requirements.

    We request that the following waste be included in Annexes IIIA or IIIB of Regulation 2024/1157 on shipments, in order to enable their shipment within the European Union based on general information requirements:

  • Recognize that tin waste is non-hazardous under CLP regulations and should be treated consistently with similar waste from other metals already on the green-list.

    However, unlike similar waste from the production and processing of copper, zinc, tantalum, precious metals, steel and aluminium, this raw material has not been included in the green list, even though it does not constitute hazardous material under CLP regulations.

  • Eliminate unnecessary notification procedures and administrative burdens for tin waste trade within the EU.

    The lack of an appropriate code greatly hinders and sometimes even prevents the trade of this valuable raw material.

• Andrea Versteyl Rechtsanwälte PartG mbB Company, DEU model reads as: wants changes source
  • Allow bilateral agreements between Member States and EFTA members to regulate waste exports under amended Article 31(3).

    Um den aufgezeigten Konflikt zu Erwägungsgrund 11 und 21 der Verordnung aufzulösen, ist aber Art. 31 Abs. 3 der Verordnung wie folgt zu ändern: "(3) Die Mitgliedstaaten können die in Absatz 1 genannten bilateralen Abkommen auch zur Regelung der Ausfuhr von Abfällen gemäß Artikel 4 Absatz 3 Satz 1 mit Staaten schließen, die Mitglieder der Europäischen Freihandelsassoziation (EFTA) sind."

  • Prohibit only the export of mixed municipal waste for disposal, not for recovery, under amended Article 44(2)(f).

    Art. 44 Abs. 2 lit. f der Verordnung wäre daher wie folgt zu formulieren: "die Ausfuhr von Abfällen gemäß Artikel 4 Absatz 3 Satz 2 ist verboten;"

  • Consider geographic specifics and border regions, particularly with Switzerland, to avoid expanding the ecological footprint of waste contrary to proximity and material efficiency principles.

    Ein so interpretiertes absolutes Ausfuhrverbot würde verhindern, dass besonderen geografischen Besonderheiten im Grenzbereich, insbesondere zur Schweiz, Rechnung getragen werden kann, und dazu führen, dass sich der ökologische Fußabdruck des Abfalls vergrößert.

• EuroCommerce Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure the interpretation of textile waste in Annex III aligns with the current scope of EPR schemes under the revised Waste Framework Directive.

    Therefore, we call on the Commission to ensure that the interpretation of textile waste in Annex III (i.e. B3030) is aligned with the current scope of the EPR schemes under the revised WFD.

  • Add a specific footwear waste category to Annex III to allow mixtures of worn clothing and textile articles with waste footwear.

    In light of the above and the upcoming EPR requirements for textile and footwear products, which aim to ensure environmentally sound treatment, we call on the Commission to include a specific "footwear waste" category in Annex III.

  • Resolve the mismatch between Waste Framework Directive codes for wood-based materials and Waste Shipment Regulation classifications to enable circular use of wood waste.

    In practice, local authorities generally require notification where the waste contains any material other than solid wood. This significantly hinders the circular use of wood, as waste processors cannot technically separate solid wood from wood-based panels.

• Brother International Europe Company, SVK model reads as: wants changes source
  • Reclassify Y49 as green-listed waste for intra-EU shipments destined for recovery.

    Reclassify Y49 as green-listed waste for intra-EU shipments destined for recovery.

  • Include Y49 in Annex III to maintain the 20 kg exemption and allow continued operation of consumer takeback schemes.

    The solution is to include Y49 in Annex III, thereby maintaining the 20 kg exemption and allowing continued operation of consumer takeback schemes.

• Circ Company, FRA model reads as: wants changes source
  • Maintain and expand green-listing for textile waste, explicitly including sorted mixtures of textiles and ensuring streamlined intra-EU movement procedures.

    Maintain and expand green-listing for textile waste and feedstock: keep textile feedstock as non-hazardous and green-listed; explicitly include sorted mixtures of textiles; and ensure streamlined intra-EU and global movement procedures.

  • Establish clearer linkage between Waste Shipment Regulation and End-of-Waste Criteria for Textiles to recognize prepared, sorted textile feedstock as secondary raw materials.

    Align Waste Shipment Regulation (WSR) with End-of-Waste (EoW) Criteria for Textiles: establish clearer linkage between WSR and EoW frameworks to reflect the commercial and material reality of textile recycling feedstock and reduce administrative barriers across Member States and global markets.

  • Avoid rigid EU-wide sorting rules and instead require that sorted feedstock meets the specifications of the recycler it is sold to.

    Sorting requirements should remain recycler-specific: avoid rigid EU-wide sorting rules; instead, require that sorted feedstock meets the specifications of the recycler it is sold to.

• VinylPlus, the European PVC Value Chain sustainability commitment. Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Revise Technical Guidance on waste classification so that end-of-life articles are classified according to their actual risk profile at end of life, not solely on their chemical composition.

    Revising the Technical Guidance on the classification of waste so that end of life articles are classified according to their actual risk profile at end of life, not solely on their chemical composition.

  • Enable post-consumer PVC wastes prepared to specification or destined for recycling in Europe to be transported under lighter Annex III requirements, with clear legal definitions in EU law including Norway, the United Kingdom and Switzerland.

    Any post-consumer PVC wastes "prepared to specification" or "destined for recycling in Europe" can be transported under the lighter Annex III ("green-listed") requirements of the Waste Shipment Regulation. As part of this, define "prepared to specification" and "destined for recycling in Europe" in EU law, using criteria mirroring Article 6(1) of the Waste Framework Directive, to provide legal certainty and limit divergent national interpretations, and include Norway, the United Kingdom and Switzerland in the geographical scope of the definition.

  • Harmonize and digitalize waste shipment procedures across Member States through a single EU-wide electronic system with real-time tracking and harmonised data formats.

    Harmonization and digitalization of waste shipment procedures across Member States through a single EU-wide electronic system, with real-time tracking and harmonised data formats, to reduce delays, duplications and administrative costs.

• Environmental Investigation Agency on behalf of the Rethink Plastic alliance NGO, GBR; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • No waste type containing plastic should be green-listed due to documented environmental and human health impacts of plastic waste trade.

    The alliance considers that no waste type containing plastic should be green-listed, in view of the well evidenced impacts of plastic waste trade on the environment, human health and domestic recycling capacity.

  • The conditions are not met to green-list synthetic-based mixtures of clothing and footwear waste.

    because we consider that the conditions are not met to green-list mixtures of clothes and footwear waste.

  • Implementation should prioritize product and system redesign for non-toxicity and recyclability, along with improvements to waste collection and sorting infrastructure.

    It is our view that to genuinely boost the internal market for recycling while safeguarding ESM, implementation should prioritise product and system redesign for non-toxicity and recyclability, as well as waste collection and sorting improvement.

• Micro company, POL Business association, POL model reads as: supports source
  • Maintain the 10% contamination threshold requirement as it balances the needs of the entire supply chain from waste collectors through recycling facilities to glass product manufacturers.

    Wymaganie 10% zanieczyszczeń określone w specyfikacji, uwzględnia potrzeby całego łańcucha dostaw - od podmiotów zbierających odpady, przez sortownie i zakłady recyklingowe, aż po producentów wyrobów ze szkła.

  • Consider further standardization of measurement methods, including types of scales, minimum accuracy, and result reporting format to increase comparability of analyses between different recycling facilities.

    Jedynym obszarem, który można rozważyć w przyszłości, jest dodatkowe ujednolicenie metod pomiarowych (np. rodzaj stosowanych wag, minimalna dokładność, format raportowania wyników), co mogłoby jeszcze bardziej zwiększyć porównywalność analiz pomiędzy różnymi zakładami recyklingu.

  • Consider further development stages of the specification, such as precise criteria for color sorting.

    Warto rozważyć dalsze etapy rozwoju specyfikacji - np. doprecyzowanie kryteriów w zakresie sortowania na kolory

• Eurometaux Business association, BEL model reads as: wants changes source
  • Coordinate green-listing of waste under the Waste Shipments Regulation with the Critical Raw Materials Act to ensure harmonised definitions and facilitate smooth transport of waste.

    Coordinate green-listing of waste under the Waste Shipments Regulation (WSR) with the future implementing act under the Critical Raw Materials Act (Art. 26(7)) listing products, components and waste streams containing critical raw materials.

  • Maintain the green-listed regime for all intra-EU e-waste shipments beyond 01/01/2027 to avoid burdensome notification procedures.

    Maintain the intra-EU green-listed regime for all e-waste shipments beyond 01/01/2027 to strengthen the EU Critical Raw Materials and Circularity goals.

  • Abstain from establishing contamination thresholds for green-listed waste as they would be counterproductive and delay shipments of critical raw material-containing materials.

    Establishing concentration thresholds for green-listed waste would be counterproductive and would undermine the meaning of the Green List.

• TXO GmbH / TXO Group Company, DEU model reads as: opposes source
  • Maintain green-listed status for high-grade electronic waste fractions to avoid unnecessary restrictions and administrative burdens.

    Maintaining green-listed status for such waste fractions is therefore economically, environmentally, and strategically justified.

  • Allow free intra-EU shipment of high-grade electronic waste to the most efficient recovery facilities without prior informed consent procedures.

    Allowing free intra-EU shipment to the most efÏcient facilities maximises recovery, reduces waste generation, and ensures valuable materials remain within the EU value chain.

  • Ensure that high-grade electronic waste is routed to specialized precious-metal smelters for maximum recovery yields and prevention of strategic material loss.

    efÏcient recovery through specialised precious-metal smelters is essential to ensure maximum yields and to prevent the irreversible loss of strategic raw materials.

• EuPC : European Plastics Converters. EuPC is the leading EU-level Trade Association, based in Brussels, representing European Plastics Converters. EuPC now totals about 51 European Plastics Converting national and European industry associations, it repres Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Legally enforce mutual recognition for waste shipments complying with EU-wide contamination limits and prohibit national deviations from these standards.

    The CEA must legally enforce the principle of mutual recognition for waste shipments that comply with EU-wide contamination limits. National deviations must be prohibited.

  • Increase the maximum contamination level for plastic waste from 6% to 10%.

    Not only should these limits follow the EU maximum contamination, but should even be increased to 10% contamination.

  • Explicitly green list plastic waste containing classified additives encapsulated in the plastic matrix under Annex III of the regulation.

    Plastics waste containing specific classified additives encapsulated in the plastic matrix and intended for recycling in the EU should be green listed explicitly under the Annex III of the regulation indicating which classified additives are allowed to be included in the green listed waste.

• MM Metal Recycling B.V. Company, NLD model reads as: supports source
  • Expand green-listing for non-hazardous E-Scrap streams like circuit boards and metal assemblies under OECD codes to reduce notification delays.

    Expand Green-Listing for Non-Hazardous E-Scrap: Including specific E-Scrap streams (e.g., circuit boards, metal assemblies) under OECD Council Decision-green-list codes (GC010, GC020) would reduce notification delays, which can take weeks, hindering high-quality recycling.

  • Harmonize classifications across Member States with clear criteria aligned with Basel Convention entries for non-hazardous E-Waste.

    Harmonize Classifications: Differing Member State interpretations of "unlisted" waste create bottlenecks. Clear criteria, aligned with Basel Convention entries (Y49 for non-hazardous E-Waste), would ensure consistency.

  • Support pre-consented facilities certified for environmentally sound management with simplified procedures to address Europe's E-Scrap processing gap.

    Support Pre-Consented Facilities: Facilities like MMMR, certified for environmentally sound management, should benefit from simplified procedures to handle Europe's 77 kt E-Scrap processing gap (2025 estimate).

• I.BLU S.r.l. Company, ITA model reads as: wants changes source
  • Ease the shipment of mixed flexible plastic packaging waste within the EU when destined for recycling operations under the Green List regime.

    In order to do so, it should be easier to ship these streams when they are destined to recycling operations within the EU in the Green List regime.

  • Increase the contamination threshold for mixed plastic waste classified under EU3011, recognizing their higher natural variability compared to homo-polymer waste.

    Considering that mixed plastic waste streams have, by nature, higher variability rates than homo-polymer ones (e.g. PET bottles, HDPE containers), this threshold should be increased.

  • Revise the Waste Shipment Regulation Guidelines to implement less stringent and more realistic quality requirements for mixed plastic waste streams.

    Therefore, the next revision of the Correspondent Guidelines regarding the WSR should foresee less stringent limits to transport these streams, implementing more realistic quality requirements for these streams.

• Province of Noord-Holland Public authority, NLD model reads as: wants changes source
  • Prioritize extending product lifespan and preventing waste generation as a guiding principle of the Circular Economy Act.

    To become truly circular, we must above all, prioritize extending the lifespan of products and prevent waste from being generated in the first place.

  • Harmonize end-of-waste criteria for secondary feedstocks across the EU to streamline waste classification and facilitate cross-border transport.

    It's crucial to harmonize end-of-waste criteria for secondary feedstocks across the EU, providing that it is sufficiently safe and healthy, to streamline waste classification rules and to facilitate cross-border transport of secondary feedstocks.

  • Examine a coordinated EU approach for introducing fiscal measures and incentives that support the transition towards a circular economy.

    Therefore the Dutch provinces ask to examine a coordinated EU approach for introducing fiscal measures and incentives that support the transition towards a circular economy.

• MedTech Europe, the European association of medical technology manufacturers www.medtecheurope.org Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Uphold the green-list status for non-hazardous intra-EU e-waste shipments beyond 1 January 2027, including the exemption for shipments under 20kg.

    Therefore, we strongly urge the Commission to uphold the green-list status for non-hazardous intra-EU e-waste shipments beyond 1 January 2027, including the exemption for shipments under 20kg.

  • Establish contamination thresholds aligned with existing legal requirements to facilitate compliance for intra-EU shipments across all relevant frameworks.

    We recommend aligning all these frameworks to facilitate compliance for intra-EU shipments by, for example, establishing contamination thresholds aligned with the existing legal requirements under the other EU acquis.

  • Develop a harmonised waste classification framework across the EU to ensure consistent categorisation and facilitate cross-border transport.

    A harmonised classification framework should be developed to ensure consistent categorisation and facilitate transport to a common destination country.

• WindEurope Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Establish dedicated waste codes for composite material waste and permanent magnets in the European List of Waste.

    Establish dedicated waste codes for composite material waste coming from decommissioned wind turbine blades and boats and permanent magnets in the European List of Waste;

  • Introduce a Europe-wide landfill ban on composite material waste from decommissioned wind turbine blades and boats.

    Introduce a Europe-wide landfill ban on composite material waste coming from decommissioned wind turbine blades and boats;

  • Set progressive reuse and recycling targets for composite materials under the Waste Framework Directive.

    Set progressive reuse and recycling targets for composite materials under the Waste Framework Directive;

• Umicore Company, BEL; register: Companies & groups model reads as: wants changes source
  • Green-list specified waste codes containing critical raw materials including electronic waste when destined for EU-based pre-consented facilities.

    we recommend that the following waste codes be confirmed for an easier procedure as if they were green-listed (though some of these are already) when destined for final recovery at EU-based pre-consented facilities:

  • Prioritize the destination of waste shipments and pre-consented recovery facilities over waste composition in determining green-list eligibility.

    The EU should prioritize the destination of waste shipments-specifically pre-consented final recovery facilities for critical raw materials (CRMs)-rather than focusing solely on their exact composition.

  • Do not rigidly exclude hazardous waste from green-listing as restricting critical raw material shipments undermines EU's CRM strategy and circular economy goals.

    Restricting intra-EU shipments of these materials risks undermining the EU's CRM strategy and circular economy goals.

• IFP Energies nouvelles Academic or research institution, FRA; register: Think tanks and research institutions model reads as: wants changes source
  • Add materials prepared for advanced recycling (plastics, textiles, tires) to the green list to facilitate their circulation for recycling purposes.

    Nous proposons donc que soient inscrites dans la green list implicitement toutes les matières à recycler qui auront été préparées en amont du recyclage avancé à partir de la collecte de déchets non dangereux pour le recyclage des plastiques, des textiles et des pneus et élastomères usagés.

  • Establish reliable and controllable traceability mechanisms to track the origin of materials traveling under the green list regime at border crossings.

    Il est essentiel que l'origine de la matière à recycler qui voyage sous le régime de la green list soit tracée lors du passage des frontières et il faut s'assurer de la mise en place de dispositifs de traçabilité fiables et contrôlables.

  • Ensure that prepared materials for recycling can circulate freely between different European countries toward recycling installations.

    Pour favoriser la croissance du recyclage en Europe, il est indispensable que les matières préparées pour être recyclées puissent circuler facilement entre les différents pays Européens vers les installations de recyclage.

• European Tyre and Rubber Manufacturers' Association Business association, BEL model reads as: wants changes source
  • Ensure that tyre shreds can be exported within the EU under the green-list procedure to recycling or recovery installations, and that the same procedures for export to third countries also apply to shreds.

    ETRMA asks that measures are taken to ensure that: 1. Tyre shreds can be exported within the EU under the green-list procedure to recycling or recovery installations, and 2. The procedures for export of tyres to third countries would also apply to shreds.

  • Commission should decide that shreds of waste pneumatic tyres are equivalent to waste pneumatic tyres and that Basel code B3140 must be used for all shipments.

    ETRMA asks for a decision of the Commission that shreds of waste pneumatic tyres are equivalent to waste pneumatic tyres (i.e.: waste of pneumatic tyres) and Basel code B3140 must be used for shipments.

  • Harmonise export procedures throughout the EU by using one single classification and code for tyre shreds.

    ETRMA stresses that the only way to harmonise export procedures is using one classification, one code, that is now on the green list.

• EUROPUR Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure the caveat 'collected in a dry state' is added to any future annex IIIB entry to prevent transportation of contaminated mattresses unfit for recycling.

    We believe that only dry mattresses fit for dismantling should be allowed to be transported under the green listed waste shipment procedure. Hence, we would argue that the caveat ", collected in a dry state," should be added to any future entry in annex IIIB.

  • Apply OECD risk-based approach evaluation criteria, including assessment of contamination risks and contamination prevention measures, when developing the green listing entry.

    For similar considerations under the OECD Decision of the Council on the Control of Transboundary Movements of Wastes Destined for Recovery Operations there is an appendix 6 which lists some of the factors to be considered.

• Wirtschaftsvereinigung Metalle e.V. Business association, DEU; register: Trade and business associations model reads as: wants changes source
  • Do not establish contamination thresholds for waste shipment, maintaining visual inspection as the standard instead.

    Abstain from the establishment of contamination thresholds in waste shipment

• Derichebourg Environnement Company, FRA; register: Companies & groups model reads as: wants changes source
  • Simplify and digitalize administrative procedures for intra-EU shipments of recycled raw materials to strengthen the single market for secondary raw materials.

    Simplification and digitalisation of procedures for intra-EU shipments are essential to strengthen the single market for secondary raw materials.

  • Green-list demonstrably non-hazardous recycled metals whether shipped directly to final users or other treatment facilities.

    Demonstrably non-hazardous recycled metals should be green-listed, whether shipped directly to final users (steel, foundries, refineries) or other treatment facilities.

  • Streamline notification procedures by allowing group notifications, adding carriers during the process, tacit renewals based on compliance history, and applying the full validity period from the date of approval rather than application date.

    Notification procedures should be streamlined without reducing environmental safeguards: allowing group notifications, adding carriers during the process, tacit renewals based on compliance history, and ensuring that the full validity period applies from the date of approval by authorities (not from the date of application), so that operators are not penalised by administrative delays.

• ESPP European Sustainable Phosphorus Platform NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Include ashes, secondary fertiliser materials, bio-based streams, and nutrient-rich process streams in the Green Listing of harmonised waste classification

    For these reasons, 'Green LisƟng' of the following wastes would significantly facilitate nutrient recycling and the bioeconomy.

  • Make Green Listing conditional that the materials are destined for nutrient recovery

    In all cases, the 'Green LisƟng' should be condiƟonal that the materials are desƟned for nutrient recovery:

  • Apply science-based quality limits from EU Fertilising Products Regulation to ashes in the classification

    For coherence, we propose to use the science-based limits fixed in the EU FerƟlising Products RegulaƟon 2019/1009 (CMC13): C-org <3%/DM, PAH16 <6mg/kgDM, PCDD/F <20 ng/kgDM tox. eq.

• European Precious Metals Federation (EPMF) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Create a strong and efficient European single market for waste that facilitates waste shipments.

    Create a strong and efficient European single market for waste that facilitates waste shipments.

  • Make the Green-listed regime for intra-EU waste shipments permanent beyond 1 January 2027.

    Make the Green-listed regime for intra-EU waste shipments permanent beyond 1 January 2027.

  • Uphold a risk-based approach vs. a hazard-based approach for waste shipments.

    Uphold a risk-based approach vs. a hazard-based approach for waste shipments.

• Aurubis is a leading worldwide provider of non-ferrous metals. We process metal concentrates and diverse recycling raw materials, inlcuding e-waste. Aurubis is a global leader in copper recycling. Company, DEU; register: Companies & groups model reads as: wants changes source
  • Keep non-hazardous e-waste under simplified Annex VII information procedures with a dedicated waste code.

    Permanently keep non-hazardous e-waste under the Annex VII information procedure by introducing a dedicated waste code, ensuring these materials continue to move across the EU through a simplified process.

  • Maintain the current regime for green-listed e-waste shipments within the EU beyond 2027.

    Maintain the current regime for green-listed e-waste for intra-EU shipments beyond 01/01/2027.

  • Automatically recognize pre-consented recovery facilities and apply expedited notification procedures for shipments to these facilities.

    Automatically recognise pre-consented recovery facilities in all Member States and ensure that shipments to these facilities are managed via an expedited ('fast-track') notification procedure.

• Sandvik AB Company, SWE model reads as: wants changes source
  • Used cemented carbide tools must be classified as 'used tools' rather than 'waste' during collection and transport to collection points.

    Therefore, used cemented carbide tools must be classified first as "used tools" and not as "waste" during collection and transport to collection points.

  • Production residues from cemented carbide processing must be reclassified from 'amber-listed waste' to 'non scrap' and treated as secondary raw material.

    Such soft scrap, which is classified as "amber listed waste" today, shall therefore be reclassified as "non scrap". Finally, it should be treated as (secondary) raw material.

  • The European Union must take measures to prevent exports of tungsten-containing materials from the EU region.

    Furthermore, the European Union shall take appropriate measures to avoid outflow/exports of such material containing tungsten from the EU region.

• A.D.I.VALOR Company, FRA model reads as: wants changes source
  • Green-list non-hazardous agricultural plastic wastes falling under EWC code 02 01 041 that contain high levels of low-risk organic and mineral contamination.

    EPRO believe that non-hazardous agricultural plastic wastes, falling under EWC code 02 01 041, require specific consideration as levels of contamination are often high requiring classification as Y48, but environmental risks are low due to the nature of this contamination.

  • Provide special consideration for green-listing non-hazardous waste packaging plastics falling into EU48 category despite contamination levels above 6%.

    we would also ask that special consideration is given to non-hazardous waste packaging plastics that fall into category EU48 due the levels of contamination being above 6%.

  • Reduce notification cost burdens to prevent diversion of recyclable agricultural waste plastics toward incineration and landfill.

    The additional cost of the notification process is increasing the cost of recycling relative to incineration and landfill. This risks agricultural waste plastics suitable for recycling being diverted to treatment operations lower down the waste hierarchy.

• SolarPower Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Green-list solar PV panels under Basel code Y49 destined for recycling and recovery.

    SolarPower Europe urges the European Commission to green-list PV modules under Basel code Y49, destined for recycling and recovery.

  • Establish additional measures of standardisation within the Circular Economy Act and WEEE revision to create a level playing field for recyclers.

    To ensure that green-listing leads to genuinely improved environmental outcomes, the European Commission must accompany such efforts by additional measures under the Circular Economy Act and the revision of the WEEE Directive.

  • Green-list battery modules and their associated black mass due to their high critical raw material recovery potential.

    Another waste stream, which we strongly urge the European Commission to green-list are battery modules for battery energy storage systems and their associated black mass due to their high critical raw material (CRM) recovery potential.

• Recycling Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Simplify and digitalise procedures for intra-EU waste shipments to strengthen the single market for recycled materials.

    Simplification and digitalisation of procedures for intra-EU shipments are essential to strengthen the single market for recycled materials.

  • Extend the scope of green-listed waste to enable easier cross-border shipping of non-hazardous waste streams between EU Member States.

    There is a need to extend the scope of green-listed waste so that they are shipped more easily between EU Member States.

• Klaster Gospodarki Cyrkularnej i Recyklingu (Circular Economy and Recycling Cluster) Other, POL model reads as: wants changes source
• FEDERREC Trade union, FRA model reads as: wants changes source
  • Include depolluted and pretreated WEEE equipment and components on the green list for non-dangerous waste transfers.

    Les équipements et composants dépollués et prétraités (moteurs électriques, transformateurs, compresseurs, câbles, circuits imprimés, CPU, RAM, disques durs, gros appareils électroménagers, équipements informatiques, modules solaires sans tellurure de cadmium) sont non dangereux une fois traités conformément à l'annexe VII de la directive DEEE.

  • Base classification on existing regulatory frameworks (RoHS, REACH, CLP, WEEE Directive Annex VII) rather than creating new contamination criteria.

    Appuyez-vous sur les cadres réglementaires existants tels que RoHS, REACH, CLP et l'annexe VII de la directive DEEE pour définir et vérifier le statut non dangereux, plutôt que de créer de nouveaux critères de contamination.

• European Boating Industry Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Create dedicated waste codes for end-of-life composite material waste from decommissioned wind turbine rotor blades, nacelles, and boats.

    The cornerstone of these changes is to create dedicated waste codes for end-of-life composite material waste from decommissioned wind turbine rotor blades and nacelles, and boats (see Annex I).

  • Amend the Waste Framework Directive, Landfill Directive, and Waste Shipment Regulation based on new composite waste codes to foster circularity.

    Based on those waste codes subsequent additions to the Waste Framework Directive, Landfill Directive and Waste Shipment Regulation should be made to foster circularity in end-of-life composite materials.

  • Provide interim guidance to national authorities and waste management industry on which waste codes should be used for composite material transportation and intra-European shipments.

    In the meantime, we would appreciate if the European Commission could provide guidance to national authorities and waste management industry on which waste codes and waste shipment codes should be used for transportation and intra-European shipments of end-of-life composite materials from decommissioned wind turbine rotor blades and boats.

• AVR-Afvalverwerking B.V. Company, NLD; register: Companies & groups model reads as: wants changes source
  • Lower the scope of the proximity principle in the Waste Shipment Regulation and replace it with objective criteria including cost efficiency, emission savings, and recovered materials to determine waste streams.

    This essential element of the waste management chain needs to be incentivised in the Waste Shipment Regulation (WSR) by lowering the scope of the proximity principle, established in Art. 16 of the Waste Framework Directive.

  • Allow waste streams to be treated by the most sustainable and efficient option regardless of the country of origin of the waste type.

    Waste streams in the EU should allow treatment by the most sustainable and efficient option, regardless of the country of origin of the specific waste type.

  • Ensure waste streams are directed towards facilities with material recovery capabilities rather than simple disposal options like landfills.

    The internal market for waste needs to ensure that waste streams are directed towards facilities with such capabilities over the simple disposal of valuable resources.

• European Refurbishement Association (EUREFAS) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Establish end-of-waste criteria for UEEE to create regulatory certainty around shipment and prevent UEEE from being automatically classified as waste.

    Establishing end-of-waste criteria to create certainty around shipment

  • Classify UEEE as a high-value resource rather than an inherent waste stream to enable reuse and circular economy potential.

    Rather than being viewed as an inherent waste stream, UEEE must be classified as a high-value resource that holds potential for the circular economy.

  • Create specific and simplified shipment guidelines for intra-EU UEEE transport to reduce administrative burden and costs for businesses, particularly SMEs.

    EUREFAS proposes creating specific and simplified guidelines that reduce logistical friction and ensure that transport remains economically viable for businesses, particularly for SMEs.

• European Electronics Recyclers Association (EERA) Business association, NLD; register: Trade and business associations model reads as: wants changes source
  • Introduce stronger and harmonised monitoring at ports, customs, and distribution hubs with shared EU intelligence systems to track suspicious shipments.

    Stronger and harmonised monitoring at ports, customs, and distribution hubs is essential, alongside shared EU intelligence systems to track suspicious shipments and deter breaches.

  • Extend the scope of green-listed waste to allow easier shipment of e-waste between EU Member States.

    EERA strongly agrees that there is a need to extend the scope of green-listed waste so that they are shipped more easily between EU Member States

• Europabüros der bayerischen und baden-württembergischen Kommunen im Namen der bayerischen und baden-württembergischen kommunalen Spitzen- und Landesverbände Public authority, DEU model reads as: wants changes source
  • Implement a timely landfill ban on municipal waste as a priority climate measure within the new circular economy legislation for 2026.

    Im Kontext des von der EU-Kommission angekündigten neuen Gesetzes zur Kreislaufwirtschaft für 2026 fordern wir deshalb: "Low hanging fruits" wie Deponierungsverbot von Siedlungsabfällen nutzen

  • Ensure that all responsibility for waste collection and management of valuable waste materials remains with public authorities, not private companies.

    Die Zuständigkeit für sämtliche wertstoffhaltigen Abfälle muss bei den öffentlich-rechtlichen Entsorgungsträgern liegen dürfen.

  • Clarify in the Waste Framework Directive that producer responsibility refers only to financial responsibility, leaving operational collection decisions to member states.

    In der Abfallrahmenrichtlinie sollte vor diesem Hintergrund klargestellt werden, dass sich der Begriff "Herstellerverantwortung" europarechtlich lediglich auf die finanzielle Verantwortung beschränkt und den operativen Aspekt der Ausgestaltung der Mitgliedstaaten überantwortet.

• European Panel Federation Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Maintain robust controls on wood waste classification and procedures under the Waste Shipment Regulation.

    EPF firmly opposes any deregulation of the classification and control procedures currently applied to waste wood under the WSR.

  • Do not green-list additional categories of wood waste for transboundary shipments.

    EPF does not support the green-listing of additional categories of wood waste for transboundary shipments.

  • Preserve access to quality wood waste for compliant recyclers such as wood-based panel producers.

    EPF urges the Commission to prioritise a controlled framework that safeguards the access of compliant recyclers, such as wood-based panel producers, to quality wood waste.

• Renewi Company, NLD model reads as: wants changes source
  • Add residual streams from soil remediation to the green list in the inorganic B20** series with provisions ensuring they comply with environmental regulations in both sending and destination countries.

    We stellen daarom voor om een toevoeging in de groene lijst op te nemen, in de (anorganische) B20** reeks, met de volgende, of vergelijkbare, omschrijving: "Reststromen uit de reiniging van verontreinigde grond, die zowel in het land van verzending als het land van bestemming, volgens de daar geldende regelgeving, mogen worden toegepast als secundaire bouwstof."

  • Do not introduce specific maximum contamination concentration limits as part of green list criteria, as they are inappropriate and would create practical difficulties.

    Hoewel een duidelijk invulling van de voorwaarde uiteraard voor alle partijen wenselijk lijkt, is het vastleggen van maximaal toelaatbare concentraties van verontreiniging in het algemeen hiervoor geen geschikte methode.

  • Maintain Article 12 safeguards enabling sending countries to object to waste transport if lower environmental standards would be applied abroad than in the country of origin.

    Renewi vindt het behoud van deze mogelijkheid belangrijk, om te voorkomen dat haar verwerkingsinstallaties ongewenste concurrentie ondervinden van milieuhygiënisch niet-vergelijkbare buitenlandse verwerkers.

• PV CYCLE Other, BEL model reads as: wants changes source
  • Green-list PV panels destined for recycling to enable transnational shipment to specialized facilities operating at economies of scale.

    the Commission should green-list PV panels destined for recycling/recovery, enabling shipments to specialised, transnational facilities operating at economies of scale for strategic/critical raw-material recovery and supporting Circular Economy and WEEE objectives.

  • Establish a clear and consistent classification for PV waste across all Member States to avoid diverging interpretations.

    A clear and consistent classification is essential to avoid diverging national interpretations.

  • Base PV panel waste classification on scientific evidence and eliminate unjustified hazardous designations by Member States.

    Some Member States still label PV panels as hazardous without scientific basis, creating delays, higher costs, and legal uncertainty for operators.

• Micro company, POL Business association, POL model reads as: wants changes source
  • Abolish the notification procedure for non-hazardous waste and assign all non-hazardous waste streams to appropriate codes on the green list.

    All waste streams that are not classified as hazardous should be assigned to appropriate codes on the green list.

  • Introduce a semantic distinction between waste destined for disposal and secondary raw materials with economic value to better reflect their role in the circular economy.

    We see merit in introducing a semantic distinction between "waste destined for disposal" and "secondary raw materials with significant value and utility".

  • Translate vague announcements about facilitating waste shipments into clear, practical and operational legislative instruments.

    Announcements regarding "measures to facilitate shipments of waste" remain vague. They need to be translated into clear, practical and operational legislative instruments.

• Confindustria Business association, ITA; register: Trade and business associations model reads as: wants changes source
  • Green-list non-hazardous e-waste after January 1, 2027 for intra-EU shipments rather than subjecting them to prior informed consent procedures.

    Per le spedizioni all'interno dell'UE, riteniamo che i RAEE non pericolosi debbano continuare a essere inseriti nella "lista verde" anche dopo il 1° gennaio 2027.

  • Include specific non-hazardous e-waste categories (motherboards, electrical cables, mixed electronic equipment, solar panels, EV charging stations, and wind turbine blades) in green-listing provided they are properly selected and free of hazardous contaminants.

    Proponiamo di inserire nella "lista verde" le seguenti categorie di RAEE non pericolosi, a condizione che siano adeguatamente selezionati e privi di contaminanti pericolosi:

  • Avoid subjecting non-hazardous e-waste to complex procedures to prevent slowing recovery and reducing the risk of illegal disposal or export to countries with lower recycling standards.

    Sottoporre questi flussi non pericolosi a procedure complesse ne rallenterebbe il recupero e aumenterebbe il rischio che vengano inviati a Paesi con standard di riciclo inferiori o che vengano illegalmente smaltiti.

• EUROPEN - The European Organisation for Packaging and the Environment Business association, BEL; register: Trade and business associations model reads as: wants changes source
• Metlen Energy & Metals Company, GRC; register: Companies & groups model reads as: wants changes source
  • Amendments to the WSR should encourage greater processing of waste with high critical raw material recovery potential and ensure these materials are routed to appropriate recycling systems through harmonisation with the CRMA implementing act and REACH.

    Amendments to the WSR should encourage greater processing of waste with high critical raw material (CRM) recovery potential, such as aluminium scrap, and ensure these materials are routed to appropriate recycling systems.

  • Reduce administrative burdens and simplify industrial waste shipment procedures for the recovery of strategic metals including copper, aluminium, nickel, and cobalt.

    There is an urgent need to reduce administrative burdens for businesses, including simplifying industrial waste shipment procedures and accelerating EU-level processes for the recovery of strategic metals such as copper, aluminium, nickel, and cobalt.

  • Accelerate the development and implementation of a single digital system for waste documentation and transport monitoring with electronic submission and automatic approval within predefined deadlines.

    It is necessary to accelerate the development of the single digital system (single EU digital window) for document management and transport monitoring, with the capability for electronic submission and automatic approval within predefined deadlines.

• EPRO Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Extend the scope of green-listed waste to reduce notification requirements and costs for cross-border waste shipments within the EU.

    There is a need to extend the scope of green-listed waste so that they are shipped more easily between EU Member States.

  • Green-list non-hazardous agricultural plastic waste despite high contamination levels, as environmental risks are low due to the nature of the contamination.

    we believe that non-hazardous agricultural plastic wastes, falling under EWC code 02 01 04 (wastes from agriculture, horticulture, aquaculture, forestry, hunting, and fishing: waste plastics [except packaging]), require specific consideration as levels of contamination are often high requiring classification as Y48, but environmental risks are low due to the nature of this contamination.

  • Green-list non-hazardous waste packaging plastics with contamination above 6% to reduce regulatory and financial burdens on European recyclers.

    we would also ask that special consideration is given to non-hazardous waste packaging plastics that fall into category EU48 due the levels of contamination being above 6%.

• RetrouMatras BV. Company, NLD model reads as: supports source
  • Recognize that mattress recycling has significantly lower environmental impact than incineration.

    the recycling process of RetourMatras emits 12% of the CO2 equivalent emissions of the linear process when mattresses get incinerated directly.

  • Adopt EU-wide regulations prohibiting mattress incineration to promote circular economy transition.

    Since March 2021, the incineration of mattresses is prohibited in order to stimulate the transition to a circular economy.

  • Establish regulatory frameworks that enable recycling companies to expand and operate across EU member states.

    The ambition of RetourMatras is to expand their business to other countries. In order to promote positive environmental impact of their process, they seek to understand the CO2-footprint of their recycling process compared to the incineration of mattresses.

• Stichting Chemelot Business association, NLD; register: Companies & groups model reads as: supports source
  • Establish EU-wide mutual recognition for end-of-waste and by-product status so that materials achieving product status in one Member State are automatically valid across the EU.

    ensure that once a material achieves product status in one Member State, it is valid across the EU

  • Expand the Green List to include key circular feedstocks such as plastic fractions, pyrolysis oil, methanol, biomass residues, and recycled pellets.

    Expand the Green List to key non-hazardous secondary streams: o pre-sorted plastic fractions (e.g. HDPE & PP); o pyrolysis oil from mixed plastics ; o circular methanol from syngas or CO₂ + low-carbon H₂; o biomass residues (e.g. untreated wood chips & pesticide-free sawdust; o mechanically recycled plastic pellets and flakes.

  • Introduce harmonised, material-specific contamination thresholds that are subject to periodic review to reflect technological progress.

    Introduce harmonised contamination thresholds tailored to materials: o plastics: ≤ 5% non-polymer impurities. o pyrolysis oil: < 1% water/solids; < 0.1% chlorine. o circular methanol: < 0.5% water & particulates. o biomass residues: ≤ 5% non-biogenic content. o recycled pellets: ≤ 2% foreign polymers/additives. These thresholds should be subject to periodic (e.g. 5-year) review to reflect technological advances.

• AVR Afvalverwerking BV Consumer organisation, NLD model reads as: supports source
  • Recognize and support waste-to-value conversion technologies like CTC that produce saleable materials from waste.

    CTC technology therefore produces only saleable products from the sludge.

  • Enable harmonized classification that acknowledges waste-derived products with commercial value and end-of-waste status as viable materials for industrial application.

    The amount of ashes is a saleable end of waste product with EU status sold as a cement replacement or as a sorbent in the fluegas cleaning of waste incineration plants.

  • Facilitate the transition from waste disposal to waste valorization through harmonized classification that supports circular economy conversion processes.

    Using CTC technology, it is now possible to convert the paper sludge, into reactive minerals and thermal energy.

• FERVER aisbl - European Federation of Glass Recyclers (Fédération Européenne des Recycleurs de Verre) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Recognize that waste treatment of photovoltaic panels will be delayed for many years due to their extended product lifetimes and should be treated as a special case in waste classification systems.

    The long introduction aims to point out that waste treatment of PV Panels is an activity which will be delayed for many years due to the very long lifetime of these products.

  • Account for the reuse market potential of photovoltaic panels through revamping and repowering when developing waste classification and management frameworks.

    Revamping and Repowering also have as consequence that many good PV Panels will benefit from an extended lifetime because these PV Panels shall enter the reuse market based on qualitative parameters.

  • Consider product warranties and performance guarantees when determining appropriate waste classification timelines for photovoltaic panels.

    The PV Panels themselves receive from the manufacturer a ten (10) year product guarantee and a twenty (20) year performance guarantee.