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

110 submissions in the snapshot (106 from organisations), portal total 110. Feedback list on the portal.

106 of 106 organisation submissions analysed; the model reads them as: opposes 1 supports 29 wants changes 61 15 held back for review (low confidence).

• Micro company, BEL Business association, BEL model reads as: supports source
  • Include dry-collected, non-hazardous waste mattresses in Annex IIIB under entry BEU08.

    Valumat hereby wishes to formally express its support for the proposal to include dry-collected, non-hazardous waste mattresses destined for dismantling and recycling in Annex IIIB of the Waste Shipments Regulation (WSR) under the new entry BEU08.

• NEVEON Hungary Kft. Company, HUN model reads as: supports source
  • The Commission should finalize entry BEU08 for dry-collected waste mattresses as proposed.

    NEVEON requests that the Commission finalise the BEU08 entry as proposed.

• UAB Metralis Company, LTU model reads as: supports source
  • Green-list PCB and related e-waste fractions to facilitate transboundary movement to EU refiners and reduce administrative delays.

    Being able to deliver and sell green-listed waste: 1. Reduces capital intensity for recyclers (selling goods in a matter of days vs delays of weeks or months). 2. Reduces administrative load, both for the recyclers and the authorities.

• Micro company, DEU Company, DEU model reads as: wants changes source
  • Enable evidence requirements to be submitted in a structured, machine-readable format linked to the electronic submission system under Article 27.

    We recommend designing the evidence requirements so they can be met in a structured, machine-readable form (a common data schema for composition, origin and pre-treatment), explicitly linked to the electronic submission system foreseen under Article 27 of Regulation (EU) 2024/1157.

  • Reference defined sampling and testing procedures per waste stream and permit compliance through documented process control rather than per-consignment analysis.

    We recommend referencing a defined sampling and testing procedure per waste stream, and allowing compliance to be evidenced through documented process control (input control, sorting process, unbroken chain of custody) rather than only through per-consignment analysis, which is not economically viable for heterogeneous streams.

  • Recognise documented process origin combined with an unbroken chain of custody for permanent magnets and ELV metal fractions.

    We recommend recognising documented process origin combined with an unbroken chain of custody as adequate evidence.

• Recyc Matelas Europe Company, FRA model reads as: supports source
  • Classify mattresses under the Green List to facilitate a European recycling network and prevent landfilling or incineration.

    Classifying mattresses as Green List would facilitate the development of a European recycling network, in line with the Commission's objectives of reducing landfilling and incineration.

• Micro company, LTU Company, LTU model reads as: wants changes source
  • Ensure the act applies by 1 January 2027 or incorporate transitional provisions to prevent non-hazardous e-waste falling into Basel entry Y49 notification.

    We ask the Commission (a) to adopt early enough for entry into force before 31 December 2026 and to invite Parliament and the Council to use the early non-objection option in Article 80(6); (b) failing that, to add to Article 2 "It shall apply from 1 January 2027", justified in a recital: it lightens a burden and affects no legitimate expectation, and Delegated Regulation (EU) 2024/3229, published on 20 December 2024, applied from 1 January 2025 in the same way; (c) in any event, a transitional provision as in Article 2 of that Regulation: pending notifications for BEU09 waste may be withdrawn and the shipment made under Article 18; existing consents stay valid until expiry.

  • Update Correspondents' Guidelines No 1 to give non-hazardous board fractions a clear common evidentiary basis.

    We suggest (a) updating Correspondents' Guidelines No 1 (WEEE; review due since January 2025) in the waste shipment expert group, setting out the evidence a shipper holds for BEU09 fractions - permit of the dismantling site, completion of Annex VII selective treatment, representative sampling (EN 14899) with an HP assessment per Commission Notice 2018/C 124/01 and a PBDE result - and acceptance at destination of a documented classification by the Member State of dispatch; (b) in the medium term, a further delegated act under Article 29(6) for BEU09 fractions, as now proposed for glass waste (B2020).

  • Retain the second and third indents of entry BEU09 as currently drafted.

    Keep the second and third indents as drafted.

• DELACAMP Aktiengesellschaft - Convena Polymers Company, DEU model reads as: wants changes source
  • Introduce a new Annex IIIB entry BEU12 for clean, non-hazardous, source-separated post-industrial thermoplastic production waste destined for R3 recycling.

    Convena respectfully invites the Commission to introduce BEU12 for clean, non-hazardous, source-separated PIR thermoplastics destined for R3 recycling within the EU.

  • Ensure ETFE production waste is expressly covered by the new BEU12 entry.

    ETFE should therefore preferably be covered by BEU12, creating a technology-neutral framework for future high-performance thermoplastic recycling streams.

• FECC Business association, BEL; register: Trade and business associations model reads as: supports source
  • Adopt a risk-based, proportionate, and practical approach that reduces unnecessary administrative barriers for SMEs while maintaining environmental protection.

    Fecc focuses on the need for a risk-based, proportionate and practical approach that maintains a high level of environmental protection while reducing unnecessary administrative barriers, particularly for SMEs.

  • Provide clear EU-level guidance and proportionate contamination criteria.

    Fecc also highlights the importance of clear EU-level guidance, proportionate contamination criteria, consideration of the intended recovery operation and receiving facility, and a future-proof mechanism that can adapt to technological developments and new circular value chains.

• Aluminium Deutschland Business association, DEU model reads as: wants changes source
  • Delete the word 'minimal' from entry BEU07.

    In addition, “minimal” should be deleted.

    machine translation by the Commission, original in DE
  • Specify the requirement solely by 'the dominant fraction'.

    It is sufficient to specify by ‘the dominatnt fraction’.

    machine translation by the Commission, original in DE
• PV CYCLE Other, BEL; register: Trade and business associations model reads as: wants changes source
  • Include whole waste photovoltaic panels in the green list for shipments between Member States.

    PV CYCLE welcomes this revision of Regulation (EU) 2024/1157 but believes whole waste photovoltaic (PV) panels should also be green-listed for shipments between Member States.

  • Adopt Option 1 by introducing a stand-alone entry BEU12 in Annex IIIB (point 2) and amending EU49 in Annex IV.

    Option 1 - a stand-alone entry in Annex IIIB (point 2): BEU12 - Waste photovoltaic panels, provided they are destined for recycling. Under this option, EU49 in Annex IV should be amended to "not covered by A1181, BEU09 or BEU12".

  • Alternatively, adopt Option 2 by adding an entry for waste photovoltaic panels destined for recycling under BEU09.

    Option 2 - an additional dash under BEU09: waste photovoltaic panels, provided they are destined for recycling.

• European Boating Industry Business association, BEL; register: Trade and business associations model reads as: supports source
  • Retain the inclusion of composite material waste in Annex IIIB and ensure harmonised application across Member States.

    EBI therefore encourages the Commission to retain this provision in the final delegated act and to ensure its clear and harmonised application across all Member States.

  • Keep administrative requirements under the green control procedure clear and proportionate for SMEs.

    The administrative requirements associated with the green control procedure should remain clear and proportionate, particularly for SMEs.

  • Establish dedicated EU waste codes for end-of-life composite materials with distinct sub-codes for boats and other streams.

    Establish dedicated EU waste codes for end-of-life composite materials, with distinct sub-codes for boats and other major composite waste streams.

• Humana People to People NGO, ESP model reads as: wants changes source
  • Amend Annex IIIA of the WSR to include mixtures of textile waste classified under entry B3030 mixed with footwear, hats, belts, and other accessories.

    The European members of Humana People to People support amending Annex IIIA of the WSR to include "Mixtures of textile waste classified under entry B3030 and mixed with footwear, hats, belts and other accessories".

  • Extend the scope of the Annex IIIA amendment to include household textiles.

    We further note that the scope should be extended to include household textiles.

• European Heating Industry (EHI) Business association, BEL; register: Trade and business associations model reads as: supports source
  • Address wider administrative barriers and harmonize Extended Producer Responsibility requirements in the upcoming Circular Economy Act.

    In this regard, EHI encourages the Commission to use the upcoming Circular Economy Act to address these wider barriers and provide greater harmonisation and legal certainty across the EU.

• WindEurope Business association, BEL; register: Trade and business associations model reads as: supports source
  • Continue pursuing Basel Convention alignment for composite material waste in parallel with EU action.

    We encourage the European Commission to continue pursuing Basel Convention alignment for composite material waste in parallel with EU action.

• European Aluminium Business association, BEL; register: Trade unions and professional associations model reads as: supports source
  • Maintain the addition of Green List code BEU07 for aluminium scrap from construction and demolition activities.

    European Aluminium welcomes the addition of new Green List codes for scrap from windows, doors, curtain walls, framing profiles, and other aluminium elements from waste from building, construction and demolition activities.

• Micro company, ITA Business association, ITA model reads as: wants changes source
  • Align the maximum foreign fraction threshold for glass packaging waste with stricter Italian national criteria.

    We therefore request that the EU threshold be aligned with these more stringent parameters.

    machine translation by the Commission, original in IT
  • Include glass yarns and fibres under CN code 7019 within the green list entry codes.

    We strongly urge the inclusion of glass yarns and Fibers (falling under CN code 7019) into the “green list” entry codes.

    machine translation by the Commission, original in IT
• MagREEsource Company, FRA model reads as: wants changes source
  • Expand the proposed BEU10 entry to cover medical devices, drones, robotic equipment, and fixation magnets.

    We therefore recommend adding the following categories to the list covered by BEU10: medical devices; drones and robotic equipment; and magnetic fixing and mounting systems ("fixation magnets").

  • Clarify the scope of permanent magnets by restricting it to rare earth permanent magnets.

    In particular, we suggest that the scope should be limited to rare earth permanent magnets.

  • Establish a dedicated waste entry for components containing rare earth permanent magnets.

    We therefore recommend the creation of a specific waste code/entry, included within the same relevant list, for components containing rare earth permanent magnets originating from the product streams identified above.

• Covestro Company, DEU; register: Companies & groups model reads as: wants changes source
  • Finalise the inclusion of dry-collected waste mattresses as entry BEU08 in Annex IIIB as proposed.

    Covestro urges the Commission to finalise entry BEU08 as proposed.

  • Amend proposed entry BEU07 to incorporate rigid polyurethane foam insulation.

    Covestro therefore proposes that entry BEU07 be amended to include "polyurethane".

• European Remanufacturing Council Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Explicitly add printer cartridges to the text of entry BEU 09.

    As the existing market for returned cartridges is well established across the EU, to further reduce the risk of different interpretations by authorities, it would be helpful to add the following words: such as printed circuit boards and printer cartridges

  • Clarify how companies should practically demonstrate the absence of hazardous properties under Annex III of the Waste Framework Directive.

    Secondly, BEU 09 requires the cartridges to be clear of any hazardous properties under Annex III of the Waste Framework Directive, but it does not explain how companies should prove this in practice. A minor clarification on the type of evidence would therefore be helpful.

• CLIC Innovation Ltd / REMHub Other, FIN model reads as: wants changes source
  • Provide clearer guidance on the regulatory boundary between BEU09 and BEU10 so separated magnets remain distinct.

    REMHub also recommends clearer guidance on the relationship between BEU09 and BEU10.

  • Establish a framework facilitating traceability and monitoring of rare earth material flows.

    The implementation framework should therefore facilitate monitoring of material origin, destination, quantities and recovery routes while avoiding unnecessary administrative burden.

  • Issue harmonised technical guidance regarding contamination limits, assemblies, documentation, and eligibility criteria for BEU10.

    Finally, REMHub recommends the development of harmonised technical guidance covering contamination limits, attached materials, magnet-containing assemblies, documentation requirements and eligibility criteria for BEU10 shipments.

• Dansk Autogenbrug Business association, DNK; register: Trade and business associations model reads as: supports source
  • Allow actors across Member States to exchange materials within environmental and fairness boundaries to support circular technologies.

    Therefore, it is absolutely crucial that actors in the different Member States are given the opportunity within the bounds of fairness and responsibility to the environment to exchange materials for the development of new technologies; a need that is also pointed out in other parts of EU legislation.

• European Precious Metals Federation Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Provide clear EU-level guidance to distinguish BEU09 from EU49 and A1181 and clarify qualifying conditions.

    However, clear EU-level guidance is needed to distinguish BEU09 from EU49 and A1181 and clarify when WEEE, components and processing fractions qualify.

  • Streamline intra-EU shipments of all WEEE, including hazardous waste streams, based on a risk-based approach.

    While this is an important first step, the EPMF calls for streamlined intra-EU shipments of all WEEE, including hazardous streams.

  • Use the upcoming Circular Economy Act to simplify procedures for shipments to pre-consented facilities capable of environmentally sound recovery.

    The upcoming Circular Economy Act (CEA) should be used to further facilitate intra-EU WEEE shipments and strengthen the European single market for waste.

• Micro company, NOR Company, NOR model reads as: wants changes source
  • Clarify the scope of other accessories and confirm whether bags and handbags are covered.

    In particular, we request that the Commission clarify whether bags and handbags are intended to be covered by this category.

  • Clarify that containing a limited proportion of damaged items does not exclude shipments from the green list.

    We therefore believe that it should be clarified that the presence of a limited proportion of damaged items does not in itself cause a shipment to fall outside the scope of the green list or become subject to more stringent procedures.

  • Ensure consistent interpretation and enforcement across the EU/EEA with clear definitions and guidance.

    Clear definitions and practical guidance will enhance predictability, reduce the risk of divergent practices between Member States, and ensure that equivalent shipments are treated consistently regardless of the border that is crossed.

• European Branded Clothing Association Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Include footwear in Annex IIIB.

    1. Include footwear in Annex IIIB.

  • Align definitions between the Waste Framework Directive and the Waste Shipment Regulation.

    2. Align the definitions of the Waste Framework Directive and the Waste Shipment Regulation.

  • Clarify the definition of textile waste prepared to a specification under code B3030 and the notion of destined for recycling within the Union.

    3. Clarify the definition of textile waste prepared to a specification under code B3030 of the Basel Convention 4. Clarify the notion of destined for recycling within the Union.

• Policy Hub - Circularity for Apparel and Footwear Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Establish harmonised EU criteria and contamination thresholds for classifying B3030 textile waste and the new textile/footwear mixture.

    In particular, we call for harmonised EU criteria for classifying B3030 textile waste and the new textile/footwear mixture, including contamination thresholds and assessment methods; clarification of what prepared to a specification means in practice; confirmation that shipments via interim recovery operations such as R12/R13 remain eligible where the waste is ultimately recycled within the EU; and greater clarity on the waste entries and product categories covered by footwear, hats, belts and other accessories.

  • Clarify rules regarding equivalent shipments outside the EU, including to OECD countries and authorisations for non-OECD countries.

    We also ask the Commission to clarify the treatment of equivalent shipments outside the EU, including to OECD countries and in relation to non-OECD country authorisations.

• Cefic Business association, BEL; register: Trade and business associations model reads as: supports source
  • Adopt the proposed inclusion of non-hazardous fibre-reinforced polymer composite waste under Annex IIIB entry BEU06 substantially as drafted.

    UP/VE and Epoxy Europe therefore strongly support the proposed inclusion of BEU06 and recommend that the Commission adopt the new entry substantially as drafted.

• Micro company, MLT Environmental organisation, MLT model reads as: wants changes source
  • Broaden the controlled application of Article 18 to include additional packaging mixtures and multi-material streams.

    GreenPak advocates for a broader but clearly controlled application of Article 18, particularly for: additional mixtures of non-hazardous recyclable packaging materials that are not currently covered by Annex IIIA; additional composite, multilayer and multi-material packaging streams for which established recycling/recovery solutions exist; clear and harmonised EU contamination thresholds and quality criteria to provide greater certainty as to when Article 18 can be used; and greater recognition of the technical capabilities of authorised receiving facilities when determining whether a waste mixture can be environmentally soundly recovered.

• FEVE - The European Container Glass Federation Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should clarify what materials or fractions constitute contamination with other types of wastes for calculating the 10% threshold.

    In particular, it should be clarified which materials or fractions are to be counted towards the 10% threshold.

  • The Commission should establish a common methodology and verification approach for determining compliance with the 10% contamination threshold.

    Without sufficient clarity regarding measurement and verification, there is a risk that methodologies and enforcement practices could differ between Member States, undermining the harmonisation objective of the Delegated Regulation.

• TechProtect GmbH Company, DEU model reads as: wants changes source
  • Explicitly cover separately collected intact used toner and inkjet cartridges intended for material recycling under BEU09 in Annex IIIB.

    In our role coordinating take-back programmes for OEMs, we ask the Commission to expressly address separately collected, intact, non-hazardous used toner and inkjet cartridges containing only residual ink or toner and intended for material recycling, including cartridges incorporating chips or electrical contacts.

  • Clarify which treatment steps are required prior to shipment under entry BEU09.

    In particular, the Commission should clarify which treatment steps, if any, are required before shipment.

  • Permit direct shipments of qualifying cartridges to authorised recycling facilities without prior dismantling.

    Where necessary, we ask the Commission to adapt the proposed wording to permit direct shipments of qualifying cartridges to facilities authorised to recycle them without prior dismantling, provided that their composition and condition allow safe shipment and environmentally sound treatment at destination.

• FERVER Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Differentiate between connected and non-connected contaminants and exclude connected contaminants from the 10% threshold calculation.

    Connected contaminants should not be counted toward the 10% contamination threshold.

  • Set a 15% non-connected contamination threshold for comingled glass waste from sorting facilities under EU code 19.12.05.

    3. Glass from Sorting Installations (MRF) - For waste from comingled collection classified under EU code 19.12.05 and shipped by Material Recovery Facilities (MRF): 15% non-connected contamination threshold.

  • Establish a 10% non-connected contamination threshold for photovoltaic panel glass excluding connected contaminants.

    4. Photovoltaic (PV) Panels - 10% non-connected contamination threshold, excluding connected contaminants, e.g. aluminum frames, cables, junction foil, wires, silicon, polymer backsheet.

• TMResponsibility AB Company, SWE model reads as: wants changes source
  • Introduce a new Annex IIIB entry green-listing household source-sorted plastic packaging waste destined for recycling under defined contamination limits.

    We propose that the Commission introduce a new entry, comparable to the entries recently added to Annex IIIB (BEU06BEU11), green-listing source-sorted plastic packaging waste (EWC 15 01 02) destined for recycling, provided that the waste contains no hazardous constituents and that the level of contamination with other materials does not exceed a defined threshold analogous to the 10% contamination threshold proposed for glass waste (B2020) in the parallel draft delegated act (Ares(2026)7981401, Part 2/2).

• Micro company, POL Business association, POL model reads as: supports source
• Groupe SEB Company, FRA; register: Companies & groups model reads as: wants changes source
  • Add a specific entry to Annex IIIB for separately collected non-hazardous end-of-life cookware consisting mainly of aluminium or steel destined for recycling.

    Groupe SEB therefore calls on the Commission to add a specific entry to Annex IIIB covering separately collected, non-hazardous end-of-life cookware consisting mainly of aluminium or steel, provided that the metal remains the dominant recoverable fraction and that the waste is destined for recycling.

• International Copper Association Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Expand the scope of BEU07 to explicitly include additional non-hazardous metal waste streams from construction and demolition activities, including copper pipes and cables.

    Expand the scope of BEU07 to explicitly include additional non-hazardous metal waste streams from building, construction and demolition activities, including copper pipes and cables.

  • Provide illustrative and non-exhaustive examples of the waste streams and fractions that fall within BEU09.

    Provide illustrative and non-exhaustive examples of the waste streams and fractions that may fall within BEU09.

  • Clarify the scope and practical application of EU49 regarding when e-waste is considered not to have undergone proper treatment.

    Clarify the scope and practical application of EU49, particularly the circumstances in which e-waste is considered not to have undergone proper treatment.

• VinylPlus Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Remove PVC from the fluorinated polymers paragraph and list it separately under EU3011.

    Remove PVC from the paragraph "Plastic waste almost exclusively(6) consisting of one of the following fluorinated polymers(7)" and list PVC separately under EU3011.

  • Ensure footnote 7 of the 2024 WSR does not apply to PVC wastes so post-consumer PVC is not excluded solely by origin.

    Ensure that footnote 7 of the 2024 WSR does not apply to PVC wastes, so that post-consumer PVC is not excluded solely because of its origin.

• Circulose AB Company, SWE; register: Companies & groups model reads as: wants changes source
  • Do not proceed with green-listing mixed textile waste without anchoring eligibility to robust sorting and pre-treatment standards at the point of origin.

    Nevertheless, it is important to highlight that the proposed green-listing of mixed waste clothing, footwear and textile waste should not proceed without first anchoring eligibility to robust, verifiable sorting and pre-treatment standards at the point of origin.

  • Ensure the Waste Shipment Regulation aligns with End-of-Waste criteria and the Circular Economy Act.

    Circulose therefore encourages the Commission to ensure the alignment of the WSR with other relevant EU legislation, such as the End-of-Waste criteria and the upcoming Circular Economy Act, both in terms of legislative coherence and objective alignment.

• RWE AG Company, DEU; register: Companies & groups model reads as: wants changes source
  • Retain the proposed green-listing of fibre-reinforced composite material waste, including wind turbine blades.

    retain the proposed green-listing of fibre-reinforced composite material waste, including wind turbine blades;

  • Retain the proposed green-listing of permanent magnets.

    retain the proposed green-listing of permanent magnets;

  • Add whole, untreated, non-hazardous end-of-life solar PV modules to the green list.

    add whole, untreated, non-hazardous end-of-life solar PV modules to the green list.

• Glass for Europe Business association, BEL; register: Trade and business associations model reads as: supports source
  • Ensure a harmonised interpretation and application of the rules across all Member States.

    As the new framework is implemented, it will be important to ensure a harmonised interpretation and application of the rules across all Member States, avoiding unnecessary administrative barriers and facilitating the smooth movement of materials for recycling.

• Micro company, POL Business association, POL model reads as: wants changes source
  • Supplement Annex IIIB with a dedicated entry for specific non-hazardous metal wastes that do not strictly meet the clean scrap criterion.

    At the same time, the Association advocates for supplementing Annex IIIB with a separate entry covering specific metal waste streamsparticularly waste containing tin and tin-bearing materials, as well as waste falling under entries B1010 and B1020that do not strictly meet the criterion of ‘clean, uncontaminated metal scrap,’ despite being non-hazardous waste and consisting of metals intended for recycling.

    machine translation by the Commission, original in PL
  • Adopt a measurable limit of 10 percent of shipment mass for associated materials covering non-metallic components.

    The Association proposes Utilising the mechanism set out in Article 79(4) of the WSR and adoptingfollowing the model of solutions proposed by the Commission for entries BEU07 and BEU11a measurable limit of 10 % of the shipment mass for associated materials.

    machine translation by the Commission, original in PL
  • Condition the simplified regime on three specific criteria including a 10 percent cap on associated materials, non-hazardous properties, and recycling within the EU.

    Application of the simplified regime should be conditional upon meeting three requirements: associated materials do not exceed 10 % of the shipment’s mass, the waste does not exhibit hazardous properties, and it is destined for recycling at an Authorised facility within the EU.

    machine translation by the Commission, original in PL
• Micro company, POL Business association, POL model reads as: wants changes source
  • Add a new Annex IIIB entry for non-hazardous metal waste such as tin-bearing materials or certain B1020 alloys with a 10 percent ceiling for accompanying materials.

    1. New Annex IIIB entry (Article 79(4)) for non-hazardous waste destined for recycling consisting mainly of (a) metallic materials, including tin-bearing materials, not otherwise covered by B1010, including recoverable fractions containing tin(IV) oxide, or (b) metals or alloys referred to in B1020 but not covered by that entry because limited quantities of other materials prevent them from meeting the clean, uncontaminated metal scrap criterion with a built-in ceiling of 10 % by weight for accompanying materials (sections 3 and 5).

  • Define a 10 percent quantitative threshold for accompanying materials under Article 29(6) for entries B1010, B1020, BEU07, and BEU11.

    2. Quantitative criterion (Article 29(6)): in the parallel act, define the permissible fraction of accompanying materials for B1010 and B1020 and give minimal amounts in BEU07 and BEU11 the same quantitative content of 10 % by weight (section 4).

  • Clarify that alloying constituents do not count as accompanying materials and determine compliance per consignment.

    3. Alloying constituents and determination: alloying constituents forming part of the metal fraction are not accompanying materials; compliance is determined per consignment on a representative basis and documented in the Annex VII information (section 4).

• ESPP - European Sustainable Phosphorus Platform NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: wants changes source
  • Assess secondary nutrient, bioeconomy, and organic streams in detail for inclusion on the green list.

    Green Listing of secondary nutrient, bioeconomy and organic streams should be assessed in detail for relevant waste materials, in order to establish clear definitions, contaminant limits and other safety conditions, Waste Classes and other conditions for eligible materials, and to then assess tonnages, recycling potential and relevance of waste trade and related regulatory obstacles for each type of material.

  • Include submitted nutrient-rich materials into a future amendment of the Green Listing Regulation.

    We hope that these materials will be assessed in detail by the Commission (we are ready to provide input to such an assessment) and that they can then be appropriately included into a future Green Listing Regulation amendment, alongside measures to support nutrient circularity and address regulatory obstacles in the upcoming Circular Economy and BioTech Acts.

• Asociación Retail Textil España (ARTE) Business association, ESP; register: Trade and business associations model reads as: wants changes source
  • Include separated footwear waste as a standalone entry in Annex IIIB.

    We therefore request its explicit inclusion in Annex IIIB, so that Annex IIIA covers mixtures while Annex IIIB covers footwear once separated.

  • Clarify that the proposed Annex IIIA entry covers home textiles in addition to clothing.

    To avoid ambiguity and the need for additional sorting, we propose rewording the entry to refer to the categories listed in Annex IVc of Directive 2008/98/EC; alternatively, we request an explicit clarification that B3030 includes apparel and home textiles.

• EPRO Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Include agricultural plastics in Annex IIIB for intra-Union waste shipments.

    2.We call for the inclusion of agricultural plastics included in Annex IIIB. This should be limited to waste shipments within the Union.

• Federation of the European Sporting Goods Industry (FESI) Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Create a standalone green-list route specifically for footwear waste.

    However, footwear also needs a standalone green-list route that reflects its inherently multi-material composition.

• Vattenfall Company, SWE; register: Companies & groups model reads as: wants changes source
  • Simplify and harmonise notification and permitting requirements at the EU level for materials destined for recovery.

    Simplifying and harmonising notification and permitting requirements associated with materials intended for recovery at EU level is therefore essential.

  • Amend entry BEU06 to explicitly cover preparation for re-use alongside recycling.

    Therefore, we propose the following addition under BEU06: BEU06 Non-hazardous waste composed of fibre-reinforced polymer composites, such as glass fibre embedded in polymer resins, which may also include coatings, adhesives and core materials, provided that it is destined for recycling or preparing for re-use.

  • Clarify that blade components like lightning-protection conductors, steel root fixings, and carbon fibre are covered under the draft Delegated Act.

    We note that blades incorporate lightning-protection conductors and steel root fixings that fall outside the coatings, adhesives and core materials currently permitted. Also, carbon fibre reinforcement should be understood as covered by the draft DA.

• Wirtschaftskammer Österreich Business association, AUT; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Include copper-containing waste under entry BEU07.

    However, copper-containing waste should also be included in this group, as copper is classified as a strategic raw material.

    machine translation by the Commission, original in DE
  • Explicitly clarify that untreated non-hazardous photovoltaic modules can be classified under BEU09 and green-listed.

    It must be made clear that these expanded and untreated non-hazardous photovoltaic panels are to be classified under BEU9 and can continue to be shipped within Europe as a green list of waste. A 4th Paragraph explicitly mentioning these untreated, non-hazardous photovoltaic modules.

    machine translation by the Commission, original in DE
  • Distinguish between bound and unbound pollutants in glass waste regarding contamination thresholds.

    B2020 Glass waste here a distinction should be made between bound and unbound pollutants. For components that are firmly bound in the glass for product-related reasons, either a higher contamination threshold should be allowed or the bound pollutants should not be included in the 10 % threshold.

    machine translation by the Commission, original in DE
• Plastics Europe Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Extend green-listing to plastic packaging waste.

    1) Plastic packaging waste. Green-listing of this waste stream is essential, as meeting the EUs circularity targets under the PPWR requires a recycling industry that is robust, efficient, and scalable.

  • Include the non-hazardous polyamide fraction from automotive shredder residue as a separate green-listed entry.

    The non-hazardous PA fraction obtained from sorting ASR should therefore be included as a separate entry in Annex IIIA (4) and green-listed.

  • Establish a dynamic, regularly updated green list alongside a streamlined procedure for remaining notified plastics.

    To reflect this progress, green-listing should be supported by a dynamic and regularly updated list, based on a technology-neutral mechanism and transparent criteria.

• Recycling Europe Business association, BEL model reads as: supports source
  • Provide legal certainty and consistent implementation for the green-listing initiative.

    The document also includes a joint statement, co-signed by several European industry associations, supporting the Green-Listing Initiative and calling for greater legal certainty and consistent implementation.

• Rethink Plastic Alliance NGO, BEL; register: Non-governmental organisations, platforms and networks and similar model reads as: opposes source
  • Reassess the draft Delegated Acts before adoption to prevent regulatory loopholes and policy incoherence.

    RPA therefore urges the Commission to reassess the draft Delegated Acts before adoption, ensuring that reduced shipment controls are introduced only where environmentally sound waste management can be demonstrated across the Union and where they enable EU circular economy objectives rather than undermining them.

• SolarPower Europe NGO, BEL; register: Trade and business associations model reads as: wants changes source
  • Explicitly green-list waste solar PV panels through a dedicated entry or separate code.

    Explicitly green-list waste solar PV panels for the purpose of shipment for recovery and recycling between Member States This should be done through a dedicated entry in the Waste Shipment Regulation or separate waste code

• EURATEX Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should confirm the minimum preparation and screening required prior to shipment and clarify the B3030 specification condition.

    We invite the Commission to confirm the minimum preparation and screening required prior to shipment, whether documented acceptance criteria of the receiving recovery facility may constitute the relevant specification, and how other accessories should be interpreted

  • The Commission should clarify that the proposed entry covers separately collected textile waste streams containing products within textile EPR scope without requiring prior sorting.

    we invite the Commission to clarify that the proposed entry is intended to cover separately collected textile waste streams containing products within the relevant textile EPR scope, including home textiles and relevant footwear and accessories, rather than requiring these products to be separately sorted before shipment.

  • Specific wording should be adopted for entry (d) to explicitly include apparel, home textiles, footwear, and accessories.

    For this later purpose we propose the following wording: (d) mixtures of wastes classified under entry B3030 (including apparel and home textiles) and footwear, hats, belts or other accessories.

• European Resilient Flooring Manufacturers' Institute, ERFMI Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The Commission should provide guidance on additional evidence required to include post-consumer PVC flooring waste within Annex IIIB.

    ERFMI would welcome guidance from the Commission on any additional evidence required to enable the future inclusion of this clearly defined waste stream within Annex IIIB.

  • The Commission services should meet with ERFMI to discuss requirements for including this waste stream.

    We would also welcome the opportunity to discuss these requirements with the relevant Commission services.

• European Refurbishment Association Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • The scope of green-listed devices should be expanded to explicitly include used electronics destined for preparation for reuse, sorting, testing, repair, or refurbishment.

    EUREFAS urges the Commission to align the revision with the Waste treatment hierarchy and Circular economy objectives by expanding the scope of green-listed devices to explicitly include used electronics headed to qualified facilities for preparation for reuse, sorting, testing, repair, or refurbishment.

  • Discarded electronic devices should be systematically assessed at collection points for reuse qualification before receiving any waste designation.

    Discarded devices should be systematically assessed at collection points to qualify them for reuse before any waste designation is applied.

  • The Commission should amend code entries in the annexes to protect the European refurbishment sector and strategic resources.

    EUREFAS calls on the Commission to amend code entries of WSR Annexes to safeguard the European refurbishment sector and preserve strategic resources within the Single Market.

• TechFab Europe Business association, DEU; register: Trade unions and professional associations model reads as: wants changes source
  • Retain the Article 18 general information requirements for qualifying shipments under entry BEU06 and ensure consistent EU-wide implementation.

    We support applying Article 18 general information requirements to qualifying shipments, while maintaining traceability and environmental safeguards. The Commission should retain this provision and ensure consistent implementation across Member States.

  • Broaden the illustrative reference to reinforcement fibres to include combinations of fibres while keeping the non-hazardous requirement.

    As a minor clarification, TECH-FAB Europe suggests broadening the illustrative reference to reinforcement fibres to read such as glass fibres, carbon fibres, aramid fibres and natural fibres, including combinations thereof, while retaining the requirement that composite waste be non-hazardous.

  • Adopt a technology-neutral approach supporting multiple recycling methods and recognise the contribution of mineral fractions in cement co-processing.

    We also encourage a technology-neutral approach supporting suitable mechanical, chemical and thermal recycling processes, and recognition of the recycling contribution of the mineral fraction in cement co-processing, in accordance with the waste hierarchy and environmental requirements.

• ETIRA Business association, BEL; register: Trade and business associations model reads as: wants changes source
  • Ensure all used cartridges classify as components under the second indent of BEU09 across all Member States if GC020 is deleted.

    For the draft Act under this consultation, ETIRA insists that in case of deletion of GC020, all used cartridges (toner and ink) will classify as components as defined in the second indent of BEU09: Waste components of electrical and electronic equipment. This classification must apply to all shipments containing different brands and models and must be interpreted and enforced identically across all Member States.

  • Green-list fully controlled and traceable collection streams of used cartridges between registered professional operators.

    Given the generally low environmental risks and hazards of used / empty cartridges, we call upon the EU to examine (like the proposal for mixed glass loads), the green-listing of fully controlled and traceable collection waste streams that meet defined packaging, documentation and acceptance requirements, conducted between registered professional operators.

  • Remove the requirement to submit the Annex VII form at least two working days prior to shipment under Article 18 WSR.

    As also mentioned by many other stakeholders, the compulsory requirement to submit the Annex VII form at least two working days before shipment (Article 18 WSR) is unfit for purpose and not necessary.

• EuCIA Business association, FRA; register: Trade and business associations model reads as: wants changes source
  • Maintain the application of Article 18 general information requirements to qualifying shipments in the final act.

    EuCIA supports applying the general information requirements of Article 18 to qualifying shipments, while maintaining traceability and environmental safeguards. We encourage the Commission to retain this provision in the final act and ensure consistent implementation throughout the EU.

  • Broaden the illustrative reference to reinforcement fibres to better reflect industry use while keeping the non-hazardous requirement.

    As a minor clarification, EuCIA suggests broadening the illustrative reference to reinforcement fibres to read such as glass fibres, carbon fibres, aramid fibres and natural fibres, while retaining the requirement that the composite waste be non-hazardous.

  • Support a technology-neutral approach across recycling pathways and recognize the recycling contribution of mineral fractions in cement co-processing.

    EuCIA also encourages a technology-neutral approach supporting suitable recycling pathways, including mechanical, chemical and thermal processes, and recognition of the recycling contribution of the mineral fraction in cement co-processing, in accordance with the waste hierarchy and environmental requirements.

• RE&UP Technologies Holding BV Company, NLD; register: Companies & groups model reads as: wants changes source
  • Establish clear, harmonized contamination criteria and set a 5% by weight threshold for separately collected, pre-sorted textile waste.

    Pursuant to Article 29(6) of the WSR, we encourage the Commission to establish clear, harmonized criteria for assessing contamination in textile waste.

  • Clarify and extend the simplified shipment regime of Annex IIIA to exports for recycling outside the EU, especially to OECD countries.

    Given the global nature of the textiles value chain, it is important to clarify whether the proposed changes to Annex IIIA or an equivalent simplified procedure could also apply to shipments for recycling outside the EU, particularly to OECD countries provided the applicable safeguards are complied with, ensuring the waste can be managed and recovered in an environmentally sound manner. We call for such extension and support its introduction, where appropriate.

  • Ensure coherence with related EU rules and achieve broader definition harmonization, including with the Basel Convention.

    In particular, pertaining to the shipments of textile waste, we would welcome broader reform and harmonization of definitions, including with international conventions like the Basel Convention.

• FEDERREC Business association, FRA model reads as: supports source
• Deichmann SE Company, DEU model reads as: wants changes source
  • Extend the exemption from the notification procedure to shipments intended for sorting, preparing for re-use, or other material recovery.

    The exemption from the notification procedure should therefore also cover shipments for sorting, preparing for re-use or other material recovery.

    machine translation by the Commission, original in DE
  • Explicitly extend the preferential treatment to mixtures of shoes and accessories even when no textile component is present.

    The privilege should therefore explicitly also apply to mixtures of shoes and accessories, regardless of whether a textile component is present.

    machine translation by the Commission, original in DE
  • Clarify whether shoes, belts, hats, and other accessories are already encompassed by Basel entry B3030.

    The proposal also raises the question whether shoes, belts, hats and other accessories are already covered by Basel entry B3030 or whether they should be considered separately. An explicit clarification would be helpful in order to avoid different interpretations and enforcement practices in the Member States.

    machine translation by the Commission, original in DE
• BASF Company, DEU; register: Companies & groups model reads as: wants changes source
  • Broaden green-listing to include sorted polyamide fractions from automotive shredder residue as a distinct entry in Annex IIIA(4), as well as other recoverable non-hazardous polymers.

    Recognizing this material as green-listed and including it as a separate entry in Annex IIIA(4) would facilitate its recycling and support achieving circularity targets set under EU End-of-Life-Vehicles Regulation. The same approach should be considered for other recoverable non-hazardous polymers, including engineering plastics, polypropylene (PP), and polyethylene (PE).

  • Expand the green-listing category for plastic packaging waste and adjust purity thresholds to reduce cross-border barriers.

    Expanding green-listing of this category would reduce administrative burdens, improve recycling efficiency, strengthen economies of scale, encourage investment in recycling technologies, and support achieving circularity objectives set under EU Packaging & Packaging Waste Regulation.

  • Green-list sorted plastic fractions derived from textile and mattress waste streams in line with their originating streams.

    If still considered waste, these sorted plastic fractions should therefore be green-listed in line with the waste streams from which they originate.

31 more analysed submissions on the consultation page.