List of non-OECD countries that are authorized to import certain non-hazardous waste from the EU

13 submissions in the snapshot (11 from organisations), portal total 13. Feedback list on the portal.

11 of 11 organisation submissions analysed; the model reads them as: opposes 2 wants changes 8 1 held back for review (low confidence).

• Micro company, FRA Company, FRA model reads as: wants changes source
  • Amend the final list of excluded countries by removing major Asian recycling hubs like India, Thailand and Malaysia.

    I strongly object to the preliminary exclusion of major Asian recycling hubs like India, Thailand and Malaysia from receiving metal waste for recovery under the proposed draft.

  • Include provisions to authorize exports to specific non-OECD countries and facilities that can independently prove ESM compliance through recognized international audits.

    The final regulation must include provisions to authorize exports to specific non-OECD countries and facilities that can independently prove ESM compliance through recognized international audits via Bureau veritas, SGS etc.

• Micro company, FRA Company, FRA model reads as: opposes source
  • Reject the proposed ban on metal scrap exports to non-OECD nations.

    The European Commissions proposal to ban metal scrap exports to non-OECD nations under the revised Waste Shipment Regulation (EU 2024/1157) represents "protectionist measures wrapped in green cloth".

• Micro company, GBR Other, GBR model reads as: wants changes source
  • Revise the proposed list so that every country and waste-stream authorisation rests on demonstrated compliance, withholding entries where evidence is insufficient.

    Please revise the proposed list so that every country and waste-stream authorisation rests on demonstrated compliance, with unresolved material deficiencies addressed before inclusion.

  • Publish a dated evidence table for each authorised stream covering treatment capacity, demand, imports, residual destinations, emission limits, monitoring, and enforcement outcomes.

    For each authorised stream, publish a dated evidence table covering actual treatment capacity, domestic waste demand, imports from all origins, residual-waste destinations, applicable emission limits, monitoring results, inspections and enforcement outcomes.

  • Publish an updated assessment and a clear response to the raised concerns before adopting the list.

    I ask the Commission to publish an updated assessment and a clear response to these concerns before adopting the list.

• LUCIUS d.o.o. Company, BIH model reads as: wants changes source
  • Reconsider the inclusion of metal waste streams for Bosnia and Herzegovina on the list of non-hazardous waste exports from the EU.

    We request reconsideration of the inclusion of metal waste streams for Bosnia and Herzegovina (BiH) on the list for non-hazardous waste exports from the EU: 120101, 120102, 150105, 160117, 170405, 191202, 110501, 120103, 120104, 160118, 160216, 170401, 170402, 170406, 170404, 170411, 191002 and 191203.

  • Assess municipal waste systems and specialised private recycling facilities separately.

    We propose that the Commission: assess municipal systems and specialised private facilities separately; allow competent authorities and operators to supplement the assessment with evidence and clearly specify conditions for including metal waste streams; support equal application of obligations to public and private companies and link sorting with existing recycling capacity.

  • Simplify administrative procedures for lawful exports of separated printed circuit boards to authorised EU facilities.

    Separately, we propose simplifying administrative procedures for lawful exports of separated printed circuit boards ("green boards") to authorised EU facilities, while maintaining correct classification, traceability and all necessary controls, to reduce the risk of treatment under poorly controlled conditions.

• Donald MCarthy Trading Pte Ltd Company, SGP model reads as: wants changes source
  • Revise the draft list to authorize exports of non-hazardous metal waste categories to Singapore.

    We respectfully request that the European Commission revise the draft list to authorise exports to Singapore for the following non-hazardous metal waste categories:

• Dow Chemical Company, NLD model reads as: wants changes source
  • Ensure strong ongoing monitoring and independent verification of approved countries.

    my support is conditional on strong ongoing monitoring, independent verification, and the Commission's willingness to reassess or remove countries that fail to maintain standards equivalent to those expected within the European Union.

• Allam Group Company, DEU model reads as: wants changes source
  • Reconsider the draft assessment for Morocco regarding ferrous and non-ferrous metal waste.

    However, we respectfully ask the Commission to reconsider the draft assessment for Morocco regarding ferrous and non-ferrous metal waste.

  • Grant authorisation for Morocco conditionally, limited to receiving facilities that hold an independent third-party audit demonstrating operation equivalent to EU Best Available Techniques.

    We propose that authorisation for Morocco be granted conditionally: limited to receiving facilities that hold an independent third-party audit demonstrating operation equivalent to EU Best Available Techniques, as foreseen in Regulation (EU) 2024/1157.

• Micro company, ESP Company, ESP model reads as: wants changes source
  • Provide the list of licensed facilities in a structured, machine-readable format per country and waste entry.

    We suggest a structured, machine-readable format, per country and waste entry, with the scope and validity of each licence.

  • Include a reference to the textile-specific minimum requirements for shipments of used textiles in recital 31.

    We suggest referring to those provisions in recital 31.

  • Create a separate leather waste description in the Annex to avoid misreading leather and fellmongery entries as textile waste.

    Although only codes and detailed descriptions define what is listed, a separate "Leather waste" description would avoid misreading.

• DigitalTrade4.EU Other, EST; register: Other organisations, public or mixed entities model reads as: wants changes source
  • Make targeted amendments to the draft delegated regulation before its adoption to improve reliability, traceability, and operational usability.

    This feedback recommends targeted amendments to the draft delegated regulation before its adoption.

  • Ensure clearer identification of authoritative data sources and structured, machine-readable information.

    In particular, the submission recommends clearer identification of authoritative data sources, current facility and permit status, structured and machine-readable information, transparent change and supersession handling, proportionate risk-based monitoring, and a clear distinction between public regulatory information and confidential shipment data.

  • Improve the reuse of existing Article 27 and eFTI-compatible information while identifying optional interoperability tools.

    It also proposes better reuse of existing Article 27 and eFTI-compatible information and identifies optional interoperability tools, including DPP, eIDAS trust services and legal-entity identifiers, without making them additional conditions for inclusion under Article 41.

• Micro company, BGR Company, BGR model reads as: opposes source
  • Adopt an approved list of audited Indian companies instead of a blanket export ban.

    The EU should consider the adoption of an approved list of Indian companies based on environmental audit instead of an outright ban.

  • Classify post-industrial clean metal scrap as raw material and permit its unrestricted flow.

    Also, post industrial clean metal scrap should be classified as raw material and allowed a free flow since it does not create hazardous risk.