How scrap leaves the European Union: the difference between “green-listed” clean metal and notified waste, the stricter treatment of exports to non-OECD countries, and the end-of-waste status that takes processed scrap out of the waste regime altogether.
How scrap leaves the European Union: the difference between “green-listed” clean metal and notified waste, the stricter treatment of exports to non-OECD countries, and the end-of-waste status that takes processed scrap out of the waste regime altogether.
Within the EU, scrap metal is legally a waste until it has been processed to the point where it ceases to be one. That classification governs how it may be moved. Clean, uncontaminated metal scrap — steel, copper, aluminium, brass, stainless — is on the “green list” and can move between EU countries and to most OECD countries with a simple shipment document and a contract between sender and receiver. Mixed, contaminated or hazardous material — e-waste, batteries, lead-sheathed cable, residues, dross — is “amber” or hazardous and needs prior written notification and consent from the authorities at both ends before it moves.
The regulation applies to the shipper, so the exporter is responsible for the paperwork, for a take-back obligation if the shipment is refused, and for proving the receiving facility is licensed.
The EU has tightened its rules on shipping waste, including scrap, to countries outside the OECD. The general direction is that green-listed scrap may go only to non-OECD countries that have told the Commission they want to receive it and have shown they can manage it in an environmentally sound way, and that exporters must audit the receiving facilities. Several large scrap importers — India, Pakistan, Bangladesh, Egypt, Vietnam, Malaysia — are outside the OECD, and the practical effect of the rules on them has been the main subject of debate in the European trade.
Turkey, the EU’s largest scrap customer, is an OECD member, as are Japan, South Korea, Mexico and the United States, and shipments to OECD countries follow the lighter procedure.
EU regulations set criteria under which iron, steel, aluminium and copper scrap that has been sorted, processed and checked to a defined standard stops being waste and becomes a product. Scrap with end-of-waste status moves as an ordinary good, outside the shipment regulation, provided the processor runs the required quality management system and issues a statement of conformity for each consignment. Many large European processors operate under these criteria precisely so that their export cargoes are not waste.
Classifies the material (green, amber, hazardous); prepares the Annex VII information document for green-listed moves or the notification for amber; confirms the receiver is permitted to take it; arranges pre-shipment inspection and radiation screening where the destination requires it; and keeps the documents for the retention period. Customs in the Netherlands, Belgium, Germany and the UK (which has kept a parallel regime after leaving the EU) check scrap containers against this paperwork.