European recycling industry associations have recently issued an urgent appeal to the European Commission to provide clarity on the planned audit obligations under the new EU Waste Shipment Regulation (WSR). Through the European industry platform Recycling Europe, national trade groups including Germany's bvse contributed to a position paper highlighting significant legal and planning uncertainties for companies in the recycling sector.
External audits for receiving facilities in third countries that recover waste exported from the EU are scheduled to become mandatory from 21 May 2027. At the same time, the European Commission only intends to set out which non-Organisation for Economic Co-operation and Development (OECD) countries certain wastes may be exported to in November 2026, when it publishes the "list of countries authorised to receive waste from the EU", bvse criticised. Preparations for the release of the list began last year.
From the industry’s perspective, the lack of information before this autumn creates a serious planning bottleneck: within a few months, companies would have to decide which partner facilities they can continue to work with, organise audits and ensure recognition by authorities – without clear guidance on criteria, responsibilities or mutual recognition of inspections, bvse said.
"Regulatory fog"
The current situation was "shrouded in a regulatory fog", said Romy Kölmel, policy officer at bvse and vice-president of the recovered paper branch of Recycling Europe. "Companies are expected to prepare for new audit obligations but do not know which standards will apply or which facilities in third countries will actually be permitted to receive shipments."
Ms Kölmel warned that the lack of planning certainty is already affecting international business relations: "If export options become uncertain overnight, a de facto export stop is looming. The uncertainty already makes the EU an unattractive trading partner for recycling companies in non-OECD countries and jeopardises the optimal use of secondary raw materials for which there are no material recovery options within the EU."
According to bvse, the joint position paper by European recycling associations underlines their clear support of the environmental objectives of the revised Waste Shipment Regulation (WSR), while stressing the need for clear, workable and coordinated implementation.
Guidelines and mutual recognition
In the position paper, Recycling Europe calls on the European Commission to increase the transparency of the procedure for approving non-OECD countries for waste exports, to issue guidance on the practical application of the audit obligations under Article 46 of the WSR, to introduce mutual recognition of audits across EU member states and to establish realistic implementation timelines, for example by postponing the audit obligation by at least six to twelve months.
It also urges clearer delineation of the roles and responsibilities of the parties involved, including clarification of the legal function of the future EU audit register and the basic rules governing validation, recognition and liability.
Ms Kölmel stressed that recycling companies are willing to implement the new requirements. "But without clear rules and sufficient preparation time, trade disruptions and market distortions are inevitable – with negative consequences for functioning international recycling chains.” Bvse is therefore calling on the European Commission to provide binding clarifications promptly and, together with the member states, ensure coordinated implementation of the new provisions.
Ensuring environmentally sound treatment
The audit obligation was introduced as part of the 2024 revision of the EU Waste Shipment Regulation. It is intended to ensure the environmentally sound treatment of exported waste at the receiving facility. The EU exporter must arrange to have an independent third party audit the facilities receiving its waste. If another exporter has already commissioned an audit for a facility, the commissioning party must make the results available to other exporters "under fair economic conditions". The European Commission will maintain a register of successfully completed audits.
Both document checks and physical inspections are required as part of the audit. A third party auditor must possess appropriate qualifications, be independent from the facility and be accredited by a national authority. The criteria for facility assessments are set out in an annex to the WSR.
Recycling Europe points out that its position paper is based not only on feedback from waste management companies and recyclers across numerous sectors but also on input from competent national authorities. If the current legal and operational uncertainties surrounding the audit framework are left unaddressed, "they risk undermining compliance, disrupting trade flows, and creating significant market fragmentation, despite the willingness of operators and third-country facilities to prepare for and comply with the new requirements," said the umbrella organisation.
Warning against restrictions in the recovered paper trade
In an earlier statement, Recycling Europe had warned against possible restrictions on the export of recovered paper. Concerns have been raised in connection with political interventions including a written EU parliamentary question that increasingly view exports of recovered paper critically and portray them as a risk to Europe’s industrial sovereignty. In the association’s view, however, this assessment falls short. Europe’s recycling system structurally generates more recovered paper than the paper industry in Europe can absorb. Exports are therefore not a problem but a necessary mechanism to keep surplus material in productive use.
Without access to international outlets, Recycling Europe says recyclers would face lower recovered paper prices, increasing stockpiling risks and reduced incentives for collection. As recycling markets are fundamentally demand-driven, restricting trade would not create additional recycling capacity in Europe. Instead, it could lead to market distortions, discourage investment and weaken the competitiveness of European recyclers.
At the same time, the association points out that exports of recovered paper are already subject to strict EU regulation. With the revised WSR, requirements for monitoring, traceability and compliance have been tightened further. Before introducing additional restrictions, Recycling Europe argues that the effects of the revised Regulation on trade flows and market conditions should first be assessed.
