Notification procedure

Cars waiting to be scrappedClick to enlarge
Cars waiting to be scrapped
Source: CC Vision

Transfrontier shipments of non-green-listed wastes are subject to a prior written notification and consent procedure. This also applies to wastes for which a permit is required.

The procedure of prior written consent comprises requirements concerning prior checks (before the shipment starts) and fate verification (for each transport). The exporter has to notify the shipment to the competent authority of dispatch by filling in the notification and movement document  and submitting additional documents. The instructions for completing the forms give advice and also fix the frame size of the forms. In Germany these forms are issued either by the competent authority of dispatch or by licensed printing-works, waste management or software companies (DE followed by a 4 digit license number, followed by the 6 digit notification number).

Transfrontier shipments of waste are only allowed when the competent authority in the country of dispatch (export country), the competent authority in the country of destination (import country) and the competent authority(ies) of transit have consented. The competent authorities of dispatch and destination have to consent in writing, whereas the competent authority of transit may choose tacit consent. All consents have to be in place together.

The consent is valid for one year. For pre-consented ecovery facilities he period of validity of the consent may be extended to up to three years. Exceptions to the obligation of prior written notification of waste shipments are described under general information requirements.The Federation/Federal States Working Party on Waste (LAGA) has developed guidance (in German) on the enforcement of the WSR.

Competent authorities

Pursuant to paragraph 14 of the German Waste Movement Act, decisions regarding the export and import of waste requiring notification in Germany come under the jurisdiction of the Federal States.. In the case of exports, responsibility lies with the authority of the Federal State in which the waste transport begins. In the case of imports, which state is responsible depends on where the waste will be treated, stored or landfilled for the first time. The Federal States have designated competent authorities responsible for examining import and export notifications for transfrontier shipment of waste. The Federal Environment Agency is the competent authority for waste transit through Germany.

It is recommended to contact the competent authority in advance in order to clarify any questions concerning procedure or required documentation for planned shipments.
Information on the focal points and competent authorities of other countries can be found at the Secretariat of the Basel Convention (SBC).

Interpretation of the term „transit“ in the field of maritime shipments

It is the opinion of the German Environment Agency concerning transit through Germany that in the field of maritime shipments the procedure of prior written notification and consent shall apply where a ship calls at a German port and/or passes through the Kiel Channel. There is no need for notification where a ship only passes through the coastal sea and/or the exclusive economic zone.

The time series shows the development of import (largest share), export, and transit 1995-2012 requiring waste.
Waste requiring notification 1995-2012
Source: Umweltbundesamt zeitreihenotifizierungspflichtigeabfaelle.xlsx