Waste, recycling and shipment of used goods

• Regulation (EU) 2024/1157 — shipments of waste
• Directive 2008/98/EC — waste framework
• Regulation (EU) 2023/1542 for waste batteries
• Directive 2012/19/EU for WEEE

Who has to appoint one

Anyone shipping waste into, out of or through the Union, including used electronics and vehicles that qualify as waste. The distinction between used goods and waste is the central question, and misclassification is treated as illegal shipment rather than as a paperwork error.

Thresholds and exemptions

Green-listed waste for recovery follows a lighter information procedure; hazardous and mixed waste requires prior written notification and consent from every competent authority on the route, with a financial guarantee.

What must appear on the label

Shipment documents rather than labels: the Annex VII information document for green-listed waste, or the notification and movement documents for the notification procedure, accompanying the consignment throughout.

Marketplace fields

Waste shipment is not a marketplace activity, but used electronics sold cross-border are frequently reclassified as waste at the border, which stops the consignment and exposes the shipper.

Documentation you must hold

Contract between notifier and consignee, financial guarantee covering return and disposal, consent from all competent authorities, movement documents completed at each stage, and for used equipment evidence of functionality testing to demonstrate it is not waste.

Standards and testing

Functionality testing and protection against damage during transport are the evidence that distinguishes used equipment from WEEE, and the WEEE Directive sets out what must be documented.

Language requirements

Documents in a language accepted by all competent authorities on the route, which usually means English plus the national languages of dispatch and destination.

When it applies

Consent before shipment. The recast Regulation tightens exports of waste to non-OECD countries and phases in from 2026 and 2027.

How long records are kept

Records for at least five years from the start of the shipment.

What happens if you do not comply

Return of the consignment at the shipper's expense, fines and criminal prosecution. Illegal waste shipment is an environmental crime under Directive 2024/1203 with imprisonment available in every member state.

Who enforces it

National competent authorities for waste shipment, customs, and environmental crime units.

Where the boundary lies

Used electronics are the recurring flashpoint: without documented functionality testing and appropriate packing, a consignment of second-hand devices is treated as WEEE, and exporting WEEE outside the OECD is prohibited. The burden of proof is on the shipper.

Questions we are asked

Is used equipment waste?

Not if you can document that it functions, is packed to avoid damage and is destined for continued use. Without that evidence, authorities treat it as waste.

Can we export electronics for repair?

Only under conditions, and exports to non-OECD countries are heavily restricted. The recast Regulation tightens this further from 2026.