Scrap metal, used tyres, plastic, e-waste and waste paper are ordinary container cargo with one difference: if they are going for recycling, recovery or disposal, they are usually waste in law, however much they sell for. Under the Basel Convention, the OECD Decision and national law, a load may need written consent from every country on the route, and a wrong description can make it an illegal shipment returned at the exporter's cost. The rules are tightening: the EU bans plastic waste exports to non-OECD countries from 21 November 2026.
Why a market value does not stop it being waste
The Convention defines wastes as things disposed of, intended for disposal or required by national law to be disposed of, and "disposal" includes recycling and recovery operations. Sale price is not the test. Maersk's advisory of 9 September 2026 says such cargo must be booked as waste "regardless of the commercial value of the material".
Maersk also stresses that waste classification, hazardous waste and dangerous goods are three separate tests: cargo that is not hazardous waste may still need consent and may still be dangerous goods. The HS code on the customs entry is a separate number again.
How the Basel Convention controls a shipment
The core is prior informed consent (PIC). Under Article 6 movement cannot start until the notifier has the importing State's written consent and confirmation of a contract for environmentally sound management; transit Parties consent too. Two forms carry this: the notification document, reviewed before anything moves, and the movement document, which travels with the load and is signed by each person taking charge of it.
What needs PIC depends on the Annexes. Annex VIII (List A) is presumed hazardous, Annex II covers "other wastes", and Annex IX (List B) is generally outside the procedure unless contamination makes the waste hazardous. Two amendments reshaped this for recyclers:
- Plastic (adopted 2019, effective 1 January 2021): added A3210 and Y48, leaving B3011 as the only plastic entry on List B: broadly, sorted plastic almost free from contamination, going for recycling.
- E-waste (effective 1 January 2025): decision BC-15/18 added A1181 and Y49 and deleted B1110 and B4030. The Secretariat's FAQ says "All e-waste is covered", and both entries need PIC. Parties that filed a non-acceptance are not bound, so check the status list.
Article 4(5) bars a Party from trading these wastes with a non-Party unless a separate agreement applies (Article 11). Recovery trade among OECD members generally runs under the OECD Decision's Green and Amber procedures, which is why carriers use those words.
Where common scrap usually sits
This is a starting point, not a classification. Maersk warns that contamination sets the classification for the whole container, however small its share.
| Stream | Usual entry | What changes the answer |
|---|---|---|
| Metal scrap | B1010, generally green | Batteries, electronics, capacitors, oils, sealed vessels |
| Used tyres | B3140, unless going to disposal | Destination bans; tyres for reuse need used-goods evidence |
| Plastic | B3011 if clean and sorted; otherwise Y48 or A3210 | Mixed, contaminated or halogenated plastic needs consent |
| E-waste | A1181 or Y49: PIC either way | Batteries inside make it dangerous goods as well |
| Waste paper | B3020, generally green | Plastic film, laminates, general waste; destination limits |
"Green" does not mean free of paperwork. Maersk names China, Malaysia, Singapore, South Africa, Türkiye and Uruguay among countries requiring a permit for import, export, transit or transshipment of green-listed waste. Amber-listed waste needs approval in every country concerned.
EU Waste Shipment Regulation: the dates that matter
Regulation (EU) 2024/1157 replaced Regulation 1013/2006. Article 86 and the Commission's notices give this timeline:
- 21 May 2026: most provisions began to apply and the DIWASS digital system went live. All plastic waste exports to third countries now need prior notification and consent, including clean B3011 to OECD countries. The Commission says green-listed waste for recovery may stay on paper until 31 December 2026.
- 21 November 2026: B3011 plastic exports to non-OECD countries are prohibited (Article 39(1)(d)), which the Commission calls a complete ban, at least until 21 May 2029. Malaysia, Indonesia and Vietnam are among the 2025 destinations it names. Do not assume a load booked earlier may still sail: ask your competent authority.
- 21 May 2027: Article 40 prohibits exports of non-hazardous waste for recovery to non-OECD countries unless the country and that waste are on a Commission list. This reaches paper, metal and tyres too. Audits of receiving facilities also start.
The Commission published a draft list on 18 September 2026, with the first list due by the end of 2026. Check the adopted version before quoting 2027 business.
The UK and US positions
UK. GOV.UK's guidance for England, updated 16 June 2026, rests on the assimilated Regulation 1013/2006, not the new EU text. Green-list shipments travel with an Annex VII form, and since 1 July 2026 those exporters must register with the Environment Agency. Notified shipments need a financial guarantee, a contract and liability insurance. Only B3011 plastic can go under green-list controls, and hazardous plastics cannot go to non-OECD countries. We found no in-force UK ban date matching the EU's as of November 2026.
US. The US signed the Convention but is not a Party. Hazardous waste exports fall under 40 CFR Part 262 Subpart H: notify EPA through WIETS at least 60 days before the first shipment, hold its Acknowledgment of Consent, carry a movement document, keep a contract and report the consent number in AES. Much recycled scrap metal sits outside those rules (40 CFR 261.6(a)(3)(ii)), but that settles only the US side. EPA says Basel Parties cannot trade Basel-controlled plastic scrap with the US without a separate agreement, and that the US may not export waste to Costa Rica, Malaysia or the Philippines under its agreements with them.
Importing-country bans
- China: solid waste imports have been prohibited since 1 January 2021. West of England P&I recorded that recycled steel, copper, brass and cast aluminium meeting national standards (GB/T 39733-2020 for steel) are not treated as solid waste.
- Malaysia: e-waste became an absolutely prohibited import on 1 April 2026 under gazette P.U.(A) 151/2026, Malay Mail reported, citing the customs director-general. Eco-Business has reported a July 2025 ban on shipments from Basel non-Parties.
- Thailand: a ban on plastic scrap imports from January 2025 has been widely reported. Confirm any destination rule locally before booking.
What happens when a shipment goes wrong
Basel Article 9 treats as illegal traffic any movement without notification or consent, with consent obtained by fraud, or that does not conform materially with its documents, and Parties consider it criminal (Article 4(3)). If the exporter is responsible, the State of export must see the waste taken back or otherwise disposed of within 30 days of being informed, unless the States agree otherwise; EU Article 25 mirrors this. GOV.UK warns of prosecution, fines and imprisonment, and says authorities may make you pay to return the waste.
Forwarders are not automatically spectators: in the EU a dealer or broker acting for the producer can be the notifier, and Article 61 lets inspectors demand evidence from whoever arranges the carriage. Carriers add their own exposure. Maersk says a misdeclared, undeclared or undocumented shipment must be reported to the authorities in all involved countries, a USD 5,000 misdeclaration fee applies, and rejection, return and restow costs fall on the customer. It accepts black mass, e-waste and lead-acid batteries only as declared hazardous waste. Other lines differ.
"Used goods" and "second-hand" misdeclaration
The EU regulation targets waste shipped "under the guise of used goods". Under Article 29 an item is a used good only if further use is certain, it works without significant pre-processing, it is tested where relevant, its use is lawful, and it is protected in transit. If evidence is missing or packing inadequate, inspectors may treat the shipment as illegal (Article 61). If two authorities disagree, it is treated as waste.
So untested televisions loaded loose are a waste problem whatever the invoice says. Basel's FAQ adds that used equipment is waste in a country if that country's law says so, and Maersk requires non-waste status in every country on the route, not just origin. Genuine resale cargo needs the kind of evidence described in shipping used machinery.
Container problems specific to scrap
- Weight: dense scrap reaches the payload or road limit long before the box is full. See container weight limits and VGM.
- Box damage and leaks: Gard, summarising 2018 guidelines for container lines, warns that heavy pieces can damage sidewalls and floors, and flags motor parts not drained of oil. See cargo securing inside the container.
- Self-heating: ferrous turnings and cuttings "in a form liable to self-heating" are UN 2793, Class 4.2. A UK accident investigators' flyer records two seamen asphyxiated on a ship (a bulk load, not a container) whose bill of lading said only "steel turnings". Raise any turnings with your carrier first.
- Batteries: Maersk warns that one short-circuiting cell in a sealed container can start a fire that cannot be reached at sea. It requires e-waste containing batteries to be booked as dangerous goods without exemption. See shipping lithium batteries.
Booking checklist for scrap and waste
- Written confirmation of the contents from whoever loaded them.
- Waste status decided for origin, every transit country and destination.
- Consent, Annex VII form or permit in the names going on the bill of lading.
- Routing fixed first: an unapproved transit country can cost the consent.
- Recovery facility, contract and any required audit identified.
- Waste code, HS code, UN number and carrier commodity code each checked, with batteries declared separately.
- Weighed gross mass, wall and floor protection, drained parts, no sealed vessels.
- Written agreement on who pays if the load is held, refused or returned.
What to do next
- EU plastic waste to a non-OECD country: stop bookings that would export on or after 21 November 2026, and ask your authority about cargo in transit.
- EU paper, metal or tyres to a non-OECD country: check the Commission's list and plan for 21 May 2027.
- Read your carrier's current waste notice before the next booking.
- Get the classification from your competent authority or a waste specialist before quoting, not after loading.
More than 29,300 logistics companies are searchable by country and service in the CargoLinked directory; ask directly about waste experience on your lane. The public requests board lists freight that shippers have posted for forwarders to quote on directly.
This guide is general information as of November 2026, not legal, customs or environmental advice. Waste rules differ by country and change often. Confirm the position with the competent authority in each country concerned, your carrier or a licensed professional before you ship.
