Potential business impact of notification controls: please provide data so that BIR can effectively advise governments

From 1 January 2021, the UN Basel Convention decided to impose notification controls for listed waste Y48 of difficult to recycle and unrecyclable plastic wastes. Thereby, the listed Y48 plastic wastes require prior written notification and then consent from export, from transit and from import countries’ Competent Authorities, as does the listed A3210 hazardous plastic wastes.

In addition, in 2022, the UN Basel Convention decided to impose notification controls for all electrical and electronic wastes from 2025. Thereby, the newly listed Y49 and A1181 electrical and electronic waste will require prior written notification and then consent from export, from transit and from import countries’ Competent Authorities as of 1st January 2025. Presently the listed A1180 hazardous Waste electrical and electronic assemblies or scrap require prior written notification and then consent from export, from transit and from import countries’ Competent Authorities.

Notification controls, written notifications and consent procedures from respective Competent Authorities are dealt with at the speed of Government administration, frustratingly not at the speed of business. Furthermore, associated financial guarantees, fees and charges deter transboundary movements to recycling facilities, necessary for a circular economy.

BIR is intent on advising Governments on the potential business impact of imposing notification controls on an increasing number of listed wastes. To demonstrate how cumbersome and dissuasive these procedures are becoming, BIR needs information directly from companies.

So, BIR is conducting a short survey on waste notification (PIC) handling efficiency to determine future notification workload on Government and Company administrators. As data is needed country-by-country we kindly ask multi-nationals to answer for each country they operate in. Each company that arranges transboundary shipments has one or more persons responsible of making those arrangements. We kindly invite those essential staff and all recyclers (both BIR member and non-members) to answer the 7 brief questions in the survey at the following link as convenient either in English, French or Spanish.

• English: https://singuser789968d7.fra1.qualtrics.com/jfe/form/SV_0wfIOyLqIPZwZIW
• French: https://singuser789968d7.fra1.qualtrics.com/jfe/form/SV_3yNkeib2xM42F94
• Spanish: https://singuser789968d7.fra1.qualtrics.com/jfe/form/SV_e5nUiF4tDhF0MV8

We also call upon national associations to provide the survey to their member companies.

As all survey data will be compiled country-by-country, no company specific information will be released. Commercially sensitive information will be kept confidential in accordance with general data protection regulations and BIR rules.

For any questions related to this survey, please contact Alev Somer, BIR Deputy Director for Trade and Environment ( asomer@bir.org ).

We thank you in advance for your valuable input which will help us as we strive to convince Governments to reduce the burden on recycling businesses.

Your information is needed as soon as possible and no later than 23 March 2023.