Joint Letter: Enabling EU industrial policy through improved circular material flows: A proportionate green-list route for non-hazardous intra-EU e-waste shipments

Executive summary

The European e-waste value chain calls on the European Commission to ensure that non-hazardous e-waste destined for recovery within the EU continue to benefit from the green-list procedure under the Waste Shipment Regulation (EU) 2024/1157 beyond 1 January 2027.

This is essential to preserve efficient intra-EU circular material flows and support European circular value chains. The EU’s circular economy, competitiveness and industrial resilience objectives depend on a functioning Single Market for secondary raw materials. Non-hazardous e-waste is a valuable circular resource, supporting recycling, remanufacturing and critical raw material recovery for Europe’s digital, clean-tech and industrial value chains. These flows depend on predictable movement across the Single Market to reach the specialised facilities best placed to recover their value.

From 2027, the broad application of Prior Informed Consent (PIC) procedures to intra-EU e-waste shipments risks undermining this framework. While PIC is appropriate for hazardous and higher-risk shipments, applying it to non-hazardous flows would add costs, delays, financial guarantees and administrative burdens to materials already managed through traceable and environmentally sound systems.

This would create clear policy incoherence. At a time when the EU is seeking to scale domestic recycling and remanufacturing capacity, stricter shipment procedures would make secondary materials harder, slower and more expensive to move within the EU. It would also weaken investment certainty for circular value chains.

A green-listing route for non-hazardous intra-EU e-waste would provide a proportionate solution. It would preserve traceability and environmental safeguards, avoid unnecessary barriers to legitimate circular flows, and allow authorities to focus enforcement on illegal, hazardous and high-risk shipments. Maintaining green-listing beyond 1 January 2027 is therefore essential to align the Waste Shipment Regulation with EU circularity, competitiveness and strategic autonomy objectives.

Signatories