Institut français de l environnement 5, route d Olivet BP ORLEANS CEDEX 2 FRANCE

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1 Institut français de l environnement 5, route d Olivet BP ORLEANS CEDEX 2 FRANCE Pilot Study of Statistics on Imports and Exports of Wastes in France Final Report 20 December 2004 Telephone: +33 (0) Fax: +33 (0) ifen@ifen.fr

2 Contents Context of the pilot study of waste imports and exports Main tasks within the framework of the pilot study Main conclusions and recommendations of the pilot study Requirements of the waste statistics regulation Four types of waste groups are specified. Categories of wastes used for this study Other requirements of the waste statistics regulation EC Regulation 259/93, on transboundary movements of waste Outline of current system Competent authorities Information collected Use by Ifen of the departmental information on transboundary movements Report issue date Presentation of main results Revision of the European Regulation (259/93) on transboundary movements of waste Correspondence between the codes used for the control system for transboundary movements of waste and the waste category rubrics of the regulation on statistics Transboundary movements of waste in 2001 and 2002 according to waste statistics regulation categories Statistical monitoring of external trade in commodities Presentation of the external trade source in France General Excluded operations The Combined Nomenclature Selection of waste rubrics in the CN Correspondence between CN waste rubrics and those of the waste statistics Towards an assessment of coverage by the external trade source 2

3 ANNEXES Annex A Waste categories defined in Annexes I and II of the regulation on waste statistics Annex B Transboundary movements of wastes in 2001 and 2002 tracked by the tracking and monitoring system Detailed results by type of waste in accordance with OECD Amber and Red lists Annex C Notification Document for Transboundary Movement of Waste, proposed by Addendum 1 to OECD Council Decision C(2001)107 Annex D Table of correspondence between rubrics of the wastes list given in Annex VIII of the Basel Convention and waste categories defined in Annexes I and II of the regulation on waste statistics Annex E Table of correspondence between the rubrics of the OECD Amber and Red lists and waste categories defined in Annexes I and II of the regulation on waste statistics Annex F - Table of correspondence between the waste rubrics of the combined nomenclature and waste categories defined in Annexes I and II of the regulation on waste statistics Annex G Table showing, for each waste category defined in Annexes I and II of the regulation on waste statistics, the codes of the OECD list, of the list from Annex VIII of the Basel Convention and waste codes of the combined nomenclature This study was conducted by the (Ifen French environment institute). It received financial backing from the European Commissions (Eurostat). The contents of the study are the sole responsibility of Ifen. The Commission bears no responsibility. 3

4 Context of the pilot study of waste imports and exports The purpose of EC Regulation No. 2150/2002 of 25 November 2002, on waste statistics, is to ensure the production of regular statistics on wastes generated by businesses and private households. These statistics are required by the EC to monitor implementation of waste management policies and, in particular, to allow verification of results relating to recovery of waste and safety of its disposal. The statistics must allow comparisons to be made between EU Member States, and developments to be monitored. Some of the waste arising in one Member State may be exported for recovery or disposal. Conversely, wastes may be imported for recovery or disposal. It is therefore useful to track waste import and export movements, in order to be able to check progress in recovery and safe disposal. The waste statistics regulation stipulates what is required of Member States in terms of statistics on generation and treatment of waste, but leaves definition of the specifications to be used to cover waste imports and exports to the conclusions of the pilot studies that Member States are obliged to conduct 1. Paragraph 2 of Article 5 of the waste statistics regulation stipulates that the Commission's proposals for these pilot studies are to comply with Annexes I and II of the regulation, especially regarding the scope of application and coverage of waste, waste categories for the classification of waste, reference years and periodicity. Annex I defines the characteristics required for statistics on generation of wastes; Annex II defines the characteristics for recovery and disposal. However, the two annexes do not classify wastes in the same manner: the categories in Annex I have to be grouped in order to obtain those of Annex II. It must also be pointed out that the waste categories defined in Annexes I and II are the result of grouping of the rubrics of categories from the waste statistical nomenclature which forms Annex III of the waste statistics regulation. Annex III also provides correspondence between the items in the statistical nomenclature and the rubrics of the European list of wastes, which now has legal status within the European Union regarding administrative declarations to be made by those generating and disposing of waste. For each waste category, the waste statistics regulation requests that, if relevant, distinction be made between hazardous and non-hazardous wastes. Annex of A of this report presents the waste categories defined by the waste statistics regulation. The system put in place in application of regulation EC No. 259/93, on supervision and control of shipments of waste within, into and out of the European Community, introduces administrative tracking of transboundary movements of certain categories of wastes. The scope of the waste movements control system covers movements of hazardous wastes and wastes classified as non-hazardous but which nonetheless present risk factors if they are not disposed of or recovered in an appropriate manner. Paragraph 3c of Article 1 of the waste statistics regulation requests that the pilot study take account of the obligations on notification of the regulation on supervision and control of shipments of waste within, into and out of the European Community. 1 For the purposes of this study, export is taken to mean any movement out of national territory and import to mean any movement into national territory. This includes intra-community movements. 4

5 Furthermore, the pilot study should propose a methodology for production of statistics on imports and exports not covered by the administrative tracking of waste, in other words those relating to wastes for recovery included in the OECD's green list. The information to be used to compile the statistics is, principally, in the form of the declarations of imports and exports of commodities made by businesses to the statistics department of the Customs service. The Institut français de l'environnement (Ifen French environment institute) is the statistics department of the Ministry of the Environment, with particular responsibility for France's response to the waste statistics regulation. It was in this capacity that, in June 2003, Ifen proposed to carry out the pilot study on imports and exports. Its proposal was accepted by the European Commission and the pilot study was conducted in This report presents the proposals and results of the pilot study. Main tasks within the framework of the pilot study For imports and exports of waste covered by EC Regulation 259/93 on supervision and control of shipments of waste within, into and out of the European Community, the first step was to examine the correspondence that could usefully be established between the rubrics of waste categories used in this control system and the categories defined in Annexes I and II of the waste statistics regulation. An assessment was also made, for each waste category, of the quality of coverage of imports and exports provided by this correspondence. Finally, the opportunities provided by revision of the regulation on supervision and control of shipments of waste within, into and out of the European Community should be highlighted. Revision of the regulation has not been adopted to date, but the main orientations are now known and should come into force in For waste imports and exports not within the scope of EC Regulation 259/93, a choice must first be made from among the rubrics of the Combined Nomenclature (CN) used by businesses obliged to declare their external trade in commodities of those sections that relate to waste. In a second phase, the waste rubrics of the CN must be compared with the waste categories defined in Annexes I and II of the waste statistics regulation. Coverage of imports and exports is assessed for each waste category. Main conclusions and recommendations of the pilot study 1) Revision of the regulation on supervision and control of shipments of waste within, into and out of the European Community will request notifying parties (waste exporters) to identify wastes in accordance with the Basel Convention as a priority; this will allow for distinction to be made between hazardous wastes and others. This type of distinction is also required by the waste statistics regulation. 5

6 2) The correspondence we propose, after our study, between the rubrics of the lists used specifically within the framework of the system for supervision and control of shipments of waste within, into and out of the European Community and the categories of the waste statistics regulation may not always be complete. This is because certain rubrics of the OECD or Basel Convention lists can correspond to several waste categories of Annex I of the waste statistics regulation. This is the case for the rubrics that include ash and residues, which we class as combustion wastes but which can, in some cases, also correspond to saline wastes in the acid, alkaline or saline wastes category. Moreover, there is a deep underlying difference between the two types of lists: those specific to the regulation on supervision and control of transboundary movements of waste tend to focus on contamination, whereas the European list of wastes and the statistical waste nomenclature are more oriented towards production processes and substances, respectively. There are, in particular, certain difficulties in matching rubrics covering hazardous metals proposed by the specific lists (mercury, arsenic). 3) From the proposed correspondence between the rubrics of the waste lists defined specifically for the supervision and control system and the waste categories defined in Annex I of the waste statistics regulation, we should nevertheless obtain fairly satisfactory coverage for imports and exports of wastes for the following categories: Spent solvents (hazardous) Acid, alkaline or saline wastes (hazardous) Used oils (hazardous) Spent chemical catalysts (hazardous) Chemical preparation wastes (hazardous) Health care (medical and veterinary) and biological wastes (both hazardous and non-hazardous) Glass wastes (hazardous) Wood wastes (hazardous) Wastes containing PCB (hazardous) Battery and accumulator wastes (hazardous) Animal faeces, urine and manure (non-hazardous) Household and similar wastes (non-hazardous) Common sludges (non-hazardous) Combustion wastes (hazardous) Mineral wastes (hazardous) Conversely, only partial coverage is obtained for chemical deposits and residues (hazardous), discarded equipment, combustion wastes (non-hazardous), and mineral wastes (non-hazardous). 4) The OECD list is incomplete for a relatively large number of operations. It does not appear that use of the Basel Convention waste list in place of that proposed by the OECD after revision of the regulation on supervision and control of transboundary movements of waste will improve the situation. It must be possible to qualify these wastes using other information such as the wording describing their nature and information given in notification documents. 6

7 5) Furthermore, the notification documents used for supervision and control of movements into and out of the European Community also request that the European list code be given for waste identification. Such information is already requested in the notification documents currently in use. We recommend preferential use of this information which by using the table of correspondence in Annex III of the waste regulation allows, the link to be made with the categories of Annexes I and II of the regulation: the difficulties of incomplete correspondence between lists, mentioned above (point 2), would thus be avoided. In particular, coverage of all of the hazardous waste categories, only partial from the lists specific to control and supervision of transboundary movements of wastes, would be improved. Study of transitory waste movements in 2002 for which double coding (OECD and European list of wastes) was available also indicates that the codes from the latter are given more systematically than those of the OECD list, the no response phenomenon would therefore be reduced. 6) Retrieval from the competent authorities of the wording specifying the nature of waste and of the code from the European list of wastes (information given by the notifying party) would result in only a slight increase in work load. 7) Selection of waste rubrics of the CN and comparison of these with the waste categories defined in Annex I provides good matches for the following categories: Spent solvents (hazardous) Used oils (hazardous) Chemical wastes (both hazardous and non-hazardous) Health care (medical and veterinary) and biological wastes (combined) Metallic wastes (both hazardous and non-hazardous) Glass waste (both hazardous and non-hazardous) Paper and cardboard wastes (non-hazardous) Rubber wastes (non-hazardous) Plastic wastes (non-hazardous) Wood wastes (both hazardous and non-hazardous) Battery and accumulator wastes (both hazardous and non-hazardous) Household and similar wastes (non-hazardous) Common sludges (non-hazardous) Combustion wastes (both hazardous and non-hazardous) 8) The animal and vegetal wastes and animal waste of food preparation and products categories raise two types of difficulties that are complex to remedy: a) some rubrics of the CN, mainly relating to products of the agro-food industries, cover both wastes and non-wastes; b) the waste statistics regulation is not precise about agro-food industry byproducts that should be classed as wastes. Clarification has been requested of Eurostat. These two difficulties prevent us from proposing relationships between the rubrics of the CN and the animal and vegetal wastes and animal waste of food preparation and products categories defined in Annex I of the waste statistics regulation. 7

8 9) The limit of per year, below which external trade in commodities does not have to be declared, has an effect on the extent of coverage provided by statistics on external trade that is difficult to assess. Additional statistical studies should be conducted. 10) The two sources (control and supervision of transboundary movements, and external trade) provide results every year and within timelines that are compatible with the requirements on waste statistics. 11) The categories of wastes that cannot be distinguished from the two sources when waste is destined for recovery (assuming use of the European list of wastes code to mobilise the control and supervision of transboundary movements source) are: Chemical catalysts (non-hazardous) Chemical deposits and residues (non-hazardous) Industrial effluent sludges (non-hazardous) Discarded equipment (non-hazardous) Discarded vehicles (non-hazardous) Sorting residues (non-hazardous) Dredging spoils (non-hazardous) Mineral wastes (non-hazardous), only disposal operations are subject to administrative tracking Solidified, stabilised or vitrified wastes (hazardous and non-hazardous). Requirements of the waste statistics regulation Four types of waste groups are specified Annexes I and II of the waste statistics regulation specify the rubrics of waste categories for which statistics are to be compiled. The categories of wastes defined in the two annexes result from grouping of the rubrics of the wastes statistical nomenclature presented in Annex III of the waste statistics regulation. Four groups of waste categories are requested: generation of waste (Annex I); recycling and recovery (Annex II); incineration (Annex II); and disposal other than incineration without energy recovery (Annex II). The type of grouping of categories of wastes for waste generation is more detailed than those to be used for recovery and disposal operations. For each type of waste, distinction is to be made between hazardous and non-hazardous waste, if relevant. The tables in Annex A of this report give the different groups. Categories of wastes used for the study In practice, these different levels of grouping limit the possibilities of a study of all waste streams that include imports and exports to the waste categories given in Annex II. For each category of waste, it would be necessary to compare the quantity generated, the quantities 8

9 recovered or disposed of, and the quantities imported and exported. The equality given below should be satisfied for each type of waste: Waste treated (recovery or disposal) in the country = waste generated in the country waste exported + waste imported Where imports and exports of waste are concerned, the important point is to obtain the most aggregated categories, those of Annex II. Availability of rubrics in accordance with the nomenclature of Annex I would be of interest, but would not allow comparison with the quantities treated appearing in Annex II, not available at this level of detail. Furthermore, some categories appear more important than others, especially hazardous wastes and those likely to be recovered. For the study, the most relevant rubrics of Annex II of the waste statistics regulation appear to be: Chemical wastes (grouping spent solvents, acid, alkaline and saline wastes, chemical preparation wastes and chemical deposits and residues) hazardous Used oils hazardous Health care (medical and veterinary) and biological wastes hazardous Household and similar wastes non-hazardous Mixed and undifferentiated materials non-hazardous Metallic wastes non-hazardous Glass wastes non-hazardous Paper and cardboard wastes non-hazardous Rubber wastes non-hazardous Plastic wastes non-hazardous Wood wastes hazardous Wood wastes non-hazardous Textile wastes Animal and vegetal wastes Animal faeces, urine and manure Mineral wastes non-hazardous Common sludges It must be pointed out that the rubrics of Annex II of the waste statistics regulation can be obtained by grouping those of Annex I of the regulation. Other requirements of the waste statistics regulation Results are to be produced every two years starting from the reference year They are to be communicated to Eurostat at the latest 18 months after the end of the reference year. Quantities are to be expressed in thousands of tonnes of normal wet wastes. For sludge waste categories, tonnage of dry matter should be given. A report on the coverage and quality of the statistics is to be produced. These requirements, especially that on timelines for submission of results, apply a priori to waste imports and exports. 9

10 EC Regulation 259/93, on transboundary movements of waste This regulation provides the legal framework for supervision and control of shipments of waste within, into and out of the European Community. It applies to all of the countries of the EU (with, however, transitional measures for new Member States). It must be compatible with the conditions of the Basel Convention on control of transboundary movements of hazardous wastes and their disposal. All of the EU countries have signed the Basel Convention. It must also be compatible with the conditions of the OECD's Decision (C92/39/(FINAL) ) on control of transboundary movements of waste destined for recovery operations. An amendment by the OECD Council, adopted 14 June 2001, requests that, in future, wastes be identified in terms of the waste rubrics listed in Annexes VIII and IX of the Basel Convention. This amendment by the OECD Council implies amendment of the European regulation on transboundary movements of wastes. If amendment is adopted in 2005, its implementation will be effective in Change in the list of wastes to be used by notifying parties in order to declare types of waste subject to transboundary movements to the administrative authorities is, of course, to be taken into account with a view to use of these declarations within the regulatory framework relative to waste statistics. Outline of the current system Regulatory requirements differ depending on whether the waste to be transferred is for recovery or disposal, and on whether movement concerns only EU countries or other countries (especially OECD countries). For the latter, distinction is made between imports and exports. The most important cases are distinguished for the purposes of this study. Export of waste for disposal from EU countries to countries that are not EFTA members is forbidden. This is to avoid disposal of waste in developing countries at low cost, but with risk to the environment. Certain waste movements are subject to prior notification addressed to the competent authorities of the destination country, with copy to the competent authorities of dispatch and transit, as well as to the consignee. This notification is usually undertaken by the exporter, who is then referred to as the notifier. Notification is obligatory, particularly in the following cases: - Import and export of wastes for disposal; - Import and export of categories of wastes on the OECD's amber and red lists. The amber and red lists include wastes considered hazardous in the sense of the European list of wastes and categories of wastes not classified as hazardous in application of OECD Decision C92/39/(FINAL) but for which recovery must be monitored. Article 10 of the regulation requires that transfers of wastes not covered by any of the annexes of Regulation 259/93 relative to the OECD's green, amber or red lists be subject to prior notification. These can be referred to as wastes that are hazardous in the wide sense. Notification of the competent authorities allows statistical processing of data after it has been centralised at the national level. 10

11 A report on transboundary movements of waste is addressed each year by EU Member States to the Basel Convention Secretariat. A copy of this report is also addressed to the European Commission and to the OECD. In France, the report is drafted under the responsibility of the Bureau de la Planification et de la Gestion des Déchets (office of planning and waste management) at the Ministry of Environment's Direction de la Prévention des Pollutions et des Risques (department of pollution and risk prevention). The statistical section of the report is produced with the participation of Ifen. Import and export for recovery of wastes that are non-hazardous in the wide sense (or wastes on the green list) and that concern OECD countries are not subject to notification by the exporter. These wastes therefore circulate freely. They are not subject to any particular tracking that would allow compilation of statistics. Competent authorities In France, the competent authority for waste imports and exports is the Préfecture de Département (departmental prefecture). The environment offices of the prefectures are supported by technical assistance from the Directions Régionales de l Industrie de la Recherche et de l Environnement (DRIRE regional authorities for industry, research and environment). Metropolitan France is divided into 96 Departments and there are four Overseas Departments. The minister for environment is the competent authority for waste transit. Information collected The departmental prefectures have information given on the notification forms and movement documents. This includes the following: The name and address (and therefore the country) of the consignor or exporter of the waste, generally the generator of the waste. The name and address (and therefore the country) of the consignee or importer of the waste (disposer or recoverer-recycler). The nature of the waste, in written form. Coding for type of waste, in accordance with the various nomenclatures: Basel Convention Y Code OECD green, amber or red list codes European list of wastes code (ex European Waste Catalogue) The disposal operations code, in accordance with the list of codes in Annex to the framework directive on waste (75/442/EEC). The code for the nature of hazards (Basel Convention H Code) The quantities of waste subject to transboundary movements, expressed in kilogrammes. If this is not possible, amounts may be given by volume (litres). Each year the environment offices of the prefectures send import/export balances of these transboundary movements of waste to Ifen, recapitulating movements in the previous year for each consignee or importer and each consignor or exporter, as the 11

12 prefectures receive a copy of the movement document accompanying each waste shipment. These balances contain the following information: 1 ) Export movements Exporter's name or business name Business registration number, allowing exporter to be identified (not always given) Importer's country code 2 ) Import movements Importer's name or business name Business registration number, allowing importer to be identified (not always given) Exporter's country code 3 ) Information common to import and export movements Basel Convention Y Code OECD green, amber and red list code The operations code, in accordance with the list in annex to the framework directive on waste (75/442/EEC). The code for the nature of hazards (Basel Convention H Code) The nature of the waste, described in written form, and the European list of wastes code, although given in the documents from the notifier, are not included in the annual balances sent to us by the prefectures. Use by Ifen of the departmental information on transboundary movements Ifen receives and processes the information in the annual balances sent by the prefecture environment offices. The information collected in this way is used to compile the major part of the annual report. If quantities appear unusual or if important information is missing (e.g. country or disposal operation not given), the prefecture's environment office or, if relevant, the competent department of the DRIRE, will be contacted for confirmation or further information. Report issue date Until now the first draft of the report has rarely been available less than 18 months after the end of the year. Such lengthy delays are, essentially, the result of difficulties in obtaining transboundary movement balances from two or three late submitting 12

13 departments. Provisional results differing, in fact, only slightly from the final ones could, however, be used to meet the deadlines stipulated in the regulation on waste statistics. Presentation of main results The results presented in the tables below cover only wastes in the OECD's red and amber lists as well as those that could not be re-classified and that have been grouped under Other Red Lists (ORL). Wastes from the OECD green list are not included in the tables. Import and export by zone Table 8 Movements of hazardous waste per zone evolution European Union EFTA Non-OECD Total OECD countries countries outside of EU and EFTA Imports tonnes % tonnes % tonnes % tonnes % tonnes Exports tonnes % tonnes % tonnes % tonnes % tonnes The tonnage of wastes imported by France and that are subject to official monitoring has more than doubled since 1998; it has been over 1 million tonnes since More than 98 per cent of the amounts imported are from European Union or EFTA countries (mainly Switzerland). Moreover, the report also mentions imports of backfill material, stone and pebbles, waste which is destined, for the most part, for disposal in Alsace. In 2002, more than tonnes of waste of this type (green list) were imported. Waste exports, mainly to European Union or EFTA countries, also rose considerably, reaching tonnes in We observe that there is no export of waste to non-oecd countries. 13

14 Imports and exports by type of waste and destination Table 9 Recovery from movements of hazardous wastes evolution Disposal Recovery Proportion Amber Red ORL Amber Red ORL recovered tonnes tonnes tonnes tonnes tonnes tonnes % Imports Exports More than 80 per cent of the waste imported and exported is destined for recovery. Most of the wastes are on the OECD's amber list. The greatest waste import streams for 2001 and 2002 include combustion wastes (iron and steel industry), surface treatments for metals, spent batteries, chemical wastes (acids and solvents), and wastes from treated woods. Exported wastes are of a variety of types and, as for imports, the amounts destined for recovery are much greater than those bound for disposal. The results relating to imports and exports, detailed in terms of the modalities of the amber and red lists, are given in Annex B of this report. A significant proportion of transboundary movements of wastes, for both import and export, could not be classified in the OECD's red or amber lists, they are grouped in the ORL columns. This share grew noticeably in Where these operations are concerned, there is no code allowing the nature of the waste to be described under the existing framework. A consequence of this last comment is difficulty in the possible use of this source to comply fully with the waste statistics regulation. A solution would be to obtain more detailed information on the nature of waste from the prefectoral environment offices: for example, the uncoded wording used in notification documents. Furthermore, as mentioned above, notifiers often use the European list of wastes code in the notification and movement documents. An amendment to the annual balance form to allow retrieval of this information from the environment offices of prefectures could be negotiated with the ministry responsible for environment. The additional work load for the prefectures appears relatively limited in relation to the work already required to produce the annual balances sent to us. The next revision of the European regulation on transboundary movements of waste 14

15 (259/93), which will probably require changes in the annual balance form, will provide the opportunity to amend the document. Revision of the European Regulation (259/93) on transboundary movements of waste The 1992 OECD decision to which the European Regulation (259/93) of 1 February 1993 refers was amended by the OECD Council Decision C(2001)107 FINAL, of 14 June 2001, to incorporate the waste lists in Annexes VIII and IX of the Basel Convention. These two lists define, respectively, non-hazardous and hazardous wastes. The scope of wastes covered by the future regulation would, on the other hand, be only slightly amended. The following are still distinguished under the new OECD Decision: a) the scope of the green list incorporating Annex IX of the Basel Convention and wastes that OECD members consider as non-hazardous; b) the scope of the amber list incorporating Annex VIII of the Basel Convention and wastes that the OECD members consider as hazardous. The normal rules of commercial transactions apply to green list wastes to be recovered: there is, therefore, no notification. Amber list wastes are subject to prior notification. The various authorities involved have the possibility of giving their tacit agreement. Amber and green list wastes destined for disposal are subject to notification and agreement from the competent authority. Amendment of the OECD Decision on the lists and also on the rules to apply to mixtures of wastes made it necessary to amend European Regulation 259/93/EC. The Commission decided on a full revision of this regulation and the revised version should, in theory, be adopted in 2005 and come into force in its new version in The Notification Document for Transboundary Movements of Waste, proposed in the addendum to the OECD Council Decision C(2001)107 on the amendment of Decision C(92)39/Final is available. It can be found in Annex C of this report. It requests that, in order to identify wastes, the codes of the waste lists given in Annexes VIII and IX of the Basel Convention be used (line i of the waste identification part). If not possible, the codes of the OECD lists can be given (line ii of waste identification part). Using this information, it should be possible to distinguish the streams of wastes that are hazardous in the sense of the regulation on waste statistics (if the Basel Convention Annex VIII code is given) from other streams covered by the European regulation on transboundary movements of waste which, for their part, would be identified by the OECD amber and red list codes and/or those from the list of wastes given in Annex IX of the Basel Convention. It is also requested that the code from the European list of wastes be given (line iii of the waste identification part). Obviously, if the European list of wastes code is given by the waste exporter on the notification document, the tables showing correspondence between the rubrics of Annex VIII of the Basel Convention or the OECD amber list and waste categories defined in Annexes I and II of the regulation on waste statistics would lose some of their interest. The analysis by Ifen of movement documents on waste transiting France's national territory, conducted on behalf of the ministry and within the framework of the annual report, shows that for more than 110 operations duly notified in 2002, only six did not have the European code filled out, whereas in 16 cases the OECD code was not given. It therefore appears that work on correspondence between waste rubrics specific to transboundary movements of 15

16 wastes and those of the waste statistics regulation have an interest for the future that is limited to cases of failure to respond, which should be few in number. Correspondence between the codes used for the control system for transboundary movements of waste and the waste category rubrics of the regulation on statistics Correspondence between the codes of the wastes list proposed in Annex VIII of the Basel Convention or items on the OECD amber and red lists and the groups of rubrics of the waste statistics nomenclature proposed by Annexes I and II of the regulation on waste statistics are presented in the form of two tables given in Annexes D and E of this report respectively. In certain cases, identical or very similar categories helped comparison. In other cases, correspondence between the codes proposed by the Basel Convention and items on the OECD lists was established initially with the rubrics of the European list of wastes, subsequent comparison with the waste statistics nomenclature was then made using the table of correspondence proposed in Annex III of the regulation on waste statistics. Moreover, study of waste transit operations for 2001 and 2002 for which the OECD list codes, a description in words of the waste and the code from the European list of wastes were available allowed certain cases to be resolved and some of the proposed matches to be validated. Finally, we also had the report on the pilot study on statistics on imports and exports of waste in Germany, conducted by Umweltbundesamt, in which correspondence tables partially covering hazardous wastes are proposed, allowing for comparison with our work. Among the OECD amber list rubrics, those described as ashes and residues were all matched with rubric 12.4 combustion wastes of the waste statistics nomenclature. This no doubt constitutes the least worst solution in the absence of further information, but in certain cases these may be metal salts corresponding more to the acid, alkaline or saline wastes of Annex I of the waste statistics regulation. In one case (AD 100: wastes from noncyanide based systems which arise from surface treatments of plastics ), no satisfactory match could be proposed with the waste statistics nomenclature. It should, however, be noted that no transboundary movement concerning this type of waste has been recorded in the past three years. The other matches proposed are, however, far from being wholly satisfactory. The study of transit movements shows, in particular, that notifiers sometimes code the item that is hazardous according to the OECD list whereas, according to the European list of wastes, it is rather the substance characterising the waste which should be used. For example, waste light bulbs containing mercury are coded AA100 (mercury waste and residues) whereas according to the waste statistics nomenclature discarded equipment (or possibly glass waste ) would be used, not metal wastes. Similarly, chemicals contaminated with solvents are coded AC210 (non-halogenated solvents) whereas correspondence between the European list of wastes code and the waste statistics nomenclature gives chemical preparation wastes. This is also the case for filtration wastes to be coded under chemical deposits and residues in the waste statistics nomenclature which, with some exceptions, are not identifiable in the OECD and Basel Convention lists (the contaminating substance is then given by the notifier). Among the rubrics of Annex VIII of the Basel Convention, those 16

17 coded A1010, A1020, A1030 and A1040, relating to wastes contaminated by hazardous metals may, for the reasons described above, have several matches in the waste statistics nomenclature. These few examples argue in favour of use of the European list of wastes code, when it is given. Grouping of all chemical wastes under a single rubric proposed in Annex II of the waste statistics regulation is a welcome step, in that it overcomes certain difficulties of correspondence between lists at the more refined level required by Annex I. The transboundary movement tracking system should provide satisfying or fairly satisfying information on imports and exports of wastes allowing coverage of the rubrics presented in Annex I of the waste statistics regulation for the following wastes: Spent solvents, hazardous. Acid, alkaline and saline wastes, it is possible to distinguish hazardous wastes from the others among the acids and bases, but there is a problem in isolating saline wastes among the rubrics of the lists specific to control of transboundary movements of waste. Used oils, hazardous. Spent chemical catalysts, hazardous. Chemical preparation wastes (mainly hazardous wastes: for the major categories of chemical wastes defined in the waste statistics nomenclature, there are matches with lists specific to control of transboundary movements. Satisfactory. Health care, veterinary and biological wastes, hazardous. Glass wastes, hazardous. Wood wastes, hazardous. Wastes containing PCBs, hazardous. Discarded equipment, (not including scrap vehicles and batteries and accumulators). Partially covered. Battery and accumulator wastes, hazardous with lead, others non-hazardous (recovery with statistical monitoring of external trade). Animal faeces, urine and manure, non-hazardous, limited to pigsty slurry. Household and similar wastes, non-hazardous (recovery with statistical monitoring of external trade). Common sludges, non-hazardous (recovery with statistical monitoring of external trade). Combustion wastes, mostly non-hazardous, difficulty in separating hazardous from non-hazardous (recovery with statistical monitoring of external trade). 17

18 Transboundary movements of waste in 2001 and 2002 according to waste statistics regulation categories The table below gives the results for transboundary movements in 2001 and 2002 subject to administrative tracking under the regulation on monitoring and control of transboundary movements of wastes, described in terms of the waste categories given in Annex I of Regulation 2150/2002. Movements of wastes in 2001 and 2002 controlled under the Basel Convention, breakdown in accordance with waste statistics nomenclature unit: tonnes Year 2001 Year 2002 Imports Exports Imports Exports 01.1 Spent solvents H Acid, alkaline or saline wastes E Used oils H Spent chemical catalysts E Chemical preparation wastes E Chemical deposits and residues E Industrial effluent sludges E Metallic wastes H Glass wastes H Wood wastes H Textile wastes H Wastes containing PCBs H Mixed and undifferentiated materials NH Batteries and accumulators wastes H Batteries and accumulators wastes NH Animal faeces, urine and manure NH Household and similar wastes NH Sorting residues NH Common sludges (except for dredging sludges) Mineral wastes (excluding combustion wastes, earth and sludges) Mineral wastes (excluding combustion wastes, earth and sludges) NH H NH Combustion wastes E H: Hazardous - NH: Non-hazardous - E: Entire scope of regulation (259/93). 18

19 Statistical monitoring of external trade in commodities Presentation of the external trade source in France General In France, it is the Direction Générale des Douanes et Droits Indirects (Customs and indirect taxes service) which establishes the trade balance. Each month, the Customs statistics department presents and comments the latest external trade results. Information on exchanges of commodities is gathered on the basis of déclarations d échanges de biens (DEB commodity exchange declaration) for trade with the 24 other Member States of the European Union, and customs declarations (SAD) for trade with other (so called third-party ) countries. Control and validation of data collected in this way is under the responsibility of the Customs information-technology department, in collaboration with other departments within the Customs Service. Around 4 million declared articles are dealt with in this way each month. Once validated, the declarations are integrated into the Customs database, allowing Customs Service statisticians to produce and disseminate results on external trade in a standardised form and to respond to requests for specific results. Excluded operations Among the operations excluded from declarations and likely to significantly limit the coverage provided by external trade in wastes, low-value operations must be mentioned. Trade with countries outside of the European Union ( third parties ) is not subject to declaration when values are less than and weight is less than one tonne. Trade with the other 24 EU Member States is not subject to declaration when, over one year, value is less than In order to obtain information that is as exhaustive as possible, an evaluation of low-value operations is included in the general FOB/FOB trade data set. Evaluations of this type, but at a more detailed level, are not carried out by the Customs statistics department. The Combined Nomenclature The Customs Cooperation Council's Harmonised Commodity Description and Coding System is a worldwide reference for nomenclatures for external statistics and Customs tariffs. Its legal status is that of an international agreement. It has been in application since 1 January The Combined Nomenclature (CN) is the European Union's commodity nomenclature, meeting requirements on statistics on external trade (both intra- and extracommunity) and for Customs tariffs. The CN is based on the harmonised system, which it incorporates and subdivides when necessary. Amendments to the CN appear each year and a publication presenting the CN and its updates is issued yearly. This also includes explanatory notes useful for interpretation of the CN. The CN is used by parties having to make administrative declarations. At its most detailed level, the CN contains around

20 items, each identified by an eight figure code. The Customs database therefore has data on commodity exchanges at the most detailed level of the CN. Selection of waste rubrics in the CN The CN covers all commodities, from amongst which those relating to wastes have to be distinguished. In some cases, a single CN rubric covers commodities that may, explicitly, be wastes or may be non-wastes for example, rubric , pigs', hogs' or boars' bristles and hair and waste thereof. It seemed preferable to us to exclude such rubrics from the list of wastes rubrics, as the non-waste proportion is likely to be the greater in terms of both amount and value. It must be pointed out that such cases are found most frequently in relation to agricultural and agro-food commodities. Agricultural and agro-food commodities also include rubrics covering by-products from these sectors for example, rubric , beet pulp with dry weight content equal to or greater than 87%. The waste statistics regulation is not explicit regarding agro-food industry by-products to be considered as wastes, and we have not received a clear answer to our questions on the subject. Examination of the rubrics of the European list of wastes and especially those in its Chapter 02, wastes from agriculture, horticulture, aquaculture, forestry, hunting and fishing, food preparation and processing would tend to exclude agriculture and agro-food industry by-products from the scope of the waste statistics regulation. Furthermore, at Community level, legal requirements govern the use of products from the agro-food industry that are unfit for human consumption as animal feed. Recovery of these by-products for animal feed should be encouraged and the qualifying of such commodities as waste is still perceived as penalising for livestock farmers, and would therefore run counter to the objective sought. We have therefore excluded from among the CN rubrics those relating to agricultural and agro-food industry by-products. Only rubrics that are explicitly wastes have been retained for example: , fish waste. The terms ash, scrap, residue, turnings, shavings and dust used in the CN categories were considered as referring to wastes. Furthermore, the CN rubrics of which the wording is used in the OECD's amber and green lists were selected. The list compiled in this way was compared with two other lists: one proposed by German colleagues, the other proposed by colleagues from the Czech Republic. These lists were disseminated at the workshop on waste import and export statistics within the framework of the waste statistics regulation, organised by the Umweltbundesamt (German federal environment agency), on 8 and 9 March 2004, in Berlin. Oversights in our list could therefore be corrected. Correspondence between CN waste rubrics and those of the waste statistics regulation Matching the waste categories of the CN with those of Annexes I and II of the waste statistics regulation posed no special difficulty. The proposed matches we established could be compared with those proposed by German and Czech colleagues, no divergence was found. A table given in Annex F of this report lists the waste rubrics of the CN with the matches with the waste categories of Annexes I and II of the waste statistics regulation. 20

21 The categories of wastes in Annexes I and II of the waste statistics regulation which are well covered by matching with the items of the CN are listed in the table below. Use of the Customs database gave the amounts of wastes imported and exported for 2001 to Certain CN rubrics make it possible, at least in theory, to track imports and exports of chemical wastes which, essentially, covers the monitoring carried out elsewhere under the regulation on control and monitoring of transboundary movements of waste. This is preferable, given the threshold on declarations for commodity trade. Used oils have a fairly high unit economic value, and can therefore be assumed to be relatively well covered by the external trade statistics system. 21

22 Waste external trade data for selected CN categories grouped per categories of Annex I of waste statistics regulation Source: Customs statistics department Unit: 1000 tonnes Imports Exports Used oils Metal wastes Glass wastes Paper and 07.2 cardboard wastes Rubber wastes Plastic wastes Wood wastes Textile wastes Batteries and accumulator wastes Combustion wastes Towards an assessment of the coverage provided by the external trade source Trade with the other 24 EU Member States is not subject to declaration when, during one year, trade is for less than It would be desirable to be able to obtain even an approximate estimate of the waste streams that escape declaration. To our knowledge, there is no simple method of obtaining such an estimate. However, one fairly inexpensive line of approach could be followed up using the annual survey files on the capacities of companies in the recycling sector (NACE and 37.20), to fairly easily estimate the share of exports represented by companies exporting less than per year. Such an estimate would only provide partial coverage of exports, as companies exporting waste are not all companies whose principal activity is recycling. Moreover, it should be pointed out that the annual company surveys do not cover companies with less than 20 employees. It seems, however, that companies with less than 20 employees must have a negligible impact, from the economic point of view, and especially where quantities of exports are concerned. A comparison of the exports in the recycling sector declared in 2002 with the annual survey of companies with waste exports, obtained from analysis of the extract from the Customs database made at our request, suggests that coverage of waste exports for the recycling sector is around 50 per cent. A more ambitious but also more promising line of action would be to calculate using the Customs database the ratio of revenue from waste exports to total export revenue, for 22