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Green list or amber list? Why the EWC code alone is not enough
A customer gives you waste code 15 01 02 or 19 12 04 and says: “It is just ordinary plastic; Annex VII will do.” Is that enough to accept the load and set off?
The code alone cannot settle the question. This guide explains how to assess the specific waste, route and receiving facility, and then select the correct procedure.
This guide covers EU waste shipment rules. The GIOŚ information describes Polish administrative practice; confirm the requirements of the competent authorities for each route.
Three checks before choosing Annex VII
Before accepting an order, check these three elements in turn:
Two coding systems — two different questions
| System | Example | What does it establish? |
|---|---|---|
| European List of Waste — EWC/LoW | 15 01 02, 19 12 04 | The type of waste for record-keeping purposes and whether it is classified as hazardous or non-hazardous. This is not itself the green list governing shipments. |
| Basel/OECD entries and Annexes III, IIIA, IIIB and IV | e.g. B1010 for certain metal scrap; EU3011 for certain plastic waste shipped within the EU | Together with other conditions, these determine whether the shipment follows the information procedure or requires prior notification and consent. |
In practice, the “green list” refers to waste covered by Annex III to Regulation 2024/1157; Article 18’s information procedure may also cover certain mixtures under Annex IIIA and waste under Annex IIIB, provided all the requirements are met. The “amber list” comprises waste listed in Annex IV, subject to prior written notification and consent. Within the EU, waste destined for disposal also requires notification, even where the material description might match a green-listed entry. GIOŚ: when notification is required.
For ordinary shipments for recovery under Article 4(4), the Article 18 information requirements apply when the quantity exceeds 20 kg. Laboratory analyses and experimental treatment trials have separate conditions under Article 4(5).
There is also a third situation: waste has no applicable single entry in these annexes, or it is a mixture not covered by an exemption. That does not make it “amber-listed”, but shipments for recovery will generally still require notification and consent. Check any statutory exceptions separately. GIOŚ: unlisted waste and mixtures.
Five steps: how to choose the procedure before loading
1. Identify what is actually in the load
Request the EWC/LoW code, the waste’s origin, a detailed description, composition, and information on impurities and contaminants. For plastics, identify the polymers and any other materials; for sorted waste fractions, establish the actual composition rather than relying on a trade name. Evidence may include a specification, laboratory results or sorting-process records. Never assign a Basel/OECD entry from the title of a load offer alone.
2. Match the exact annex entry
Read the full Basel/OECD entry and the applicable Annex III, IIIA, IIIB or IV to Regulation 2024/1157. Check its wording, scope, exceptions and destination-specific restrictions. A mixture of several green-listed wastes does not automatically become green-listed: to qualify for the information procedure, it must fit a relevant Annex IIIA entry or a single applicable entry and satisfy its conditions. The European Commission distinguishes EU3011, EU48 and AC300 for different plastic fractions shipped within the EU; separate rules, including those governing B3011, apply beyond the EU. Commission: plastic waste shipments.
3. Assess contamination, hazardous properties and POPs
Finding a seemingly matching green-list description is not the end of the assessment. Under Annex III, contamination may prevent use of Article 18 if it sufficiently increases the risks associated with the waste or prevents environmentally sound recovery. Check hazardous properties and the presence of persistent organic pollutants (POPs): if a relevant concentration limit in Annex IV to Regulation (EU) 2019/1021 is reached, prior notification and consent may be required even if the waste is not classified as hazardous. Regulation 2024/1157: Article 4 and Annex III.
There is no single universal permitted contamination percentage for all waste. The exact entry, characteristics of the waste and feasibility of environmentally sound recovery matter; where specific criteria apply to an entry, check the current rules. Commission: work on contamination criteria.
4. Check the purpose and the actual receiving facility
Establish whether the waste is destined for recovery (R) or disposal (D), who will receive it, and which operation will actually be performed. The Article 18 information procedure is designed for certain shipments for recovery; do not select it simply because the waste is theoretically recyclable. Within the EU, shipments for disposal are prohibited in principle; where the conditions of Article 11 allow consent, the PIC procedure applies. Commission: principal shipment procedures.
5. Review the destination and every transit country
Specify the countries of dispatch, transit and destination. Green-listed waste cannot always travel on Annex VII to any destination. For example, since 21 May 2026, plastic waste exports from the EU to third countries, including OECD countries, are subject to a specific prior notification and consent procedure; within the EU, qualifying EU3011 waste may fall under Article 18. Exports to non-OECD countries face additional prohibitions and transitional rules. Check the current import and transit rules and the carrier’s national authorisations. Commission: plastic waste rules; GIOŚ: shipment destinations. From 21 November 2026, plastic waste exports to non-OECD countries will be banned, with the prohibition in place at least until 21 May 2029.
Examples: 15 01 02 and 19 12 04 — what can we reliably conclude?
| EWC/LoW code | What the code tells you | What else you need to know |
|---|---|---|
| 15 01 02 | Plastic packaging. | Which polymers are present? Is the material sufficiently homogeneous and free of problematic impurities? Which shipment entry fits the consignment, and where is it going? |
| 19 12 04 | Plastics and rubber from mechanical waste treatment. | What proportions of plastics and rubber are present? Which polymers and impurities? Does the consignment meet the conditions of one entry or an applicable mixture entry? |
In either case, the right answer to “Can I use Annex VII?” is: send the description and composition of the actual consignment, the route and the receiving facility. We do not claim that all waste coded 19 12 04 requires notification or that all 15 01 02 waste qualifies for the green-list procedure. These examples show what the code alone cannot establish. Commission: plastic waste criteria.
What documents follow from the classification?
| Assessment outcome | Procedure for a typical intra-EU shipment | What should be prepared? |
|---|---|---|
| Waste meets Annex III or IIIB requirements; an eligible mixture meets Annex IIIA | For recovery: Article 18 information procedure, subject to the remaining requirements and restrictions. | New Annex VII form, an appropriate Article 18 contract and the required details of the parties and facility. |
| Waste listed in Annex IV | Prior written notification and consent (PIC). | Notification, consents from the competent authorities concerned, and the appropriate movement document. |
| No applicable single entry, or a mixture not covered by an exemption | Generally PIC; do not automatically label the waste “amber-listed”. | Clarify the classification and complete the notification procedure before shipment. |
| Waste destined for disposal within the EU | Within the EU, shipments for disposal are prohibited in principle; where the conditions of Article 11 allow consent, the PIC procedure applies. | Verify that the shipment is permitted and obtain the required consents before dispatch. |
Poland — GIOŚ guidance: From 21 May to 31 December 2026, GIOŚ accepts the new paper Annex VII outside DIWASS for Article 18 shipments; a contract complying with the new Article 18 is also required. From 1 January 2027, GIOŚ indicates that green-list shipments must be handled through DIWASS. New PIC notifications follow the electronic procedure applicable from 21 May 2026. Under Article 85(3), the previous Regulation (EC) No 1013/2006 continues to apply where the notification was submitted and the destination authority acknowledged receipt before that date. GIOŚ: Annex VII transitional arrangements; GIOŚ: PIC notifications.
Where the competent authorities of dispatch and destination disagree on classification under Annexes III, IIIA, IIIB or IV, do not resolve the dispute yourself in favour of Annex VII. Regulation 2024/1157 provides for prior notification and consent in that situation (Article 29(4)).
FAQ — frequently asked questions
There is no asterisk beside the waste code. Does that automatically mean green-listed?
No. The asterisk relates to classification under the European List of Waste; the cross-border procedure also depends on the shipment entry, composition, treatment operation and destination.
Is every mixture of hazardous or non-hazardous waste “amber-listed”?
No. Certain mixtures listed in Annex IIIA may qualify under Article 18; others require PIC even without their own Annex IV entry. Check the precise composition and applicable entry.
Is EU3011 enough to export plastic waste outside the EU?
No. EU3011 is a specific entry used for certain intra-EU shipments. Exports beyond the EU face separate restrictions, including PIC from 21 May 2026. Commission: rules by destination.
What information is needed to confirm the classification?
Start with the EWC/LoW code, the origin and composition, any test reports or specifications, quantity, route and transit countries, receiving facility and planned R/D operation. Those details are needed to check the annex entry before selecting Annex VII or PIC.
Only have an EWC code and unsure whether the load can move?
Send us the code, waste description and composition, dispatch and destination countries, transit countries and receiving facility. Permitra can help classify the specific shipment and establish the correct procedure before loading.
Official sources and further reading
- Regulation (EU) 2024/1157, Articles 4, 18 and 29 and Annexes III, IIIA, IIIB and IV.
- GIOŚ, shipments of green-listed waste.
- GIOŚ, prior written notification and consent procedure.
- European Commission, plastic waste shipment rules.
- European Commission, implementation of Regulation 2024/1157.
- GIOŚ: Annex VII transitional arrangements (Poland).
- GIOŚ: DIWASS and earlier PIC notifications (Poland).