Three checks before your first shipment to Ukraine

Break preparation into three decisions, made before setting the loading date:

Step 1. “Non-hazardous waste” – what do you actually need to establish?

The relevant legal term is generally non-hazardous waste. Calling waste “neutral” does not identify a transboundary shipment procedure. An EWC/LoW code without an asterisk indicates its classification in the European List of Waste, but does not establish whether the shipment is “green-listed” under export rules.

Ask the customer for the waste’s origin, composition and contamination level, its EWC/LoW code, proposed Basel/OECD entry, weight, consignee, facility name and recovery operation code. The number 15 01 02 or 19 12 04 alone is insufficient to identify the applicable procedure.

Step 2. What do EU export rules mean for Ukraine in 2026?

Ukraine is not an OECD member. Until 20 May 2027, exports of certain green-listed wastes from the EU to non-OECD countries remain subject to Commission Regulation 1418/2007, as amended, notably by Regulation 2021/1840. In the table for Ukraine, B3011 appears in column b (prior written notification and consent), while other Annex III wastes and eligible Annex IIIA mixtures appear in column d (other control procedures in the destination country). Later restrictions on B3011 must also be considered. Electrical and electronic waste is subject to separate export restrictions; do not apply the green-list route automatically to GC010/GC020.

For other eligible green-list entries, Ukraine’s column d means national controls in addition to EU information requirements. “Other control procedures” does not justify omitting Annex VII where EU Article 18 applies.

Step 3. Who arranges Ukraine’s e-Zelenka?

The Ukrainian service “Висновок на транскордонне перевезення відходів, що включені до Зеленого переліку відходів”, known as e-Zelenka, provides an administrative opinion for shipments of waste on Ukraine’s Green List. Applications are submitted electronically through ЕкоСистема. Coordinate this with the Ukrainian consignee and check the scope of the issued document before setting a loading date.

According to the official service information, attachments include a foreign trade contract with specifications, information on the waste’s origin and composition, and documentation for Ukrainian customs classification. Imports for recovery also require facility details, the recovery operation code, the facility’s permit register number for the relevant waste treatment, and an accredited laboratory’s opinion confirming the absence of hazardous properties.

Depending on the material, additional documents may be required, such as information on radiological checks and explosion risks for metals, or a phytosanitary certificate for plant waste. The service information states a processing time of 10 working days and no administrative fee; this does not guarantee that an incomplete application will allow transport to be arranged within ten days.

B3011: why does the shipment date change the answer?

Special rules apply to plastic waste genuinely classified under entry B3011. GIOŚ, Poland’s Chief Inspectorate of Environmental Protection, states that from 21 May 2026 exports from the EU to a non-OECD country require prior written notification and consent. This includes Ukraine. Preparing Annex VII without obtaining the required consents does not authorise departure.

From 21 November 2026 until at least 21 May 2029 exports of B3011 from the EU to non-OECD countries are prohibited. Ukrainian import consent, a contract with the consignee or a ready truck does not override the ban. Resuming exports later will depend on the new system’s conditions and country list; it will not happen automatically.

An EWC code for “plastics” does not establish a B3011 classification. First confirm that the particular consignment meets its criteria. Otherwise, a different procedure or prohibition may apply.

What changes from 21 May 2027?

For waste other than B3011, Regulation 1418/2007 is repealed with effect from 21 May 2027. Under the new system, exports of specified non-hazardous wastes from the EU to a non-OECD country will depend on compliance with Regulation 2024/1157, including the country and waste stream being on the Commission’s list and the relevant treatment and facility requirements. This includes the independent facility audit required by Article 46, generally conducted no more than two years before export.

Ukraine has submitted a request to receive specified wastes from the EU. A request does not establish inclusion on the list or permission to receive any waste. On 18 September 2026, the Commission published a draft list, open for feedback until 16 October 2026; its latest announcement anticipates the first final list by the end of 2026. A draft is not an export authorisation. Before planning shipments from 21 May 2027, check the adopted list, the relevant waste entry and continuing Ukrainian import requirements. Article 41(3) sets 21 November 2026 as the adoption deadline; the latest Commission announcement refers to the end of 2026, so the actual adoption and entry into force must be checked.

Which documents should you prepare before departure?

No single document set fits every shipment. For lawful exports from the EU to a Ukrainian recovery facility, check at least:

• ✓ the EWC/LoW code, confirmed Basel/OECD entry, composition and recovery purpose;
• ✓ the appropriate Annex VII and Article 18 contract or PIC documents and valid consents, depending on the procedure;
• ✓ the Ukrainian e-Zelenka, where required, and the facility’s current authorisation for that waste type and process;
• ✓ transport documents, the contract and customs documents agreed with the organiser and customs broker;
• ✓ the carrier’s authorisations in the loading country and every transit country, including BDO registration when transporting waste through Poland;
• ✓ consistency of waste, weight, route, parties and facility details across all documents.

If a route from another EU Member State passes through Poland, also check national transport monitoring obligations for the particular category of goods. Do not assume that one waste form replaces export customs clearance and transport documents.

Three examples before accepting an order

1. Sorted paper for recovery

If the consignment meets the conditions of the relevant green-list entry, check Ukraine’s column d in Regulation 1418/2007, Article 18 requirements, the new Annex VII and contract, and Ukraine’s e-Zelenka and facility permit. “Recovered paper” without composition details is not enough to determine the procedure.

2. Plastic waste described as B3011

Confirm the classification first. For shipments from 21 May 2026, check the required notification; from 21 November 2026 until at least 21 May 2029, exports to Ukraine are prohibited. A change in the shipment date may determine whether the operation is permitted.

3. “Ordinary waste” with only a six-digit code

Ask for further information. Without a shipment-list entry, composition, recovery purpose and facility details, you cannot confirm Annex VII eligibility or assume Ukraine will permit import. In 2027, the new Commission list must also be checked.

A load for Ukraine, but only a waste code?

Send us the EWC code and proposed Basel/OECD entry, the consignment’s description and composition, loading and transit countries, planned date and Ukrainian facility details. We can help check the EU procedure and identify the documents to agree with the consignee before departure.

FAQ – shipping waste from the EU to Ukraine

Official sources and further reading

1. Regulation (EU) 2024/1157, particularly Articles 18, 39–42, 46 and the transitional provisions
2. Commission Regulation (EC) 1418/2007 – export destination table for non-OECD countries
3. Commission Regulation (EU) 2021/1840 – amendment to the Ukraine table, point 69
4. GIOŚ – green-listed waste, non-OECD exports, Annex VII and the DIWASS transition
5. GIOŚ – notification and the B3011 export ban for non-OECD countries
6. Ukraine, ЕкоСистема – e-Zelenka, required attachments and processing time
7. European Commission – Ukraine’s request and export rule changes from May 2027
8. BDO – registration obligations for carriers transporting waste through Poland
9. European Commission – draft non-OECD country list, 18 September 2026
10. European Commission – DIWASS launch and paper transition
11. German Environment Agency – country table, Ukraine
12. Official consolidated Regulation 2024/1157, 30 July 2026