Exporting Waste from the UK to Poland — Cross-sector Customs and Environmental Regulations

Legal Basis — Post-Brexit the UK Has Its Own Legislation

Before Brexit, transboundary waste shipments from the United Kingdom to Poland were governed directly by EU Regulation (EC) 1013/2006 (the Waste Shipment Regulation). After 31 December 2020, the UK ceased to apply the EU regulation and reverted to its own rules — the Transfrontier Shipment of Waste Regulations 2007 (TFS) as subsequently amended.

In practice, the UK regulations broadly follow the Basel Convention on the Control of Transboundary Movements of Hazardous Wastes (to which the UK is a signatory), but they are not identical to the EU WSR. In particular, following the revision of the EU regulation (EU WSR 2024/1157, applicable from May 2026), the UK and the EU now operate separate procedures — the requirements on both sides must be checked.

Green List vs Amber List — The Key Distinction

All transboundary waste legislation is built around the division of materials into two lists, defined by the Basel Convention and implemented through the national TFS regulations:

Green List — Simplified Procedure

Green List wastes are materials considered non-hazardous to the environment or human health, destined for recovery (recycling), for which a simplified information procedure is sufficient. The exporter need only:

• Complete Annex VII (the information form), which must accompany every shipment.
• Confirm that the consignee in Poland holds the appropriate environmental permit to recover the specific waste type.
• Attach a contract between the notifier and the consignee.
• Submit a standard EX1 export customs declaration in the UK.

Typical Green List wastes in UK-Poland trade:

• Clean steel scrap (HS 7204)
• Waste paper and paperboard for recycling (HS 4707)
• Sorted PET bottles (HS 3915)
• Clean aluminium scrap (HS 7602)
• Copper scrap (HS 7404) — provided it is uncontaminated

Amber List — Prior Informed Consent

Amber List wastes require Prior Informed Consent (PIC) — written consent from the competent authorities of all countries involved in the shipment (the UK, any transit countries, and Poland as the country of destination). The PIC procedure involves:

1. Submitting a Notification application to the Environment Agency (EA) — the competent authority in England.
2. The EA assigns a Notification number and forwards the application to the Polish competent authority (the Chief Inspectorate for Environmental Protection or the relevant Regional Inspectorate).
3. The Polish authorities have 30 days to grant consent, grant conditional consent, or object.
4. Once consent has been received from all authorities, the EA issues a permit for the shipment.
5. Every individual shipment must bear the Notification number and a current Movement Document.

Typical Amber List wastes:

• Waste electrical and electronic equipment (WEEE) — mobile phones, computers, household appliances
• Mixed non-ferrous metal scrap (with contaminants)
• Mixed or contaminated plastic waste
• Asbestos waste and asbestos-containing materials
• Medical and pharmaceutical waste
• Lead-acid batteries and accumulators

The Role of the Environment Agency (EA)

In England, the Environment Agency (EA) is the Competent Authority for transboundary waste shipments. In Wales this role is performed by Natural Resources Wales, in Scotland by the Scottish Environment Protection Agency (SEPA), and in Northern Ireland by the Northern Ireland Environment Agency (NIEA).

The EA is responsible for:

• Receiving and processing Notification applications for PIC.
• Issuing Notification numbers for approved shipments.
• Checking Movement Documents at the border and at the receiving facility.
• Initiating enforcement proceedings in the case of illegal shipments.

Applications to the EA are submitted through the EDOC (Electronic Duty of Care) system. The fee for a Notification application ranges from £600 to £3,000 depending on the number of shipments covered by a single consent (framework consents covering multiple shipments over a year are available).

Step-by-Step Procedure — Exporting Waste from the UK to Poland

1. Classify the waste — check the EWC (European Waste Code, known as the LoW — List of Wastes in the UK) and determine whether the waste is on the Green List or the Amber List.
2. Check the consignee in Poland — the consignee must hold a valid environmental permit to treat/recover the specific waste type (an integrated permit or a permit to collect/process).
3. For Green List waste: complete Annex VII, sign a contract with the consignee, submit the EX1 in the UK — done.
4. For Amber List waste: submit a Notification application to the EA (via EDOC), await PIC (up to 30–70 days), obtain the Notification number, prepare a Movement Document for each shipment, submit the EX1.
5. EX1 customs declaration: export declaration in the UK CDS. In the goods description field, include the EWC code, HS code, waste description, and Notification number (where applicable). easyclearance.pl handles this part of the process.
6. Import into Poland: on the Polish side, waste for processing must be imported by an entity holding the relevant permit. Customs clearance in Poland (SAD + environmental documents).

Recyclable Materials — Specific Cases

Metal — Steel and Aluminium Scrap

Clean steel scrap (HS 7204) and aluminium scrap (HS 7602) without contaminants — typically Green List, EWC code 17 04 05 (iron and steel) or 17 04 02 (aluminium). With contaminants (paint, varnish, other metals) it may fall onto the Amber List.

Waste Paper

Clean waste paper (HS 4707) — Green List, EWC code 20 01 01 or 15 01 01. Contaminated or mixed waste paper — requires individual verification.

Plastics

Plastic waste (HS 3915) has been subject to significant regulatory changes since 2021. Clean, single-fraction sorted PE/PP/PET — may qualify for the Green List. Mixed or contaminated — Amber List. From 2025, the EU has imposed additional requirements on imports of mixed plastic waste.

Customs Clearance Costs for Waste Shipments

EX1 export clearance for waste shipments: from £45 to £120 per customs declaration. Environmental costs must be added (EA Notification fee: £600–£3,000) as well as the costs of preparing the Annex VII documentation or the Movement Document. The clearance price ranges quoted are indicative — a precise quotation is provided once documents have been submitted.

Official Sources

• GOV.UK: Importing and exporting waste — Environment Agency / DEFRA, 2026
• GOV.UK: Transfrontier Shipment of Waste — EA guidance — Environment Agency, 2026
• GOV.UK: Waste import and export guidance — DEFRA, 2026

Frequently Asked Questions (FAQ)

What waste can legally be exported from the UK to Poland?

From the UK to Poland it is permissible to export waste destined for recovery (recycling) — both from the Green List and the Amber List, though the formal conditions differ. Green List waste (e.g. clean metal scrap, waste paper, sorted PET) requires only an Annex VII form and an EX1 customs declaration. Amber List waste (e.g. WEEE, mixed plastics, hazardous waste) requires Prior Informed Consent (PIC) and a Notification number from the Environment Agency. Exporting waste solely for disposal (landfill, incineration) to an EU country is generally prohibited under the TFS Regulations.

What is the difference between the Green List and the Amber List for waste?

The Green List contains non-hazardous waste destined for recovery — simplified procedure with an Annex VII form. The Amber List contains waste requiring the full Prior Informed Consent (PIC) procedure: a Notification application to the Environment Agency, consent from the competent authorities of the destination and transit countries, a Notification number, and a Movement Document for every shipment. The division is based on the Basel Convention and its implementation in the UK Transfrontier Shipment of Waste Regulations.

What permits are required to export waste from the UK?

For Green List waste: no special environmental permit is required — an Annex VII form and an EX1 customs declaration are sufficient. For Amber List waste: a Notification application must be submitted to the Environment Agency (EA) and a Notification number obtained after Prior Informed Consent (PIC) has been granted by the UK and Polish authorities. The EA application fee ranges from £600 to £3,000. The consignee in Poland must hold a valid environmental permit to process the specific waste type.

What is the role of the Environment Agency in waste exports?

The Environment Agency (EA) is the Competent Authority in England for transboundary waste shipments. The EA receives Notification applications for Amber List waste, issues Notification numbers, coordinates information exchange with the Polish Chief Inspectorate for Environmental Protection (GIOS) or the relevant Regional Inspectorate, checks reports on completed shipments, and inspects Movement Documents. Illegal transboundary waste shipments without a Notification number are punishable by a fine of up to £50,000 or up to two years' imprisonment.

What does the Notification procedure for Amber List waste involve?

The Notification procedure involves: (1) the exporter submits an application to the EA via the EDOC system; (2) the EA checks completeness and forwards it to the Polish competent authority (GIOS or the Regional Inspectorate); (3) the competent authorities of the destination and transit countries have 30 days to grant consent or object (extendable to 70 days); (4) once PIC has been obtained from all parties, the EA issues a consent with a Notification number valid for up to one year (multiple shipments permitted); (5) every shipment must be accompanied by a Movement Document bearing the Notification number.