Brussels publishes the draft list of non-OECD countries that may keep importing European waste after May 2027, and delivers a pointed assessment of the Turkish plastics route that will stay open when the November ban lands
BRUSSELS, 21 September 2026 | Peacock Tariff Consulting Trade Desk
The European Commission has published the draft list of non-OECD countries that could be authorised to keep importing non-hazardous waste from the European Union after May 2027, opening a consultation that runs until 16 October and starting the clock on one of the most consequential reorganisations of global secondary materials trade in a decade.
Alongside the draft list, published on 18 September, the Commission released its assessment report on the sustainable management of plastic waste exported from the European Union to Türkiye. The report finds that Türkiye has strengthened its legislation and enforcement, and then identifies three areas where Brussels wants more: transparency on data, information on implementation, and clarity on governance.
The two documents together define how roughly 32 million tonnes of annual European waste exports will be routed from late 2026 onward, and they arrive at a moment when the recycling and secondary raw materials trade has very little slack in it.
The regulation and its two deadlines
The framework is Regulation (EU) 2024/1157, the recast Waste Shipment Regulation, adopted in 2024 and in force since 20 May that year. It was designed, in the Commission’s framing, to ensure that the European Union does not export its waste challenges to non-European Union countries.
It contains two separate prohibitions on two separate dates, and conflating them is the single most common error in commentary on the regime.
The first is narrow and imminent. Exports of plastic waste from the European Union to non-OECD countries are banned from 21 November 2026. That is sixty-one days away. It applies to plastic waste specifically and to non-OECD destinations specifically.
The second is broad and later. As a general principle, the European Union will no longer export waste of any kind to non-OECD countries from 21 May 2027. This applies across waste streams, not just plastics.
The second prohibition carries an exception, and the exception is what was published this month. Exports may be authorised to non-OECD countries that explicitly request to continue receiving waste from the European Union and demonstrate that they can manage it sustainably. Thirty-two countries submitted such requests. The Commission has assessed them, including each country’s capacity to manage waste sustainably, and has summarised the outcome in a report published with the draft list.
Stakeholders have until 16 October to respond through the online consultation. The first authorised list will be established by the end of 2026, and it will be updated regularly and at least every two years, with countries that miss the first cut able to apply or reapply.
The numbers underneath
The Commission’s background data gives the scale of what is being restructured.
The European Union exported 32 million tonnes of waste in 2025. Around 40 percent of those exports went to non-OECD countries. That is roughly 12.8 million tonnes of material that, from 21 May 2027, will either need its destination country to appear on the authorised list or will need to find a home elsewhere.
On plastics specifically, the European Union generates around 40 million tonnes of plastic waste a year and exports between 1 and 1.5 million tonnes annually. In 2025 the total was 1.4 million tonnes, split roughly half to OECD destinations and half to non-OECD destinations.
The destination breakdown for 2025 is where the commercial exposure becomes visible. Türkiye took 510,000 tonnes, by a wide margin the largest single destination. Malaysia took 276,000 tonnes, Indonesia 215,000 tonnes, Vietnam 137,000 tonnes and the United Kingdom 108,000 tonnes.
Apply the November 2026 prohibition to that list and the picture is immediate. Malaysia, Indonesia and Vietnam are non-OECD countries. Together they accounted for 628,000 tonnes of European plastic waste in 2025, roughly 45 percent of the total. All of that becomes prohibited on 21 November this year, with no authorisation exception available, because the plastics ban to non-OECD destinations is absolute rather than conditional.
Türkiye and the United Kingdom are OECD members. Their 618,000 tonnes combined are unaffected by the November deadline.
Why Türkiye got its own report
That arithmetic explains the second document.
The Waste Shipment Regulation requires the Commission to monitor exports of plastic waste to OECD countries and to assess whether importing countries can manage that waste in an environmentally sound manner. The Commission focused its first such assessment on Türkiye on the straightforward basis that Türkiye is the main OECD destination for plastic waste exported from the European Union.
It is also, on the numbers above, the destination most likely to absorb displaced volume after 21 November. If 628,000 tonnes currently going to Southeast Asia needs a new home and Türkiye is the largest available OECD outlet, the pressure on the Turkish route is obvious before a single tonne moves.
The assessment itself is balanced in tone. It acknowledges that Türkiye has strengthened its legislation on plastic waste management and imports, and that it has taken steps to improve enforcement, including through increased controls and higher fines. Turkish policy on imported plastic waste has tightened substantially since the disruptions of 2021, and the report credits that.
It then sets out three areas where further information and progress are needed.
The first is a lack of transparency on data covering plastic waste generation and treatment, including on the impact of imported waste on the management of domestically generated waste. That last clause is pointed. It asks whether imported European material is displacing the recycling of Turkish domestic waste, which would invert the environmental logic of the trade entirely.
The second is insufficient information on how legislation is being implemented to prevent environmental harm linked to imported plastic waste. Legislation on the statute book and legislation enforced at a sorting facility in an industrial zone are different things, and the report says Brussels cannot yet see the second.
The third is unclear governance arrangements for plastic waste management, a finding about institutional responsibility rather than about rules or enforcement capacity.
The Commission said it looks forward to engaging with Türkiye’s competent authorities on the findings, that it will continue monitoring exports, and that it remains committed to strengthening bilateral cooperation on waste management.
What this is, in trade policy terms
It is worth being precise about the instrument, because it does not fit the usual categories.
This is not a tariff. No duty is imposed and no revenue is collected. It is a quantitative export restriction, conditioned on the regulatory capacity of the destination country, administered through a listing mechanism with a periodic review cycle.
Instruments of that shape have become steadily more common in European trade policy. The Carbon Border Adjustment Mechanism conditions import access on carbon accounting. The deforestation regulation conditions it on supply chain traceability. The forced labour regulation conditions it on production conditions. The Waste Shipment Regulation conditions export access on the destination’s waste management capacity.
The common thread is that market access now depends on a regulatory assessment of conditions outside the European Union, made by European institutions, on a timetable European institutions control. For the countries being assessed, that is a significant transfer of commercial consequence to an administrative process in which they are applicants rather than negotiating parties.
The thirty-two applicant countries have no appeal mechanism against an adverse listing decision comparable to a WTO dispute over a tariff. They can reapply at the next review, which is at least two years away.
Who is exposed
Several groups of businesses face concrete consequences.
European waste management and recycling companies are the most directly affected. Firms that collect, sort and export plastic waste to Malaysia, Indonesia or Vietnam have sixty-one days to redirect those flows. The options are limited: OECD destinations, principally Türkiye and the United Kingdom, or domestic European processing capacity that does not currently exist at the required scale.
The likely commercial result is downward pressure on the gate price paid for mixed and lower-grade plastic waste in Europe, because the alternative outlet is disappearing. For municipalities and waste collection authorities whose budgets depend on materials revenue, that is a fiscal question arriving in the middle of a financial year.
European manufacturers using recycled content face the opposite pressure. If more plastic waste stays in Europe, more recyclate should eventually be produced domestically, which supports the recycled content targets embedded in European packaging legislation. That is the policy’s intent. The transition period, however, is likely to feature a gap between the material arriving and the capacity to process it.
Recyclers in Malaysia, Indonesia and Vietnam lose a feedstock source on 21 November. The industries that grew around imported European plastic waste in those countries have limited time to restructure, and the volumes involved, 276,000 tonnes, 215,000 tonnes and 137,000 tonnes respectively, are substantial relative to their domestic collection systems.
Turkish recyclers face the opposite and equally awkward problem: a probable increase in available European feedstock at precisely the moment when the Commission has put their sector under formal monitoring and named three deficiencies it wants addressed.
Shipping lines and logistics operators serving the Europe to Southeast Asia waste trade lose a cargo category. Waste is low-value backhaul freight on routes where the loaded direction runs the other way, and removing it changes the economics of those services at the margin.
The compliance mechanics
For businesses moving waste across European borders, several operational points follow.
Classification determines everything. Whether a consignment is waste or a product, and whether it is hazardous or non-hazardous, decides which rules apply. The distinction between plastic waste and plastic material for further processing has been contested at the frontier for years and the November deadline raises the stakes on getting it right. Misclassification to preserve a shipping route is precisely what enforcement authorities will be looking for.
Destination status must be verified against the correct list. The OECD and non-OECD distinction governs the November deadline. The authorised list governs the May 2027 deadline. A country can be non-OECD and authorised, in which case non-plastic waste may still flow to it after May 2027 while plastic waste may not flow to it after November 2026. Getting those two regimes confused will produce detained containers.
The consultation is open and it matters. Until 16 October, any stakeholder can make submissions on the draft list. Businesses with material commercial exposure to a specific destination country have a direct interest in whether that country appears, and this is the only formal opportunity to say so before the list is fixed at year-end.
Contracts need review. Long-term waste offtake agreements with processors in affected destinations will become impossible to perform on the relevant dates. Force majeure and change-in-law provisions determine who bears that cost, and the answer is often unclear in contracts drafted before 2024.
Transitional stock needs planning. Material in transit or in port storage around 21 November faces a hard cut-off. Shipment scheduling in October and early November should be managed with the deadline as a fixed constraint rather than a target.
The OECD loophole, and why it is not one
Commentary since the publication has fixed on a point that is correct but frequently misstated: plastic waste exports to Türkiye are not banned by the November 2026 restriction, because Türkiye is an OECD member and the restriction applies to non-OECD destinations.
That is accurate as far as it goes. It is misleading as a conclusion.
The Waste Shipment Regulation does not leave OECD destinations unregulated. It requires the Commission to monitor plastic waste exports to OECD countries and to assess whether the importing country can manage that waste in an environmentally sound manner. Where that assessment is negative, the Regulation provides mechanisms to restrict the flow. The Türkiye report published on 18 September is the first exercise of that monitoring function, and the three deficiencies it names are the record against which any future restriction would be justified.
So the Turkish route is not a permanent exemption. It is a conditional continuation subject to an assessment that has just begun and that has already identified concerns. Anyone building a commercial plan on redirecting Southeast Asian volumes to Türkiye should read the report as a warning rather than a green light.
The more general point is that the OECD and non-OECD distinction in the Regulation is a proxy for waste management capacity rather than a judgement in itself. Where the proxy and the reality diverge, the Regulation gives the Commission tools to act on the reality. The direction of travel across every recent piece of European market access legislation has been from category-based rules toward evidence-based assessment, and waste shipments are following the same path.
What the thirty-two applications tell us
The fact that thirty-two non-OECD countries formally applied to keep receiving European waste is itself worth sitting with.
Waste imports are frequently framed in public debate as something imposed on developing countries by rich ones. The application process inverts that framing. Thirty-two governments looked at a European prohibition taking effect in May 2027 and asked to be exempted from it.
The reason is that the trade is commercially valuable to them. Imported secondary raw materials feed processing industries that employ people, generate export revenue when the recyclate is sold on, and in some cases supply domestic manufacturing that would otherwise import virgin material at higher cost. Where the recycling is done competently, the environmental case is positive as well: reprocessing plastic uses substantially less energy than producing it from petrochemical feedstock, and the emissions saving accrues globally regardless of where the reprocessing happens.
The problem the Regulation addresses is not the trade in principle. It is the fraction of it that ends in open burning, unlined landfill or riverine discharge, and the difficulty of telling from a customs declaration in Rotterdam which fraction a given container belongs to.
The authorisation mechanism is an attempt to resolve that at country level rather than container level, which is administratively tractable but blunt. A country with excellent facilities and poor governance may fail. A country with adequate governance and mediocre facilities may pass. Firms operating good facilities in countries that do not make the list will lose access to European feedstock regardless of their own standards.
That is a real cost of the design and it has no remedy inside the current framework other than reapplication at the next review.
The wider picture
This regime is the European Union’s answer to a two-decade pattern in which developed economies exported the downstream consequences of their consumption to countries with less capacity to manage them. The Commission is explicit about the reasoning: waste exported from the European Union is often managed in conditions much less environmentally sound than in Europe, which is particularly problematic in developing and emerging countries that already face challenges dealing with their own waste and are expected to see the highest growth in waste generation in future. In some cases, the Commission notes, waste imports from developed countries undermine progress toward better management of domestically generated waste.
The policy logic is sound and the direction is not seriously contested. The implementation risk sits in the gap between prohibition and capacity.
Europe generates around 40 million tonnes of plastic waste a year and currently exports 1 to 1.5 million tonnes of it. Removing the export route does not by itself create the sorting, washing and reprocessing capacity to handle the retained material. If that capacity does not arrive on the same timetable as the prohibition, the retained waste goes to incineration or landfill, which is environmentally worse than competent recycling abroad and no better than incompetent recycling abroad.
The Türkiye assessment is where this tension is most visible. Brussels has simultaneously closed the non-OECD plastics route, identified Türkiye as the destination that will absorb the displacement, and published a list of concerns about Turkish capacity. Those three positions are coherent only if Turkish capacity and governance improve on a short timetable, which is what the Commission’s stated commitment to bilateral engagement is presumably intended to achieve.
What to watch
Three dates structure the next fifteen months.
16 October, when the consultation closes and the content of stakeholder submissions begins to shape the final list.
21 November, when the plastics prohibition to non-OECD destinations takes effect, and when the redirection of roughly 628,000 tonnes a year of European plastic waste begins to show up in port statistics and gate prices.
End of 2026, when the first authorised list is established, determining which of the thirty-two applicants keeps access to European waste from May 2027.
Beyond those, the question worth tracking is whether the Commission’s monitoring obligation for OECD destinations produces further assessments. Türkiye was first because it is largest. The United Kingdom, at 108,000 tonnes in 2025, is the next OECD destination of any size, and any post-November increase in its intake would place it in scope for the same treatment.