May 26, 2023

Takin’ out the trash: How do transnational waste traffickers operate?

In 2020, 282 containers full of mixed waste bales sailed from Salerno, Italy, to Sousse, Tunisia, in four shipments. Italian customs did not raise any flags. Customs classified them as CA, or automated control (controllo automatizzato in the local language), simply meaning no control.

Back then, the COVID-19 pandemic was kicking, and officials relaxed scrutiny of goods between countries. But even outside global emergencies, only a tiny portion of outbound containers undergo some control. In Italy, it’s roughly 2%.

“We run very few checks because controlling in an excessive and massive manner is unthinkable,” the former head of the Salerno customs office, Maurizio Pacelli, told Mongabay. “Otherwise, no goods would leave.”

However, those seemingly innocuous 282 containers would erupt into an international scandal, leading to protests, the arrest and the sentencing of six Tunisian officials, and a lengthy dispute between Italy and Tunisia on waste repatriation. There was even a fire that may have destroyed evidence. In Italy, prosecutors are still investigating the responsibilities of a broker, the exporting company, Sviluppo Risorse Ambientali (SRA) and the officials who authorized the shipment, among others.

Globalization requires goods to move fast, even at the expense of giving some illicit cargo the go-ahead. In 2021, around 851 million containers on ships carried about 11 billion metric tons of goods around the globe, according to data from the United Nations Conference on Trade and Development. Not all of that was consumer goods: some was waste and scrap shipped from one country to another, often from wealthier economies to poorer ones. In 2021, 1.5% (169.5 million metric tons) may have been waste and scrap, according to U.N. Comtrade data.

In the same year, according to Eurostat, 68 million metric tons of waste traveled within EU borders, while the EU shipped 33 million metric tons of waste to non-EU countries, coming to nearly 20% of the global waste trade. Within the EU, the main routes flow to Germany, the Netherlands and Belgium, which then often export it eastward to countries like Poland, the Czech Republic and Slovenia, to name a few. This is easily done, given an absence of border controls in the EU.

For destinations outside the EU, China used to be the largest recipient of Western waste.

“China has always been, let’s say, our relief valve,” Antonio Pergolizzi, a waste analyst, said. “Mostly for low-quality plastic waste made of nonrecyclable polymers.”

But in 2018, China stopped taking other countries’ trash. The trend shifted to other Asian and North African countries. When shipping internationally, most national customs administrations use an electronic system to determine the amount of scrutiny placed on the shipment, which isn’t always affected by whether or not it’s waste.

But as the EU is negotiating stricter regulations on transboundary waste shipments, things might change.

Data from the Shipment of Waste Enforcement Actions Project run by the European Union Network for the Implementation and Enforcement of Environmental Law to up the amount of inspections offers an idea of the numerous violations in this sector: In 2021, 46% of shipments pulled for inspection were waste; of these, between 23 and 29% were illegal in some way. These figures come with caveats, as at the time they were included in a recent report, they lacked data from several countries. In general, inspection rates vary considerably depending on environmental regulators and customs’ focus and whether they use intelligence sources.

With China no longer taking waste and trash piling up, some EU countries began to run into trouble.

In 2017, Italy saw an outbreak of fires at waste facilities or illegal dumping in empty warehouses. Between 2017 and 2019 officials documented 239 of these incidents across Italy, according to a parliamentary inquiry committee on illicit activities in waste management.

After the fires faded, new destinations emerged. Since Italy has only 37 incinerators or waste-to-energy plants, mostly located in the north, and landfills are expensive (about 200 euros, or $225, per metric ton), a significant portion of the waste ends up abroad.

One of the issues is the fraction of plastics that aren’t currently easily recyclable. “We have reached a very high percentage of separate collection,” Renato Nitti, Trani chief prosecutor, who has long investigated waste trafficking, said. But “the cycle of plastic waste management is not complete throughout Italy.”

And this is how Tunisia ended up with 282 illegally shipped containers by July 2020, all coming from the Italian waste company SRA, based near Salerno.

When Tunisian customs opened a few of the containers, the consignment stunk, and it showed a vast array of materials, from plastic bags to paper ones, from paint can lids to foam, all pressed and tied up with wire. Their accompanying documents claimed the waste was sent to Tunisia to be transformed into something else. But at first glance, the waste didn’t look easily recyclable. Nor did the receiving company have the background or the equipment for recycling. In addition, according to the Bamako Convention, African countries do not allow the importation of municipal waste.

On paper, the waste was labeled as 19 12 12, which is basically mixed waste resulting from mechanical waste treatment, the first step household waste undergoes after collection in Italy. Some experts sarcastically call it fritto misto, or “mixed salad,” because it usually contains a bit of everything, including plastics. Since sorting and managing such waste requires additional costs, its usual fate is either in a landfill or an incinerator.

Five months after the case broke, Tunisian authorities arrested several officials, the former minister of the environment, Mustafa Laroui, among them. They were charged with fraud, corruption and abuse of office. The owner of Soreplast, the receiving company, promptly fled the country after being charged with illegal trafficking.

In December 2021, Italy announced its intention to take the waste back to get a better idea of its composition. Italy’s foreign affairs minister at the time, Luigi Di Maio, traveled to Tunis to meet the president, Kais Saied. The following day, the 29th, some of the waste was set on fire.

“Fire destroys evidence of illicit trafficking,” said Pergolizzi, talking about other blazes that took place in Italy following China’s ban. But his phrasing couldn’t be more appropriate.

In February 2022, most of the waste was repatriated — including a sample of the burned waste. Since then, the Public Prosecutor’s Office of Potenza has been investigating the case in Italy. But after a year and a few months, little progress has been reported. In the meantime, the Italian parliamentary inquiry committee on illicit activities in waste management approved a final report on the case. According to the committee, the plan was to get rid of about 7,900 metric tons of unrecyclable mixed household waste — and possibly more in the future — for a quarter of the Italian rate, travel excluded.

This isn’t the way waste is supposed to be handled.

There is an international convention on waste management, known as the Basel Convention, established in 1989. In part, the convention is meant to counter the dumping of hazardous waste in the Global South through its prior informed consent (PIC) procedure. In the Italian case, Tunisia gave consent — but from an agency that was not designated to handle PIC procedures.

For each case, competent authorities usually consider numerous documents, including showing that the receiving company is suitable to receive the type of waste. But an assessment is based mostly on papers presented by the exporting company, said Claudia Salvestrini, the director of the Italian polyethylene goods recycling consortium Polieco.

Traffickers may report they have a suitable facility when they only have a shed with a blocked conveyor belt, which cannot sort anything, she said, much less recycle it. “There is a real lack of control,” she added.

Polieco has actively fought transnational waste trafficking for years. Salvestrini said she has recently seen more and more authorized Italian companies declaring that their waste is headed for an EU country, but then stealthily sending it outside the EU. According to her, EU nations now favor Türkiye for discarded plastic waste.

Many Turkish companies have the license to import plastic waste, but lack the facilities to recycle it, according to a 2022 Greenpeace report. Since disposing of the waste in illegal landfills is cheaper, much of the EU’s plastic trash ends up polluting Turkish soil and waters.

Two years ago, Turkish authorities discovered 114 container loads of unrecyclable German plastic waste in five different Turkish ports. Although Türkiye dubbed this shipment illegal, they have not received any help from German authorities to return the waste.

According to both the Basel Convention and European regulation, exporting countries are obliged to take back illegally trafficked waste — theoretically. Practically, in many cases this doesn’t happen, as responsibilities are pushed from one authority to another as time passes.

On the outskirts of Sarbia, Poland, for instance, 6,500 metric tons of plastic waste rest in an illegal landfill waiting for repatriation back to its source, also Germany. After years of take-back requests — since 2018 — Germany has not taken back one ounce.

German state broadcaster NRD found that between 2015 and 2020, Germany received the most requests from Belgium and Poland for returning illegal waste. According to Eurostat data, in 2022, Germany shipped 149,700 metric tons of plastic waste to the Netherlands, 92,380 to Türkiye, and 81,230 to Poland.

EU traffickers often take advantage of the lack of border controls. To travel stealthily, they will opt for codes that do not always require the PIC procedure. This is the case for the code 19 12 04, namely rubber and plastic.

In October 2019, Bulgarian authorities found an illicit cargo of 127 containers full of mixed waste, mislabeled as 19 12 04. Around the same time, law enforcement agencies in Italy stopped 17 rail cars packed with mixed waste, also headed to Bulgaria and declared as 19 12 04.

Codes starting with 19 — i.e.,19 12 04, 19 12 12 and 19 12 10 — indicate waste coming from treatment facilities. These codes are often used to get around the proper classification of waste.

“Running it through a waste facility is sufficient to let eco-criminals say that is waste from waste management,” Nitti said, providing traffickers with some margins to send municipal waste far from where it was generated — at least until a recent judgment of the Court of Justice of the European Union, which reaffirmed that waste coming from treatment facilities, if not significantly altered in its chemical or physical properties, still has to follow the self-sufficiency and proximity principles the EU requires for household waste.

“Misclassification and mislabeling of wastes is one of the modus operandi among offenders,” Tatiana Terekhova, from the legal and policy unit of the Basel, Rotterdam and Stockholm conventions secretariat, wrote in an email. She pointed to examples like claiming electronic goods as used electronics or claiming metal, household waste or mixed plastic wastes as miscellaneous.

Experts agree that classifying what is waste and what is not often poses huge dilemmas and throws a wrench into making a circular economy. Pergolizzi, a waste analyst, called this the top issue. In his experience, “traffickers operate within this lack of definition,” he said.

This may also be challenging from a customs perspective. Pacelli, for instance, who was at the head of the Salerno customs office from May 2021 until this June, pointed out that without a physical inspection and analysis from environmental agencies, it is often impossible to establish whether what has been declared corresponds to the actual consignment. In some cases, he added, deciding whether something is waste or not requires some level of interpretation. Such an assessment may be a lengthy process involving other authorities with high costs for occupying port areas. In addition, he said, the Salerno office is understaffed and deals with many other tasks.

Therefore, European customs authorities adopt a risk management approach. According to specific criteria and risk profiles, customs flag consignments for bypassing control or to undergo documentary checks, scanner control or physical inspection. It’s up to each customs administration to define the most problematic commodities both at the import and export levels. The illegal movement of waste may be one of them. In 2021 and 2022, the Italian customs administration said it controlled about 4% of containers that might have been at risk of transboundary waste trafficking.

Control activities are carried out “to fight against criminal phenomena such as smuggling, counterfeiting, laundering and illicit trafficking,” the Italian customs administration wrote in response to a freedom of information request.

The aim is to mitigate threats to the security of the European Union, human health, biodiversity and the financial interests of member states. However, consignment selection criteria is kept confidential; some nations, like Italy, only disclose the total numbers of risk profiles: In April 2022, they were 15,035 — 11,479 for imports and 3,556 for exports.

Anna Kobyłecka, environment program manager at the World Customs Organization (WCO), confirmed that import controls are usually higher than those on exports.

“For waste shipments, a recommendation for customs should be to apply relevant levels of controls both at export and import,” she told Mongabay. According to Kobyłecka, the proper identification of risk indicators is among the most important steps to prevent waste trafficking, together with promoting awareness of the issue among customs officers, capacity building and cooperation with other customs administrations and national environmental agencies.

Amel Jrad, a Tunisian environmental consultant, advocated instead for higher sanctions or penalties: Countries that commit irregularities and violate the laws should be severely sanctioned, she told Mongabay.

According to Pergolizzi, waste should not leave each European country until it gets treated and is no longer considered waste. Prevention is key; only by building incentivized markets for recycled products can those markets compete with environmental crime.

In the meantime, while 213 containers have been repatriated to Italy, most of the burned Italian waste still sits in the outskirts of M’saken, Tunisia, covered in sand. Majdi Karbai, a former member of the Tunisian parliament, stresses that a solution for it has yet to be found.

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Banner image: A landfill with mixed waste. Image by Tom Fisk via Pexels (Public domain).

This article was developed with the support of


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