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Exports of EU non-hazardous green listed waste for recovery will be prohibited to non-OECD countries from 21 May 2027, unless they meet strict new environmental conditions. From the same date, exporters will need to ensure that the environmental standards of destination facilities are independently audited and approved.

A general ban on waste exports for disposal, and a ban on hazardous waste exports for recovery, to non-OECD countries, will continue to apply.

EU plastic waste exports

From 21 May 2026, any authorised export of plastic waste outside the EU will be subject to the prior notification and consent procedure.

From 21 May 2027, exporters of plastic waste – in line with other wastes – will need to ensure that the environmental standards of destination facilities are independently audited and approved.

From 21 November 2026 until 21 May 2029, the export of plastic waste to non-OECD countries, including clean, non-hazardous waste plastic which is destined for recycling (B3011), will be prohibited. Thereafter, non-OECD countries will have to notify the European Commission and meet strict new environmental standards, enabling them to receive EU non-hazardous plastic waste (B3011) only. 

Digital waste tracking in the EU and UK

From 21 May 2026, procedures for movements of waste within the EU will become digital, with streamlining of fast track procedures for pre-consented facilities, and more stringent waste shipment transparency requirements within the EU.

In April 2025, the UK is scheduled to launch mandatory digital waste tracking (MDWT), which is a similar scheme, although a significant delay is widely anticipated.

The job of a shipment inspection agency is to check that goods conform to the buyer’s specifications and World Trade Organisation (WTO) rules, before they are shipped. Inspection agencies can also be used to verify cargo when it is already on board a vessel, and to check the security, seaworthiness and functionality of the vessel itself.

Accreditation required

Shipping inspection agencies need to be recognised and accredited by the authorities of the importing country, as independent and impartial third parties. To satisfy Customs requirements in India, the third-party inspection agency needs to be approved by the Directorate General of Foreign Trade (DGFT). Either a buyer or a seller of goods can hire an inspection agency.

Pre-shipment inspection certification (PSIC)

The shipment of consumer goods, secondary raw materials and certain soft commodities between countries can sometimes require a pre-shipment inspection certificate (PSIC) to be issued by an inspection agency, to obtain Customs clearance and assure the customer that they are being sent what they ordered.

What are pre shipment inspections checking for?

In the case of hazardous or non-hazardous waste shipments, pre-shipment inspections are likely to be checking for contaminants that contravene the rules of the destination country, and that might violate other contractual terms agreed with the buyer or importer. Scrap metal might be physically searched by an authorised inspector for prohibited metal items such as guns, ammunition or mines, and tested for radioactive materials using specialised equipment, before a PSIC is issued. For shipments of waste paper or waste plastic, inspection agencies might be looking for prohibited contaminants such as putrefiable organic matter, medical waste, or municipal solid waste.

What evidence do inspection agencies need?

Depending on what is being shipped, inspection agencies may only require emailed documents and visual evidence from the seller or exporter before authorising certification. Photographs or videos of key steps during the loading process are usually required to obtain a PSIC. For example, evidence may include photos of the container’s closed door with the container number visible; a bale break; and a photo of the seal in place clearly showing the seal number. This supporting evidence can then be forwarded as part of the inspection report to the relevant authorities, and shared with the customer.

PSI certification is no guarantee

Although pre-shipment inspections are meant to lower the risks of international trade for all parties, inspections of goods on arrival may still result in delays and disputes. Customs checks can reveal discrepancies between official documentation and the physical shipment, for example, resulting in a fine or the shipment being turned back. On arrival, the commodity’s stated quality or quantity may be disputed by the buyer if, say, the weight of a waste paper shipment is affected by excessive moisture content, or it presents as a less valuable grade. Disputes of this kind can give rise to claims for partial or full reimbursement, or the goods being rejected. Due to these risks, some traders use CTRM software to optimise their trading strategies and mitigate uncertainties.

Introducing technology to manage the arrival and departure of loads carried by vehicles, along with their weight data, is known as weighbridge automation.

How weighbridge automation works

Weighbridge automation works by replacing humans with electronic hardware and software when managing the use of ground-mounted scales. Automation aims to improve efficiency and accuracy by eliminating human data entry, reducing the need for paper documentation, and relying more on cameras and sensors to manage the flow of traffic across weighbridges.

Using weighbridge software in automation enables weight data from digital scales to be captured and calculated automatically for the weighbridge ticket, then digitally shared in real-time with authorised users and third parties. Sensors and cameras can be used to track and guide a truck’s position, while barcode scanning can match the vehicle and its recorded weight.

Benefits of weighbridge automation

The costs of automation – such as licensing the software, investing in hardware, and training staff – tend to be outweighed by longer term savings due to lower headcount, reductions in human error, and overall operational efficiency gains. Automation enhances monitoring and reporting by integrating weight data with CTRM software, accountancy packages, and third party digital systems such as those used by shipping lines. Automation can also improve data security by introducing role-based access and configuration.

Checks and certification

Like traditional weighbridge operations, ‘trade approved’ automated weighbridges need regular checks and an up-to-date weighbridge calibration certificate to record and certify their level of accuracy. This helps guard against issues such as hysteresis.

Importers of hazardous waste to India can download a completed pre shipment inspection certificate (PSIC) pdf from the Directorate General of Foreign Trade (DGFT) website, as soon as it has been uploaded by a DGFT approved inspection agency, along with any video and photographic evidence required.

What is the PSIC for?

Before a shipment of hazardous waste arrives in port, an inspection agency needs to have checked that the waste being shipped doesn’t contain contaminants that contravene India’s hazardous waste management rules (HWMR), although there are exceptions. The agency is also meant to confirm the buyer’s specifications, and to verify that the quantity and value of the import is compliant with World Trade Organisation (WTO) requirements, which are then recorded on the PSI certificate.

Which wastes require a PSIC?

Certain secondary raw materials that are not classified as hazardous waste in countries such as the UK or Italy, do qualify as hazardous waste in India, including scrap paper. As a consequence, exporters of green list waste sometimes need a PSIC along with Forms 6 and 9 and other documentation such as a certificate of origin (COO), to enable Customs clearance when the shipment reaches India.

A PSIC for scrap metal is not always needed, however. This depends on where the waste came from, and which port the shipment is entering India by. As of December 2024, a PSIC is not required for the import of whole end-of-life tyres (ELT) either, although it is illegal to use imported whole scrap tyres for pyrolysis.

PSIC required information

Details of the exporter, importer and waste originator need to go on a PSIC. The shipment’s container numbers, the quantity of bales, the weight in metric tonnes, and the Harmonised System (HS) code of the waste also need to be provided. The PSIC certifies to Customs that an inspection has found the details on the certificate to be true and correct. An original hard copy of the PSIC is usually required by Indian Customs before the shipment arrives, at risk of delays and penalties.

Inspections and evidence

While scrap metal exports can involve physical inspections before departure to obtain a PSIC, along with testing for the presence of radioactive materials, other wastes may only require documentary and visual evidence. Photographs or videos are taken during the loading of the container, including photos of the closed door with the container number visible, a bale break, and the seal in place clearly showing the seal number. 

Waste importer authorisation

Importers of hazardous waste to India use a Form 5 to obtain authorisation from their State Pollution Control Board for the import or export of hazardous and other waste for reuse, recycling, recovery, co-processing or utilisation. It is one of a suite of twelve HWMR forms.

Weighbridge software is used to digitally manage data for incoming and outgoing loads of material, which is recorded when a truck passes over ground-mounted scales, known as a weighbridge.

What does weighbridge software do?

Traders of soft commodities such as grain, and secondary raw materials such as scrap metal, need accurate measurements of weight to determine the value of the loads they are handling. The exact mass of the load being picked up or deposited is calculated by weighbridge software using readings from the weighbridge when the truck is empty, and when it is loaded. The weight of the unloaded truck or container, known as the tare weight, is then subtracted from the gross weight of the truck or container when it is loaded. This results in the mass of the load.

To ensure accuracy and avoid issues such as hysteresis, weighbridges need to be tested on a regular basis. Once verified, a weighbridge calibration certificate (WCC) can be issued to certify that the weighbridge meets acceptable industry standards for accuracy. 

Weighbridge ticketing

The data that is typically found on a weighbridge ticket, such as what the load weighs, what the load is, and what’s carrying it (which usually refers to the truck’s registration number) can all be digitally managed by weighbridge software. Modern weighbridges will generate a print-out of the ticket for the driver, copies of which need to be retained by the weighbridge operator. In the UK, a hard-copy written ticket is usually needed to accompany the load, although digital versions are becoming accepted.

Digital waste tracking

Weighbridge software is also useful to councils and waste management businesses who need to know the mass of the household waste they are picking up and depositing for disposal or recycling. Mandatory digital waste tracking (MDWT) regulations, which are supposed to come into force in 2025, will make reporting requirements of this kind more stringent. The extra costs of complying with MDWT rules are likely to put pressure on business margins and council budgets unless they digitalise their operations and get ready for MDWT.

Commodity trading and connectivity

Modern weigh bridge software enables data-sharing via API technology to third parties such as customs authorities, trading companies, and shipping lines. Digitalisation of this kind can improve transparency and efficiency along the global supply chain. Other technologies that modern weigh bridge software can connect with include recycling software, scrap trading software, risk management software, CTRM software, and various accountancy packages.

Benefits of weighbridge software

Weighbridge software can enable faster and more accurate management of incoming and outgoing loads across multiple weighbridges and sites if required. It can eliminate the errors and potential for fraud associated with manual data input. It can allow users to access their data remotely, enhancing financial control and risk management. For example, operators can be alerted to prevent a transaction being processed if the customer’s account has credit issues. The ability to monitor weighbridge activity in real-time also enables businesses to link the movements of material to stock control.

Countries that aim to damage each other’s trade by raising tariffs and trade barriers are often described as being in a trade war.

Beggar-thy-neighbour policies, such as retaliatory tariffs and punitive quotas, are typical of trade wars. So are competitive currency devaluations, and subsidised exports aimed at undercutting the rival country in other markets. Acrimonious breakdowns in trade negotiations, and complaints to the World Trade Organisation (WTO), are all part of the political theatre of trade wars. Outright bans on financial transactions, investments and the movement of goods and services across borders, sometimes known as sanctions, can also be imposed in extreme circumstances.

Causes of trade wars

Trade wars usually arise when one nation decides that the benefits of cheaper imports are outweighed by the economic and political costs. Industries with a powerful political lobby can stir up the conditions for a trade war, in the hope of preventing cheap imports from gaining market share. Sometimes the importing country has sectors that it wants to protect from foreign competition for strategic or national security reasons, such as key technology businesses.

The perception that trade partners are gaining a disproportionate advantage from freer trade, at the expense of the importing country, is a sign of impending trade war. Sometimes trade wars escalate slowly, when negotiations are accompanied by incremental rises in tariffs to increase political pressure.

Dumping

In general, the chances of a trade war are heightened by the existence of longstanding trade imbalances. For example, some countries choose to subsidise goods for export at below production cost, which is known as dumping. Over time, the countries that buy these goods tend to experience de-industrialisation. This is because their domestic manufacturers cannot compete on price, or security of supply, with the dumped imports. De-industrialisation creates political tensions that usually move in favour of raising tariffs and trade barriers.

Consequences of trade wars

In most circumstances, trade wars suppress trade flows and global GDP growth; in other words, they are bad for wealth creation overall. Because importers tend to pass on the higher cost of tariffs (which is a tax on imports) to consumers, trade wars can also be inflationary, causing higher prices. Trade wars usually have wider political repercussions, affecting freedom of movement, for example, and technology sharing.

Winners and losers

While trade wars tend to be negative for consumers and global commerce, they can nevertheless be beneficial for individual nations or protected sectors, especially if wider political objectives are taken into consideration. ‘Winning’ a trade war – or extracting concessions by threatening a trade war – largely depends on the relative importance of international trade to each nation’s economy, and to the interests of those in power. The more that a trade war hurts you domestically, the greater the chances are that you are going to make concessions to the other side. For this reason, retaliatory tariffs are often targeted at industries that lie within the constituency of individual politicians who may be decisive in negotiations. However, some politicians do prefer to foment full-blown diplomatic crises, rather than admit defeat at the negotiating table.

Law of the jungle

Historically, the WTO has been largely ineffective as an enforcer of international norms and rules. China, the U.S. and the EU generally deal with trade issues on a bilateral basis, applying the ‘law of the jungle’, which is to say that they negotiate on the basis of raw power, and who has greater leverage, rather than submitting to arbitration or a legal judgement, for example.

Trade war risk management

Until recently, the post-war consensus has been that trade wars are worth avoiding, for both diplomatic and economic reasons. But as the risk of trade war grows, international traders of soft commodities and secondary raw materials are having to embrace modern risk management software that helps them navigate these uncertainties and protect their margins.

A tax that is applied to the import of goods is known as a tariff. Customs duties, as tariffs are also known, are paid by the importer to their home government. However, the cost of the tariff is usually passed on to the consumer of the end product in the form of higher prices.

Ad valorem tariff

Tariffs can be calculated in different ways. The most common method is an ‘ad valorem’ tariff which is levied as a fixed percentage of the value of the imported goods. If imported whisky is subject to an ad valorem tariff of 20%, a bottle of $100 single malt whisky will attract duty of $20, while a $50 bottle of blended whisky will be taxed just $10.

Specific tariff

Specific tariffs, by contrast, are a ‘per-unit’ duty that is charged as a fixed amount on each imported good. The number of units being imported is what counts for a specific tariff. If there is a $10 specific tariff on imports of solar panels from China, for example, the tax paid will be $10 per panel, regardless of whether they are valued at $2,000 or $200 each.

Tariff rate quota (TRQ)

Tariffs that vary according to the quantity of a particular good being imported, are known as tariff rate quotas (TRQ). The rate of a tariff quota generally rises steeply once the ‘within quota quantity’ threshold has been reached. So for example, a country might allow the importation of 500 light aircraft at a tariff rate of 10%. However, any light aircraft imported above this threshold would be subject to 30% duty.

Mixed and compound tariffs

In some cases, countries such as India have taken a mixed tariff approach where they apply either an ad valorem tariff or a specific tariff on an imported good, based on which calculation brings in the most (or least) revenue. Pakistan has used compound tariffs, where both an ad valorem and a specific tariff are levied on the same imported good, then added together to reach a total. Tariffs can also be applied to exports, although these are rare.

Rules of origin

Calculating a tariff can be complicated when an imported good is made up of inputs from more than one country. For example, bottles of olive oil imported from Italy may derive from olives that were grown in both Morocco and the EU, for which different tariffs rules might apply. This is why many exporters of soft commodities need a certificate of origin document to accompany their shipments (as well as a phytosanitary certificate for example), enabling Customs authorities to calculate the relevant duty.

What are tariffs for?

Tariffs, like all taxes, are a way of raising revenue for government. In most advanced economies, however, tariffs are primarily a tool of industrial policy. Tariffs can be targeted to protect domestic sectors of the economy by effectively raising the cost of imported goods that compete in that market. If an overseas government is unfairly subsidising its export industries to undercut competitors and grab market share in a process known as ‘dumping’, tariffs can legitimately be used in retaliation.

Trade disputes

Sometimes, the threat of tariffs – or their imposition – is used as a negotiating tactic to obtain various political objectives, especially if the counter-party relies heavily on doing business with the country threatening tariffs. Unsurprisingly therefore, tariffs are often subject to international disputes that organisations like the World Trade Organisation (WTO) try to regulate. Frequently however, the WTO’s rulings have been ignored or flouted by the likes of the U.S., the EU, and China.

Protectionism

At the beginning of the industrial revolution, Great Britain applied high tariffs to enable its fledgling iron, steel and cotton-weaving industries, powered by new technologies, to develop into globally dominant exporters, while being protected from foreign competition. The success of this strategy, which came to be known as protectionism, was subsequently copied by the U.S., Germany, and China when they too industrialised their economies and sought to grow their markets overseas.

Free trade

Free trade policies favour the absence of restrictions on imports and exports, implying low or no tariffs. Post-war consensus has favoured free trade as an engine of global economic growth, although attitudes may be changing.

Large-scale subsidies for export manufacturing in China and elsewhere have raised geo-political tensions. De-industrialisation in some high-deficit countries, and persistent surpluses at the expense of domestic consumption in nations such as South Korea and Germany, have caused trade imbalances. The risk is that a correction may come in the form of greater protectionism and beggar-thy-neighbour policies; in other words, trade war.

Technologies that help businesses navigate the operational and strategic uncertainties that can cost them money, are known as risk management software.

Operational risks

For traders of secondary raw materials and soft commodities, or indeed any business that relies on global supply chains, operational risks are a daily challenge. Logistical mishaps and documentation errors can cause costly delays. Compliance issues, contaminated material and underweight loads can lead to claims and penalties. Cumulatively, operational risks erode profit margins and undermine competitiveness – which risk management software tries to prevent through automation and process optimisation, for example.

Strategic risks

Strategic risks tend to be bigger-ticket items associated with market and currency volatility; financial hazards such as access to credit; and geopolitical events such as armed conflict and trade wars. Strategic risk also encompasses missed opportunities (opportunity costs) where businesses forego higher revenue and growth because their capital and time are invested in less profitable activities. Risk management software tries to help improve traders’ strategic decisions and outcomes by providing them with better data insights and context – and timely alerts.

Modern vs. traditional risk management

Traditionally, risk management has been unstructured. Traders make judgements based on their client relationships, lessons learned and subjective interpretations of economic indicators. Assessing dangers and opportunities in this way isn’t always logical or aligned with a company’s objectives. The advent of risk management software, however, enables a more pro-active and organised approach to reading a dynamic situation, following agreed rules. Used in tandem with modern methodologies, risk management software can make dealmaking more agile, profitable and resilient in the face of shocks.

Risk methodologies

Risk management software solutions work best when staff adopt a structured approach to uncertainties, with procedures for identifying risks, assessing them, and monitoring them. These steps enable the business to plan how to avert unnecessary risks, and mitigate the impact of risks that are either worth taking because of the potential upside – or are, to some extent, unavoidable.

CTRM software

In recent years, specialised commodity trading and risk management (CTRM) technologies have evolved that leverage AI and live data to navigate the volatile and uncertain world of physical commodities. Modern CTRM software assists trading in soft commodities like grains and nuts, and secondary raw materials such as scrap paper and waste plastic. ETRM software meanwhile helps energy traders that deal in oil, coal and tyre-derived fuel, for example.

Future of risk management

Modern physical commodity trading systems are increasingly adopting a networked approach to trading risks. When international buyers and sellers of commodities adopt smart contracts and electronic bills of lading, inefficiencies caused by paper documentation can be eliminated. This brings the benefits of greater transparency to all trade participants, enhancing trust and reducing many of the operational costs and uncertainties that the global commerce community sometimes views as inevitable.

Grey swans, black swans

Many small and medium sized traders don’t have a plan for grey swan events. These are high impact events that are to some extent predictable, but happen very seldom, such as the Covid pandemic. Large corporate organisations are usually obliged to develop contingency plans for grey swan risks that address ‘known unknowns’.

Black swan events, by contrast, are ‘unknown unknowns’ that lie beyond normal expectations and are therefore much harder to prepare for, such as the 9/11 terror attack. Even in the most dramatic circumstances, though, having an agile, tech-enabled approach to risk is likely to improve a trader’s chances of weathering the storm.

The UK and EU have arrangements with the United States and Canada that enable certain plants and plant products such as almonds and wheat flour to be imported with reduced controls, so long as pre-export checks (PEC) are performed in the country of origin.

Almonds from California

In the United States, PEC certification applies to direct shipments from California, bound for the EU, of bulk and unprocessed almonds classified under HS codes 0802 11 (inshell) and 0802 12 (shelled). The PEC concession enables testing for aflatoxin – a toxin produced by mould that can grow on almonds – to be undertaken in the country of origin by an approved laboratory. The PEC certification includes a description of the consignment, the United States Department of Agriculture (USDA) attestation, and an aflatoxin certificate.

Since January 2024, Great Britain (not Northern Ireland) requires a separate GB-PEC certificate for almond shipments to the UK. Northern Ireland continues to accept the EU’s PEC certificate. PEC concessions are set out in Annex II to the Commission Implementing Regulation (EU) 2015/949. In Great Britain, the provisions of assimilated Regulation (EU) 2017/625 (Article 73) apply.

Canadian wheat and wheat flour

In Canada, PEC concessions apply to the examination and testing of ochratoxin A levels in wheat (HS code 1001) and wheat flour (HS code 1101 00) that are destined for the UK and EU. Like aflatoxin, ochratoxin A is a type of mycotoxin that can be dangerous to humans and animals. It is found in foods including cereals, preserved meat, and fresh and dried fruit.

To qualify for reduced checks, consignments must be accompanied by a sampling and analysis report from an approved laboratory in Canada, and a certificate that is completed, verified and signed by the Canadian Grain Commission. An identity code needs to be included on the certificate, on the report, and on each individual bag or packaging form.

Pre-export checks are not mandatory

Consignments without the certificate and laboratory report required by PEC can still be imported, but do not qualify for reduced checks. This increases the likelihood of examination and sampling to check compliance with British or EU standards. A properly completed PEC certificate download, by contrast, can ensure that consignments are subject to less than 1% controls at the EU and GB borders.

Imports to the UK and EU of plant-based soft commodities that do not qualify for PEC concessions often need to be accompanied by a range of official documentation, including a phytosanitary certificate, to gain customs clearance. Some high risk food and feed of non-animal origin (HRFNAO) also require pre-notification before arrival at the port of entry.

The main EU customs form used in international trade is the single administrative document (SAD), whose UK equivalent is HMRC Form C88. It provides proof of authorisation to import or export for the country of destination, and enables traders and agents to comply with customs regulations. It also tracks the movement of goods through customs.

Once a consignment has been cleared, the SAD serves as evidence that a customs declaration has been properly made. It also serves as a tax declaration document for paying taxes and duties, and as a transport document, helping to expedite goods shipments.

What information goes on a single administrative document?

A SAD describes the goods being imported or exported, along with their HS commodity code, their quantity and value, their origin and destination, and their customs procedure code, which determines how customs will deal with the consignment’s entry into the country. Codes entered in the SAD’s various document fields need to align and connect with one another, at risk of penalties and delays, so guidelines should be closely followed.

Digital communication and SAD

Traders can electronically share the information contained in a SAD by using freight forwarder or advanced CTRM software that connects to customs digital systems such as HMRC’s Customs Declaration Service (CDS), formerly CHIEF. Manually completed SAD documents are also accepted. Customs allocate a master reference number (MRN) to each single administrative document when they record the status of the accompanying goods. Status indicates whether the consignment been cleared, rejected, or if queries have been raised.

Who needs to complete a SAD?

Traders don’t need to use a SAD for movements of goods within the EU, unless the goods are of non-EU origin. A SAD is required for trade with third countries however. When goods are transported through several countries before reaching their destination, a SAD must be filed in each transit country.

HMRC Form C88 and Form C79

HMRC Form C88 needs to be completed by anyone who imports goods from non-EU countries into Great Britain, or exports them from Great Britain to non-EU countries. The information it provides enables customs officials to assess and collect the correct amount of import duty, VAT, and other taxes. Reclaiming VAT paid on imported goods from outside the EU requires another document, Form 79. This form provides evidence of the VAT paid on imported goods, and cannot be used for customs clearance purposes.

8 copies of SAD

SAD Copy 1 and Copy 2 remain at the office of departure, for control and statistical purposes respectively. Copy 3 is for the consignor or exporter, although it may be retained by the community transit principal. Copy 4 is for the customs authorities in the destination state. It provides evidence that the goods are in free circulation or not, and indicates whether customs duty is payable.

Copy 5 is returned from the office of destination, to the customs authorities in the state of despatch, providing evidence that the goods reached their destination intact. This copy is also used for the return of goods. Copy 6 serves as the customs import declaration on arrival in the state of destination. Copy 7 is the statistical copy of the import declaration for the state of destination. Copy 8 is retained by the importer or the importer’s agent.