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Waste as a resource: how updated waste shipment rules can support more circularity in healthcare

Posted on 06.11.2025

Modernised waste shipment rules play an essential role in the mission of accelerating the EU’s transition to a circular economy. By 31 October, the European Commission consulted stakeholders on harmonising the classification of certain waste types (so-called “green-listed” waste) to facilitate their shipments across borders.

In its consultation response, MedTech Europe recommends upholding the green-list status for non-hazardous intra-EU e-waste shipments beyond 1 January 2027, including the exemption for shipments under 20kg. Besides, we outline general improvement suggestions to support more circularity in healthcare.

A harmonised EU waste shipment system is crucial for a functioning EU internal market. Today’s fragmented landscape creates inefficiencies. Extending Prior-Informed-Consent requirements to non-hazardous e-waste would increase these barriers to detriment of cross-border recycling and remanufacturing.

Part of these issues will be lessened with the Digital Waste Shipment System (DIWASS). However, while digitalising shipment processes is a positive step, it cannot offset the broader economic and logistical challenges introduced by PIC. Besides, interoperability and consistent enforcement across all Member States will be essential for the DIWASS to deliver meaningful efficiency gains.

More broadly, future proof waste shipment rules should in MedTech Europe’s view clarify and harmonise the end of waste status and relevant definitions, ensure a unified waste classification across the EU, opt for EU approval of cross-border shipment in case of registered take-back schemes, simplify the renewal process for approved notifications, harmonise templates and guidelines across the EU and a European Single Waste Market, mandate approval of documents in English, enact special regulation for own products/waste that has not been used by consumers and waste from clinical trials as well as align the Waste Shipment Regulation with other frameworks, i.e. on sustainability reporting.