MedTech Europe Response to EC public consultation on Regulation (EU) 2024/1157 on Shipments of Waste

Modernised waste shipment rules play an essential role in the mission of accelerating the EU’s transition to a circular economy. By 31 October 2025, 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 provide a set of general improvement suggestions to support more circularity in healthcare. 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 and
• Align the Waste Shipment Regulation with other frameworks, i.e. on sustainability reporting.