E-Waste Exports Under the Updated Basel Convention

Anyone managing industrial-scale electronic waste flows is now facing a profoundly different regulatory landscape. As of 21 May 2026, EU Regulation 2024/1157 on cross-border waste shipments is fully applicable, replacing the previous Regulation 1013/2006 and introducing, through delegated regulations 2024/3229 and 2024/3230, a new regime for e-waste export built around the Basel Convention's classification codes. For companies handling waste electrical and electronic equipment, this is no minor update: it changes how material is classified, how authorisation procedures toward third countries work, and, above all, how much margin for error is tolerated. With Italy's e-waste collection rate sitting only slightly above 30% against the EU's 65% target in 2025, every tonne of material that leaves the EU under the wrong classification represents both a compliance risk and critical raw material value lost to the domestic supply chain.

What changes for e-waste export under EU Regulation 2024/1157

EU Regulation 2024/1157, published on 11 April 2024, redesigns the entire framework for waste shipments between member states and toward third countries, with the stated goal of preventing the export of problematic waste and strengthening traceability across the chain. Compared with the previous regime, the most significant change concerns tighter controls on receiving facilities: exporters must now be able to demonstrate that the destination plant manages the material to standards equivalent to those in force in Europe, with independent audits required for non-EU facilities. The regulation also pushes toward digitalisation of notification paperwork, progressively replacing paper forms with a centralised electronic system meant to speed up information exchange between the competent authorities involved in a given shipment.

The Y49 code and the end of the GC020 entry

The most concrete change for anyone moving electronic waste concerns classification. Delegated regulations 2024/3229 and 2024/3230 aligned EU law with the Basel Convention's e-waste amendments, introducing the new Y49 entry to replace the previous GC020 classification used for non-ferrous metals. Since 1 January 2025, the GC020 entry can no longer be used for e-waste exports to OECD third countries: any such shipment must be coded under the Y49 scheme, with all the procedural consequences this carries in terms of prior notification. A simplified GC020-based procedure remains admissible only for shipments within the European Union, and in any case no later than 31 December 2026 — a clear signal that the window for adjusting internal processes is steadily closing.

OECD and non-OECD countries: two different regimes for e-waste export

The reform consolidates a sharp geographic distinction. Toward EU and third-country OECD destinations, e-waste export remains possible but is subject to a prior written notification and authorisation procedure by the competent authorities, with the new Y49 code as the mandatory reference. Toward non-OECD countries, by contrast, the regime becomes considerably more restrictive, in line with the Basel Convention's core purpose of preventing hazardous or problematic waste from being offloaded onto countries lacking adequate treatment capacity. For a company currently supplying post-consumer material or industrial electronic scrap to non-OECD markets, this means reassessing the entire map of authorised recipients and, in many cases, redirecting flows toward recovery facilities within the Union.

The Ministry's opinion and the proximity principle

Some practical questions were clarified by Italy's Ministry of the Environment and Energy Security in an opinion issued on 4 February 2026, which addressed in particular the case of non-hazardous e-waste shipments toward OECD countries such as Japan: even when the importing country would not itself require additional formalities, a shipment leaving Italy must still follow the notification procedure under the Y49 code, in line with EU rules. The opinion also confirmed that the proximity principle — which in theory allows authorities to object to a shipment if the waste could be treated closer to its place of origin — cannot be invoked as grounds for objection when the waste is destined for recovery operations (R4) rather than disposal. In practice, this clarification protects the international trade of high-value secondary materials, such as circuit boards bound for specialised refining plants.

Getting ready: audits, traceability and documentation duties

For companies that handle e-waste export on a regular basis, adapting to this framework requires work on several fronts. The first is a precise mapping of EWC codes against the corresponding Y49 classification for every flow handled, so that already-planned shipments do not get stuck at customs over an obsolete code. The second is documentary verification of non-EU destination facilities, given the possibility of independent audits required under the new regulation. The third, more structural step involves integrating internal traceability systems with the future centralised digital notification system — an investment that looks early today but will become mandatory as national authorities complete the shift away from the paper-based model.

Companies that get ahead of this regulatory transition turn a compliance constraint into a genuine competitive edge: an export chain able to demonstrate precise traceability, correct classification under the Y49 code, and solid relationships with verified destination facilities reduces the risk of customs holdups, shortens authorisation times, and positions itself as a reliable partner for international operators increasingly attentive to their own reputational and environmental exposure. In a market where the critical raw material value locked inside e-waste is growing faster than domestic recovery capacity, the ability to move confidently between the two sides of the regulation — the European framework and the Basel Convention — is set to become an ever sharper line between companies that merely comply and those that turn compliance into strategy.