MedTech Europe responds to Waste shipment Regulation consultation
MedTech Europe sets out its response to the EU consultation on Regulation (EU) 2024/1157 harmonising the classification of certain waste types (so-called 'green-listed' waste) to facilitate their shipments across borders. It welcomes the European Commission’s efforts to modernise waste rules and promote recycling but warns that some proposed measures, such as extending the Prior Informed Consent procedure to all intra-EU shipments of e-waste, could create significant administrative burdens, delays and costs. It emphasises the need for clear definitions of waste and end-of-life products, uniform classification systems, and consistent templates and guidelines across the EU. MedTech Europe also urges the maintenance of 'green-list' status for non-hazardous intra-EU e-waste shipments and supports streamlined approval, renewal and documentation procedures, ideally through EU-level or digital systems. MedTech Europe provides a set of general improvement suggestions to future-proof the waste shipment rules that include calling for specific regulation to address products/waste that is not used by consumers and for waste from clinical trials and aligning these rules with medical device legislation. It points out that 'a perfectly safe product for use becomes hazardous under the WSR and the Basel Convention. We recommend aligning all these frameworks to facilitate compliance for intra-EU shipments by, for example, establishing contamination thresholds aligned with the existing legal requirements under the other EU acquis'.