What is Regulation (EU) 2024/1157 on shipments of waste?

A revision of the EU Waste Shipment Regulation (WSR), published in 2024, which strengthens control over cross-border movements of waste within the EU and beyond. The key element: a ban on plastic waste exports to non-OECD countries from November 2026 (with an optional derogation possible for selected countries meeting waste management criteria).

How much plastic waste does the EU currently export?

At its peak (2017-2018) the EU exported up to 8 million tonnes of plastic waste per year to Asia (mainly China until 2018, then Malaysia, Vietnam, Turkey). After import bans in the destination countries, exports fell to about 3-5 million tonnes/year in 2023-2025. The EU-to-non-OECD ban means this stream must be processed inside the EU.

What does this mean in practice for transport?

Three effects: (1) growth in shipments of sorted waste from sea ports (where it previously went onto container ships) to recyclers inside the EU; (2) growth in shipments of regranulates (R-PET, R-HDPE, R-PP) from recyclers to packaging producers after PPWR forces recycled content; (3) a change in the route profile — fewer long runs to ports, more medium runs to recyclers (300-800 km).

Can plastic waste be carried in a silo trailer?

Raw plastic waste (film, bottles, packaging pieces) is usually transported in lugger trailers, walking floors or containers. Silo trailers are used for **shredded and sorted** material (e.g. PET flake before regranulation, HDPE regrind), which already has a free-flowing structure. After regranulation the recyclate returns fully to the silo trailer segment — just like virgin material.

Who gains from the export ban, and who loses?

Winners: European mechanical and chemical recyclers (more feedstock), producers of recyclate-based packaging (PPWR + access to feedstock), intra-EU carriers with compliance certificates. Losers: export intermediaries, container ports (less waste traffic), carriers without supply chain traceability certification.

Does the ban also apply to regranulate (recovered raw material)?

No. The ban applies to plastic **waste** (Basel classification B3011 — plastic waste for recycling, B3012 — plastic waste unfit for recycling). Once the waste is processed into regranulate, its status changes from 'waste' to 'secondary raw material' — and it can be sold and transported without restriction within the EU and beyond. The status boundary is defined by end-of-waste criteria (the Commission is proposing uniform European criteria within the Circular Economy Act 2026).

regulacje transport 19.09.2025 PHS Magnum

Ban on Plastic Waste Exports Outside the OECD from Nov 2026

DAF silo trailer transporting bulk materials

In brief

Regulation (EU) 2024/1157 on shipments of waste introduces a ban on plastic waste exports to non-OECD countries from November 2026. A stream of the order of 3-5 million tonnes per year must be processed inside the EU. Consequences for transport: growth in intra-EU shipments (shredded waste to recyclers, regranulate to packaging producers), a change in route profiles (fewer long runs to ports, more medium runs between plants), a premium for carriers with chain of custody certificates (RecyClass, ISCC). Poland — as a large importer of plastic waste from the EU and a country with developed recycling infrastructure — sits at the centre of the new arrangement.

What the regulation changes

The WSR in its current version (Regulation 1013/2006) has governed waste shipments since 2007 — mainly consent procedures, classifications (green/amber list), and bans on certain waste types to specific countries.

The new (EU) 2024/1157 introduces three structural changes:

A ban on plastic waste exports to non-OECD countries from 21 November 2026 — absolute, with a possible derogation of up to 5 years for selected countries that apply and meet waste management criteria.
Strengthened control over exports to OECD countries — a requirement of written consent from the receiving state for every shipment (the “prior informed consent” procedure).
Digitalisation of procedures — all waste shipment notifications mandatorily electronic from 2026-2027.

The scale of the phenomenon — how much waste stays in the EU

The EU generates about 25-30 million tonnes of plastic waste per year. Before the WSR reform:

Recycling in the EU: ~10-12 million tonnes/year
Incineration with energy recovery: ~10 million tonnes/year
Landfilling: ~3-5 million tonnes/year (declining)
Exports: ~3-5 million tonnes/year (mainly to Turkey, Vietnam, Malaysia)

Once the ban enters into force, the export stream must be “absorbed” by domestic infrastructure. Three paths:

An additional 3-5 million tonnes/year to mechanical recycling (requires expansion of sorting and washing plants)
Part to chemical recycling (a dynamically growing segment 2025-2030)
Part to energy recovery (when physically unfit for recycling)

Each of these paths = new tonne-kilometres of transport inside the EU.

Three new transport segments that will grow

Segment 1: Sorted waste from the point of generation to the recycler

Stream: sorting plant → mechanical or chemical recycler. Material: PET flake, HDPE flake, PP regrind — waste that is already shredded, colour-sorted and polymer-specific.

Transport type: lugger waste containers, walking floors, and on a smaller scale silo trailers (for materials that already flow as granules).

Distance: 200-800 km — mainly within countries, but a growing cross-border segment (Poland→DE, Czechia→DE).

Segment 2: Recyclate (regranulate) from the recycler to the packaging producer

Stream: recycler → bottle/film/crate producer. Material: R-PET pellets, R-HDPE pellets, R-PP pellets — full-value regranulate with a defined technical specification.

Transport type: pneumatic silo trailer — exactly as for virgin material.

Distance: 100-1,000 km. PHS Magnum with its Chorula base (4 km from the A4, 180 km from the DE border) — a natural transit location for PL→DACH routes.

Segment 3: Specialised waste for chemical recycling

Stream: mixed plastics sorting plants → pyrolysis / glycolysis / depolymerisation installations. Material: mixed polyolefin films, PET destined for depolymerisation.

Transport type: containers, in selected cases silo trailers for shredded materials.

Distance: 300-1,500 km — very long runs, because chemical recycling plants are few (Germany, Austria, the Netherlands).

The change in route profiles after November 2026

Before: significant waste traffic from deep within the EU (sorting plants in PL, IT, ES) → container ports (Rotterdam, Hamburg, Antwerp) → ships to Asia.

After: this traffic disappears. Replaced by:

Shorter routes: sorting plant → domestic recycler (200-500 km)
Medium routes: recycler → packaging producer in another EU country (500-800 km)
Occasional long routes: specialised waste → chemical recycler in DE/AT/NL (1,000-1,500 km)

Overall: the number of tonne-kilometres in the EU grows, but the profile of a single run gets shorter. Shorter runs = higher rotation, a bigger role for intra-EU routes such as Poland↔DACH.

Poland — its position in the new arrangement

Poland:

2nd place in the EU for the amount of plastic waste imported (after Germany) — before the ban
Developed mechanical recycling infrastructure (PCC, BoryszewERG, Plastics Recyclers Poland, a regional base of recyclers)
A growing chemical recycling base (Anwil, BASF and LyondellBasell projects starting 2024-2026)
Geography: 180-300 km to most consignee plants in DE/AT/CZ

Conclusion: after November 2026 Poland becomes the main regranulate supplier for DACH. Silo trailer transport between Poland and Germany/Austria/Czechia — the segment with the highest growth dynamics in the industry.

What to plan — for shippers and carriers

For shippers (packaging producers, the food industry, distributors)

Start talks with recyclate suppliers in the EU — the supply chain will get shorter, but prices will rise along with PPWR demand
Define your preferences: do you want recyclate of a specific origin (e.g. PL with a RecyClass certificate)?
Secure a partnership with a certified carrier (OCS, RecyClass) — from 2027 it will command a premium

For carriers

Implement OCS certification (required at throughput >1,500 tonnes/year from 2027)
Implement RecyClass / ISCC PLUS (recyclate supply chain traceability)
Dedicate part of the fleet to food-grade (the highest-valued segment)
Build relationships with recyclers and packaging producers in DACH

About the author

This content was prepared by the PHS Magnum team in cooperation with Aleksy Pasternak — the company’s Managing Partner, a bulk material transport expert with 35 years of experience in trading plastic granulates, recyclates and industrial minerals in the EU. Aleksy publishes industry analyses on the expert portal pasternak.me , where you will find further studies on regulatory topics (PPLP, PPWR, OCS), technical topics (silo trailers, TDT) and operational topics (big-bag transloading, repackaging).