The Basel Convention is one of the most important international legal frameworks for controlling transboundary movements of hazardous wastes and other wastes. Its plastic waste amendments, adopted in 2019 and in force since 2021, changed the way many plastic waste shipments are controlled internationally. As a result, several categories of plastic waste became subject to the Convention’s Prior Informed Consent procedure, meaning that shipments may require notification, consent, movement documentation and confirmation of disposal before they can legally move across borders.
This was an important legal development that triggered many countries imposing bans on plastic waste imports or ban certain types of plastic products. Yet, all of this did not yield an effective sound management of plastic waste.
The reason is the absence of operational systems needed to know what is being exported, what is being imported, who is responsible, whether consent was properly obtained, whether the shipment arrived, and whether the waste was actually recycled, recovered or disposed of as declared.
What the Basel PIC Procedure Requires
The Prior Informed Consent procedure is the heart of the Basel Convention’s control system. The Convention describes the procedure on electronic approaches for notification and movement documents as involving four main stages: notification, consent and issuance of the movement document, transboundary movement, and confirmation of disposal.
In principle, this creates a clear chain of responsibility.
Before a shipment moves, the exporting country must notify the importing country and any transit countries. The shipment should not proceed without consent. When the shipment moves, it should be accompanied by movement documentation. At the end of the chain, disposal or recovery should be confirmed.
On paper, this is a strong compliance model.
In practice, it depends on whether countries can manage the information behind the procedure: exporters, importers, waste codes, quantities, destinations, transit routes, consent status, shipment documents, facility permits and confirmation of final treatment.
Is There Data on International Waste Trade?
There is data on international waste trade, but it is fragmented and incomprehensive.
Some trade data comes from customs and trade-statistics systems, such as UN Comtrade and national customs databases. Researchers use these systems to estimate global plastic waste trade. For example, a 2024 study in Resources, Conservation and Recycling estimated that global waste plastic exports estimated that global waste plastic exports totalled about 255 million tonnes from 1988 to 2022.
Other data comes from Basel Convention national reporting. Parties are required to submit annual national reports under Article 13 of the Convention. The Basel Convention’s Electronic Reporting System is the tool used by Parties to submit these reports, and the Secretariat states that reports submitted by Parties can be viewed for the years 2001 to 2024.
Basel national reports can include information on the generation, export and import of hazardous wastes and other wastes. The Convention also has a reports dashboard based on data transmitted by Parties.
Does Basel Collect PIC Data?
Basel collects national reporting data from Parties, and this reporting can include information on exports and imports of controlled wastes. The reporting system is important, but it is not equivalent to a live global PIC-tracking platform.
The Basel Secretariat itself notes that PIC documentation is still paper-based and transmitted by post, fax and email and explains that electronic approaches could reduce administrative burden, speed up and lower the cost of the PIC procedure, and improve enforcement.
This is a crucial point. If the Convention itself recognises that documentation is still often handled through paper, post, fax and email, then the control system is legally binding but operationally outdated.
There is no single public system where one can see all PIC notifications, consent decisions, movement documents, shipment status, transit routes, final disposal confirmations and discrepancies in real time. Instead, information is distributed across national authorities, annual reports, customs data, individual permits, paper documents, emails and domestic systems.
Is Data Collected Under the Basel Convention Reflective Of Real Waste Trade?
Basel data is important, but it does not fully capture the operational reality of waste trade.
First, national reports are annual and retrospective. They are useful for reporting what happened, but less useful for controlling shipments as they happen.
Second, reporting quality varies between countries. The Basel Convention warns that the data is based on information transmitted by Parties and should be carefully interpreted. Academic literature has also identified uneven national reporting practices across countries and years as a limitation of the Basel Convention database.
Third, trade statistics and Basel reporting do not always serve the same purpose. Customs trade data can show that waste moved from one country to another, but it may not show whether the movement was properly notified under PIC, whether the receiving facility was authorised, whether the declared recovery operation took place, or whether the material was misclassified.
Fourth, plastic waste trade is only one part of the broader waste-trade system. Waste can be misclassified, mixed with other materials, moved through intermediary countries, or declared as recyclable material even when the receiving system cannot manage it properly.
This means that the PIC data available through national reporting should not be confused with full control over waste movements.
Why the System Does Not Function Well Enough
The weakness is not only legal. It is operational.
The PIC procedure relies on multiple authorities, documents, exporters, importers, customs offices, transit countries and disposal or recycling facilities. If these actors are not trained or connected through digital workflows, the system becomes slow, fragmented and difficult to enforce.
A shipment may be approved in one system, documented in another, checked by customs in a third, and reported to the Basel Secretariat much later through an annual national report. If information is missing, inconsistent or delayed, authorities may not detect problems until after the waste has already moved.
This is especially problematic for plastic waste because the value of the material depends heavily on quality, contamination and actual recyclability. A shipment may be described as plastic waste destined for recycling, but the receiving country may lack the capacity to process it properly. Once the shipment arrives, weak domestic infrastructure, informal processing, open dumping or illegal burning can turn a legal trade movement into an environmental problem.
Recent reporting continues to show how plastic waste exports from high-income countries are redirected to countries that may already struggle with domestic waste management. For example, The Guardian reported that Germany and the United Kingdom remained major exporters of plastic waste in 2025, with large volumes going to countries such as Turkey, Malaysia and Indonesia. Reuters has also reported that Vietnam, a major importer of plastic scrap, struggles to recycle both domestic and imported plastic waste, with weak sorting and informal recycling contributing to poor outcomes.
The legal shipment may be documented. The environmental result may still be poor.
What Digital Compliance Should Look Like
To make Basel plastic waste amendments work better, countries need more than legal obligations. They need to know where the actual reliable hubs for recycling plastic waste are located. And secondly, they need to all be connected to digital compliance workflows.
A practical digital system should connect the full PIC chain: notification, consent, movement document, shipment tracking and confirmation of disposal. It should also connect the actors involved: exporters, importers, competent authorities, customs, transit countries, receiving facilities, laboratories, inspectors and enforcement agencies.
Such a system should include:
- a registry of authorised exporters, importers, brokers and certified recovery and recycling facilities;
- digital notification and consent workflows;
- shipment-level tracking from approval to arrival;
- digital movement documents linked to customs systems;
- alerts for missing consent, expired permits, suspicious routes or quantity mismatches;
- facility-level confirmation of recycling, recovery or disposal;
- links between Basel waste codes, customs codes and national permit systems;
- dashboards showing exports, imports, destinations, material types and compliance risks;
- risk scoring for shipments, operators and destination facilities;
- audit trails for enforcement and reporting.
From Annual Reporting to Real-Time Control
The Basel Convention already recognises the need for electronic approaches to notification and movement documents. However, the pace of digital transformation remains slow compared with the scale of global waste trade.
If millions of tonnes of plastic waste move internationally, while the control system still depends heavily on annual reports, paper documents, email exchanges and uneven national reporting, then implementation will remain weaker than the legal text suggests.
The next step should not only be better law. It should be better operational control.
The Fussbann Group Perspective
Fussbann Group develops digital solutions that help public authorities, municipalities, international organisations and private actors operationalise environmental management.
For Basel plastic waste controls, this means building systems that turn legal obligations into practical workflows: shipment tracking, actor registries, digital documentation, alerts, dashboards, decision-support tools and compliance monitoring.
The plastic waste amendments made the law stronger. Effective implementation now depends on whether countries can see, verify and act on what is happening in real time.
Binding law matters. Without digital systems that connect documents, actors, shipments and final treatment, plastic waste controls remain too dependent on delayed reporting and fragmented administration.
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