How do we truly put an end to the illegal trade in plastic waste?

Wishful thinking and quick fixes

As long as Europe cannot process its own plastic waste, conducts far too few checks and new fossil plastic remains artificially cheap, the problem will not diminish but disappear to places where control is weaker and environmental damage is greater.

The European Union wants to keep plastic waste within its borders with the Waste Shipment Regulation (WSR). This attempts to intervene in plastic waste exports and obliges companies to demonstrate where their waste goes and how it is processed. From 21 November 2026, the WSR will introduce a ban on all exports of plastic waste to non-OECD countries.

In theory, this should lead to more processing within Europe and better control over waste streams. In practice, the problem is: as long as European recyclers cannot compete with cheap virgin plastic, there remains a shortage of recycling capacity and the incentive remains for plastic waste to shift to incineration, landfill or other (illegal) waste streams.

Waste colonialism persists

The WSR is a response to an export model spanning many years, in which Europe has a large share of its plastic waste processed outside its borders. That stream flows through Rotterdam, where approximately 40% of plastic waste exports are shipped to Indonesia, Vietnam, Malaysia or Turkey. In this transit hub, containers regularly change hands, meaning waste streams quickly disappear from view and exact data diverge.

Without sufficient recycling capacity, sales markets and enforcement, we cannot expect less export to automatically lead to more processing within Europe. At the same time, the export ban is incomplete. The ban on exports to non-OECD countries is temporary, and countries can reapply to import waste after just 2.5 years, leaving European recyclers in uncertainty about their future opportunities.

In addition, the export of plastic waste to Turkey can simply continue, where 3.7 million kilograms of plastic waste goes from the Netherlands every month (December 2025). Marco Musso of the European Environmental Bureau (interview, 28 April) calls the restriction to OECD countries arbitrary: “There is essentially an assumption that waste is processed properly within OECD countries. This is not always a guaranteed practice.” Non-EU OECD countries, such as the United Kingdom, can serve as intermediate stations, causing waste to still disappear from view. The result is that waste streams do not disappear, but are relocated.

Waste smuggling follows the cheapest route

That is precisely where the risk for illegal trade lies. Plastic waste trade remains profitable because flawed monitoring and a low chance of being caught keep illegal export and processing outside the EU attractive. This makes illegality primarily a cost issue: as soon as legal processing is more expensive than evasion, the incentive grows to export waste streams via other labels or routes.

Furthermore, the plastic waste chain is difficult to monitor. The Intelligence and Investigation Service of the Human Environment and Transport Inspectorate (ILT-IOD) points out that waste can disappear from view and still be exported through false codes, documents, mixing with other cargo or diversion. From 21 May, the WSR obliges notification about waste streams, but if supervision is insufficient, this remains primarily a paper-based control and waste streams can still disappear. In addition, the ILT highlights their undercapacity, putting enforcement under pressure. Consequently, they do not expect an increase in processing within the EU.

Fix the business model for European recyclers

Underlying this is the previously exposed market failure: circular alternatives are more expensive than new fossil plastic. Attention has long been drawn to cheap new plastic, sometimes even labelled as "recycled", flooding the market. As a result, companies lack the business case to invest in recycling capacity on a large scale. As long as new plastic remains cheap and recycled material relatively expensive, the incentive to invest in recycling capacity is missing.

The European Packaging and Packaging Waste Regulation (PPWR) can increase the demand for recyclate in packaging, but only covers part of the plastic waste stream. For much of the exported plastic waste, this is no solution. In addition, extra demand alone does not solve the problem. If cheaper imported recyclate can fill a large part of that demand, Dutch and European recyclers remain vulnerable. Recycled-content targets only work when it is clear where the recyclate comes from and whether it has been reliably audited.

Lauriane Veillard of Zero Waste Europe (interview, 4 May) warns of this risk: “We saw an increasingly high import of recycled plastic into the European Union. That would mean that waste we have in Europe is repeatedly incinerated, and that our targets are met with waste from elsewhere.” In other words: recycled-content targets can be met on paper, while European plastic waste is still incinerated and the European recycling sector is not strengthened.

Less virgin plastic, more European recyclate

Pricing virgin plastic remains essential. As long as new fossil plastic is cheaper than recyclate, European recycling remains economically vulnerable, and subsidies and loans are a drop in the ocean. In the long term, a strong price incentive is therefore needed to make new plastic more expensive and give recyclate a fair chance.

This requires various measures that must align with each other:

Strengthened modulation in Extended Producer Responsibility (EPR) Producers must be rewarded more strongly for using recyclate, and pay more when they rely on new plastic. Research by CE Delft shows that strengthened fee modulation increases effectiveness, provided that discounts increase sufficiently as more recyclate or bio-based material is applied.

A plastic packaging tax aligned with the EU plastic levy A plastic packaging levy on non-recycled plastic in packaging helps to narrow the price gap between fossil and recycled materials, discourage the use of virgin plastic packaging and strengthen investments in recycling.

The “Circular Leverage” With a circular leverage, which taxes the share of fossil plastic in products and uses the revenue to stimulate circular alternatives, an integrated approach is created, making it harder to shift costs and limiting leakage effects within the chain.

Requirements for origin, quality and control Standards for recyclate only work if it is clear where recyclate comes from and whether it is actually recycled. Without requirements for origin, quality and control, standards can be met with cheap "recyclate" from outside Europe, while European waste is still incinerated.

The WSR thus marks an important but incomplete step. Without sufficient recycling capacity, effective enforcement on the registration of plastic waste streams, including to non-EU OECD countries, and structural price incentives, the measure will not solve the problem but at best relocate it. In addition, recycling alone is not enough: prevention and reduction of plastic use are also crucial to shrink the waste stream at the source. The reality is simple: as long as it remains cheaper to export or evade waste than to process it sustainably, the system remains leaky.

Plastic policy also requires Dutch action

Unfortunately, policy lags behind. Important decisions on fiscal measures were postponed by Jetten I and were missing from the Spring Memorandum, meaning uncertainty remains for the sector and investments in recycling and circular solutions fail to materialise.

At the EU level as well, the next step will be decisive. The announced Circular Economy Act must not just be a recycling package, but must focus on reducing primary material use, stricter controls on imported recyclate, harmonised end-of-waste criteria and stronger incentives for reuse, prevention and European recyclers. Zero Waste Europe calls for fiscal incentives on primary raw materials and reform of rules that make producers responsible for their waste, so that they do not only finance waste management, but also enforce circular design, reuse and waste prevention. vv

The Climate Citizens' Assembly also advises a plastic standard and a levy. Although the government is adopting about half of the Assembly's recommendations, proposals such as a levy on fossil plastic and a mandate for more recyclate are being investigated further. Jetten I is postponing the measures once again.

If the Netherlands, the ultimate European transit hub for plastic waste, wants to prevent more waste smuggling, the cabinet must make decisions: better enforcement, reliable data, support for recycling companies and a fair price for new plastic.