Cross-border waste paper shipments in 2026 new rules and risks for Germany

In 2026 companies in the German waste paper industry are facing significant changes in how recovered paper can be shipped across borders.

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New EU rules on waste shipments aim to protect the environment, improve traceability and tighten export controls outside the European Union.

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EU waste shipments regulation updates

On 20 May 2024 the EU adopted a revised Waste Shipments Regulation to update the rules that govern the movement of waste within the EU and beyond. Many of the new procedures will become mandatory from 21 May 2026 and apply fully by 21 May 2027.

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The aim of this legislation is to ensure that exported waste is managed in an environmentally sound way, to increase transparency in shipment tracking and to reduce illegal waste trade.

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What the changes mean for recovered paper trade

1. Stricter Export Controls

In 2023 the EU exported around 35 million tonnes of waste outside its borders. Almost half of this went to non-OECD countries.

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Under the new rules, exports of waste (including paper) to countries outside the OECD will require those countries to formally notify the European Commission and demonstrate they can manage the waste sustainably before they are approved as import destinations.

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This change introduces new administrative steps and potential delays for waste paper exporters in Germany that have traditionally shipped materials to Asia and other regions.

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2. Digitalised Documentation

From May 2026 all notifications and shipment documents will be handled digitally in a central EU system. This aims to improve traceability of waste shipments and reduce paperwork.

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Exporters must ensure accurate classification and documentation for recovered paper to avoid fines or shipment blocks. Even non-hazardous paper waste may require movement documents and prior consent in some cases.

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New risks for German recovered paper exporters

These regulatory updates create several strategic risks for companies involved in cross-border waste paper shipments:

• Export restrictions for some destinations could reduce market access for secondary raw materials.
  
  
• Increased compliance burden with digital notifications and stricter audit requirements for facilities outside the EU.
  
  
• Longer lead times for approvals as importing countries seek listing with the EU for permitted waste imports.
  
  

Industry representatives have warned that these tighter rules could disrupt established trade flows and require more robust compliance systems in 2026 and beyond.

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Opportunities in the EU internal market

On the positive side, the revised regulation also facilitates waste paper shipments within the EU where consistent recycling quality and certification can support smoother transfers across member states.

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Germany’s central location and strong recycling infrastructure position it well to benefit from intra-EU trade in recovered paper as export routes outside the EU become more regulated.

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For the German waste paper industry, 2026 marks a turning point in cross-border trade. With stricter export rules, digital documentation and environmental compliance at the forefront, companies that invest in compliance systems and stay ahead of regulatory updates will be better positioned to navigate the changing landscape.

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Managing shipment quality, accurate classification and proactive engagement with authorities will be key to maintaining access to global and EU markets in the years ahead.

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