OPINION: On 21 November 2025, the EU entered the final year before the implementation of the revised Waste Shipment Regulation (EU) 2024/1157. This will ban all plastic waste exports from EU member states to more than 160 non-OECD countries. While on the surface this move will place the legislative protection in place that limits member states – which, if you haven’t been paying attention, the UK is not – outsourcing the treatment of plastic waste to developing countries. But the question remains: what will happen to the estimated 7.5 million tonnes of plastic waste currently being generated across the region?
Like recent calls from some in the UK to ban all plastic waste exports, which is a potentially positive step that could create certainty and confidence in the sector, opening the way for long-term investment, the risk remains for what happens to the material. In contrast, the investment is being made, and the infrastructure is being built. Within the legislation, there is scope to expand the current exemptions for “less hazardous” waste, such as paper and metal, to include plastics from 2029. What should be absolute certainty is still tinged with grey.
While there are some positive indicators of investment in the space, such as the Omra facility (a Tomra/Plastretur joint venture in Norway), this barely moves the needle on NET processing capacity, given the loss of plants across Europe. With nearly one million tonnes of processing lost since 2023 and future investments either stalling or being cancelled altogether, how Europe intends to deal with the material remains unclear.
However, unlike the calls in the UK for an outright ban, limiting exports to countries that lack the infrastructure, environmental and labour standards, or the ability to provide transparency and traceability does leave the door open for exports to countries that do… such as the UK.
So, is there an opportunity for the UK amongst these shifting global supply chains? The markets do not seem to think so. Outside of two significant investments by both Enviroo (food-grade rPET recycler due online in 2027) and Veolia (tray-to-tray recycling), the appetite remains limited despite the significant gap identified in the UK’s projected capacity and the opportunity to benefit from material currently destined for Asia, finding a home over the channel.
The challenge will always be quality, and with all restrictions on waste movement, it is the hard-to-recycle, low-value material that remains an issue, regardless of where it ends up. The gap between OECD and non-OECD countries has continued to widen as policies have consistently driven higher recycling rates, greater collection coverage, and reduced landfill use. Yet the loss in capacity has continued unabated. Not least because, alongside the positive steps taken, they have been met with growing costs in both labour and energy, making the finished goods less attractive to either imports or virgin materials.
The UK is no immune to these issues, and for materials that need a heavy input of both these costs, profit margins remain elusive. There is also a risk that the current misalignment between EU and UK policies post-Brexit provides an opportunity for less responsible operators to treat domestic recyclers as simply a gateway to “business as usual” through continued exports to the newly banned territories. While inter-agency cooperation is expected across members’ state regulators and the respective devolved governments’ authorities, the sheer volume of material seeking a home could trigger a tsunami of challenging waste streams heading our way. Is this what Brexit was designed to achieve, to make the UK Europe’s trafficker of illegal waste shipments?
But what about chemical recycling? Doesn’t that provide options for hard-to-recycle streams that would traditionally be exported? Of course, there remains interest and investment in this space. Recent months have seen funding for projects in Sleaford and Middlesbrough announced, yet the quality, specifications, and scalability remain unproven. With quality still a driver in this space, it doesn’t address the issues at the bottom of the quality spectrum.
As a proponent of global circularity, I have always called for a pragmatic approach to managing the recycling supply chain. Unilateral prohibition shifts the problem to another part of the world. While the fundamental issues of high energy and labour costs remain consistent across the developed world, the expectation that waste can be handled at the source is naïve. Robust regulations exist to ensure the responsible exportation and management of waste, creating a localised investment environment that enables high-quality, technology-focused, responsible recyclers.
Demand for cheaper consumer goods has driven the creation of products that become waste, fostering vibrant manufacturing capabilities across the world. Why should the solution to the inevitable end of the life of these goods be any different?
Harmonising simple concepts, such as waste classification, could enable better understanding and collaboration between agencies. While Turkey and the UK recognise the same EWC code for plastic waste, they differ on how waste is classified, leaving loopholes that can be exploited. Brexit offered many things, and in the case of our ability to take a leading role in the Global Circular Economy, it is there for the taking, rather than simply following 18 months later and pushing the problem onto someone else.
Subscribe for free