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The CIT Seminar on “Waste Management and transport by rail” took place in Geneva on 7 May 2024 and was hosted by the Secretariat of the Basel, Rotterdam and Stockholm Conventions (BRS).
Since 2023, CIT has been involved in issues relating to the cross-border transport of waste and its management in rail transport. The ad hoc Waste Expert Group led by CIT in cooperation with UIC (see this article in CIT News 2/2023) is dealing with these issues and CIT already held a dedicated workshop on these issues in Bern in October 2023.
The seminar was divided into four thematic panels. The first panel focused on regulatory aspects and started with the relationship between the RID (Appendix C to COTIF), as the regulation governing dangerous goods, and hazardous/non-hazardous waste with a presentation by Jochen Conrad (OTIF, Dangerous Goods Department). The provisions on waste in the RID were detailed with further explanations on the connection between the RID and the Basel Convention. It is important to note in this context that the list of hazard characteristics used in the Basel Convention corresponds to the classification used in the RID and the dangerous goods regulations applicable to other modes of transport. New RID provisions on waste in 2025 will update the regulation in this area and were outlined at the seminar.
Yorg AERTS (European Commission, DG ENV) presented the new European Regulation (EU) 2024/1157 on Waste shipments published in the Official Journal of the EU on 30 April 2024. The new regulation repeals Regulation (EC) No 1013/2006 and from 21 May 2026 will apply to shipments of waste between EU countries, waste imported into the EU from non-EU countries and waste exported from the EU to non-EU countries. The primary objective of the new regulation is to facilitate shipments of waste within the circular economy in the EU by digitalising procedures (Article 27 of Regulation (EU) 2024/1157 is on “Electronic submission and exchange of information”) and introducing a central system for this purpose, with improved traceability of waste movements and better harmonization of waste classification (Regulation (EU) 2024/1157, Preamble (37) and Article 61 §7). The European Commission also explained that the regulation embodies a commitment to tackle waste trafficking, with its antifraud office (OLAF) given powers to investigate in this matter, an EU-level group established for coordination and cooperation on enforcement, and procedures of inspection and penalties introduced in response to these offences. There will be many challenges in implementing these new regulations over the coming months, as the eFTI regulations come into force in August 2024 and the digital tools for these electronic data exchanges are put in place.
Ethem Pekin (Community of European Railway and Infrastructure Companies, CER) reacted to the EU Commission’s presentation by reminding participant that the EU Circular Economy Action Plan aims to connect waste policy with product policy. CER welcomed the digitalisation of procedures and explained that the rail sector will actively contribute to the implementing and delegating acts, which can bring relevant and needed improvements and clarifications, in order to deliver the goals of the new waste shipments regulation. CER also published an article on the same topic recently, available here.
The second panel focused on operational issues, with three representatives of carriers and intermodal operators (Kombiverkehr Gefahrgut, SBB Cargo International, Hupac) who manage and transport waste on a daily basis and who are experiencing problems at different levels - technical, regulatory, and administrative. After explaining how waste is transported in intermodal traffic, the experts took some examples of a transport chain in intermodal traffic, notably from Italy to Sweden with seven different RUs involved. In practice, the transport of waste is very complex and not suited to rail (Regulation (EC) 1013/2006 with the management of Annex IB – Movement document and the Annex VII Document on information accompanying shipments of waste). On the basis of this postulate, in this second panel the CIT GS presented a legal overview of the current regulatory framework (Regulation (EC) 1013/2006, eFTI Regulation and the new Regulation (EU) 2024/1157) and the analysis already done by the sector within the Waste Expert Group since 2023.
CIT is seeking concrete solutions to facilitate relations between carriers, railway undertakings and intermodal operators with appropriate transport documents, such as:
- CIM Consignment Note for combined transport, supporting documents on handling difficulties,
- Info table on provisions for the organisation and carriage of waste
- Checklist on the reporting of irregularities in the international carriage of dangerous goods and waste by rail.
The issue of liability of all stakeholders in the transport chain was a decisive aspect of the presentation and legal analysis provided by CIT. The pivotal role played by freight terminals in the transport chain is vital to the smooth running of transport and exchanges with rail companies. The possibility of inviting the terminals to a forthcoming event or meeting would be relevant.
In the third panel, Tatiana Terekhova from the Secretariat of the Basel, Rotterdam and Stockholm Conventions (BRS) presented the most recent developments under the Basel Convention, on controlling transboundary movements of waste and key stages of the procedure, which includes notification, consent and issuance of the movement document, the transboundary movement, and confirmation of disposal. The competent authorities in each country are responsible for this PIC (Prior Informed Consent) procedure. Environmental issues and the fight against illegal international waste trafficking are also central to the work of the BRS Secretariat. Also, in relation with the EU Commission’s presentation, the BRS is discussing options to digitalise the PIC Procedure in a working group established in 2022. It is therefore interesting to note that digitisation initiatives are also taking place on the side of the administration and competent authorities of the countries involved in cross-border waste management.
The last panel of the seminar was dedicated to CIT’s proposals to facilitate the work and management of waste transported by railway undertakings and carriers. The introduction of an optional checklist relating to irregularities in this type of transport can fill in the gaps and shortcomings in the transport documents exchanged between carriers. An info table can also be created summarising all the points to which rail carriers need to pay attention when transporting waste. Finally, adaptations to the CIM consignment note could be developed to meet the needs and particularities of waste transport within this tried-and-tested essential document with the digitalisation of the main functions and including the new codes for international codes for waste carriage by rail through RailData’s ORFEUS System 1.6. In addition to the documentary details explained by the CIT GS, Matthias Mächler from Raildata provided concrete examples of what is being done and will be done to develop the digital tools used by rail carriers to better manage transport data and documents for waste shipments. Summing up, the CIT General Secretariat emphasised the development of legal functionalities to help give rail carriers greater legal certainty for waste management.
The challenges posed by the implementation of the new regulation on waste shipments between now and May 2026 will drive the sector and all parties involved. In the meantime, CIT will be implementing some products to meet carriers’ needs: information table, CIM Consignment Note with adaptations for additional functionalities, and a Checklist for monitoring irregularities during carriage. All this work will continue within the framework of the CIM Working Group and the Expert Group on Waste, whose next online meeting will take place at the beginning of July, and within the framework of CIT's cooperation with the UIC Freight Department, OTIF Dangerous Goods Department and CER Circular Economy Department, as well as with all the stakeholders and experts in waste sent by rail. By the sector, for the sector.