EU and cross-border transportation of waste Cologne, June 23rd, 2004

Theory versus reality

Who is Future Green One of Europe’s largest inkjet remanufacturers Emphasis on environment Awarded by various governments Well known at large companies: – ABN AMRO bankHeineken – Dutch Tax officeSHELL – Police departmentsKLM – UNICEFMETRO One of Europe’s largest inkjet remanufacturers Emphasis on environment Awarded by various governments Well known at large companies: – ABN AMRO bankHeineken – Dutch Tax officeSHELL – Police departmentsKLM – UNICEFMETRO

Our motto: Turning waste into value

Locations per Factories in: Netherlands Hungary Sales offices and Cartridge Return Centres (CRC’s) in: Netherlands Belgium Serbia-Montenegro Hungary Austria Switzerland Italy

Cross-border transportation 6 foreign companies International buying selling of empties 6 foreign companies International buying selling of empties

What is waste Overall legislation in EU: EVOA Regulation about supervision and control on the transportation of waste within, from and to the European Community

Characteristics of a Eur. Regulation: Directly applicable Binding for all parties concerned Works the same in all member-countries Will not be translated into national legislation, national decision making on items such as – Financial security – Penalties Directly applicable Binding for all parties concerned Works the same in all member-countries Will not be translated into national legislation, national decision making on items such as – Financial security – Penalties

EU Regulation on the supervision and control of shipments of waste This Community Regulation (EEG 259/93 of 1 February 1993, in The Netherlands commonly referred to as EVOA) was implemented in This European regulation is aimed at overseeing flow of waste and at preventing unwanted removal - for instance to Third World countries.

The basic principle of the European policy is that waste materials have to be processed as much possible in their land of origin and in the nearest processing plant. The export of waste materials can however not always be avoided. EVOA was set up by the European Union with the aim of harmonising the rules of exporting waste materials. The regulation outlines various procedures concerning cross-border trafficking of waste materials. The procedures to be followed depend on the kind of waste material, the sort of removal and the status of the country or countries involved in the actual cross-border trafficking.

A definition of waste Each item of which the holder disposes of, wishes to dispose of or should dispose of. To dispose of can mean: – Final removal – Useful application

A wide definition Jurisprudence of the European Court of justice is binding. A product can be categorised as waste, even if it has commercial value: – Broken 2 nd hand goods – Inkjet cartridges Jurisprudence of the European Court of justice is binding. A product can be categorised as waste, even if it has commercial value: – Broken 2 nd hand goods – Inkjet cartridges

Criteria non-waste 1 Equal to primary raw material Same characteristics as raw material No other pollution than with a primary raw materials Can be used directly, without waste related pre-treatment, in a production process Used for the same purpose as the initial use Equal to primary raw material Same characteristics as raw material No other pollution than with a primary raw materials Can be used directly, without waste related pre-treatment, in a production process Used for the same purpose as the initial use

Criteria non-waste 2 Produced on purpose (no residue) No extra risk No extra precaution necessary No negative value Regular market Produced on purpose (no residue) No extra risk No extra precaution necessary No negative value Regular market

And still Empty cartridges are considered waste ??

3 kinds of waste Green list (toner cartridges) Yellow list (inkjet cartridges) Red list (mix of toner and inkjet cartridges) Green list (toner cartridges) Yellow list (inkjet cartridges) Red list (mix of toner and inkjet cartridges)

Cartridges according to EVOA and EURAL EVOA: – Toner cartridges: Code GC 020 – Inkjet cartridges: Code AD 070 Eural (Overall listing of waste material): – Toner cartridges – Inkjet cartridges EVOA: – Toner cartridges: Code GC 020 – Inkjet cartridges: Code AD 070 Eural (Overall listing of waste material): – Toner cartridges – Inkjet cartridges

Procedures, theory versus reality Toner cartridges: Green list, no permit needed Inkjet cartridges: Yellow list, permit needed. But, for instance Hungary categorises Toner cartridges under yellow list, so permit is needed. Toner cartridges: Green list, no permit needed Inkjet cartridges: Yellow list, permit needed. But, for instance Hungary categorises Toner cartridges under yellow list, so permit is needed.

No escape Not only the sender is responsible for the proper documentation and administration, so is the receiver

Documents needed Notification Transport document Notification Transport document

Cross border transport NL-HU Start: NL Through: Germany and Austria End: Hungary Permits needed: NL, GER, AUS, HU Start: NL Through: Germany and Austria End: Hungary Permits needed: NL, GER, AUS, HU

Hire an expert European rules are complicated and are not equally applied in all countries

Thank you for your attention