Annex VII Explained
A working walkthrough of green-list (Article 18 / B3011) plastic shipments: who signs what, the consignee contract, take-back obligations, record retention — and what makes a load non-compliant.
The two regimes for waste shipments
International waste shipments run under one of two procedures. Notified shipments require prior written consent from every competent authority involved — slow, expensive, and used for hazardous and problematic wastes. Green-list shipments under Article 18 of the Waste Shipment Regulation move without prior consent, accompanied by a completed Annex VII form, provided the waste meets the relevant green-list entry.
For plastics, that entry is B3011: plastic waste destined for recycling, consisting almost exclusively of a single polymer (or otherwise meeting the entry's narrow mixture conditions), sorted and almost free from contamination. Every consignment we ship — LDPE film, HDPE bottles, PET bottles, PP, PA — is prepared to meet B3011, because failing it converts a routine container into an illegal shipment.
The Annex VII form, block by block
The form is one page. Its power is that it names real parties who carry real obligations:
| Block | Content | Who it binds |
|---|---|---|
| 1 | Exporter / person who arranges the shipment | The UK entity legally responsible — us |
| 2 | Importer / consignee | The Turkish reprocessor receiving the material |
| 3–4 | Actual quantity and date of shipment | Reconciled against weighbridge tickets |
| 5–6 | Carrier(s) | The hauliers and shipping line |
| 7 | Waste generator / new producer | Where the material arose |
| 8 | Recovery operation code | R3 (recycling of organic/plastic substances) |
| 9 | Waste identification | B3011, HS code, description |
| 10–11 | Countries concerned | UK → transit states → Türkiye |
| 12 | Signature of the person who arranges the shipment | Legal declaration the information is correct |
Signing Block 12 is not a formality: it is a declaration, by an identifiable person at a UK-jurisdiction entity, that the shipment complies. That signature is what regulators pull on when something is wrong. We sign a lot of them, and we intend every one to be defensible. A downloadable annotated sample is available at the end of this page.
The contract behind the form
Article 18 requires a contract between the person who arranges the shipment and the consignee to be in force when the shipment starts. It must oblige the consignee to recover the material in accordance with the regulation, and — the clause people forget — oblige the shipper or consignee to take the waste back if the shipment or recovery cannot be completed as intended. Our consignee contracts carry these clauses verbatim, alongside the commercial terms. If a counterparty resists a take-back clause, that tells you everything about their confidence in their own licence.
Record retention
Annex VII documents must be kept for at least three years from the start of the shipment, by all three parties: arranger, consignee and carriers. Our shipment files bundle the Annex VII with the contract reference, waste transfer notes, loading photographs, weighbridge tickets and the arrival confirmation, so the three-year duty is satisfied with a single retrievable file per container.
What makes a load non-compliant
The recurring failure modes, all avoidable:
- Mixed polymers — a "film" bale containing PP strapping, PVC or laminates beyond the B3011 conditions.
- Contamination — food residue, oil, moisture, soil; "almost free from contamination" is judged on what inspectors find, not on intentions.
- Wrong classification — shipping material as green-list when its condition requires notification.
- Paper mismatch — quantities, consignees or HS codes on the Annex VII that do not match the physical load or the customs declaration.
- Unlicensed consignee — the Turkish end lacking the licence or quota for the material; see our Türkiye import guide.
Our controls map one-to-one against this list: single-polymer acceptance specs, photographic grading before purchase, pre-shipment inspection, document assembly by people who read the customs entry, and consignee verification before contract.
Why suppliers should care
If you sell scrap, your company's name sits in Block 7 of someone's Annex VII. When exporters cut corners, the investigation reaches backwards through that form. Selling to a documented, registered, take-back-contracted exporter is not bureaucratic comfort — it is how you keep your company out of other people's enforcement files.
This page is general guidance, not legal advice. See the "last reviewed" date above.