Combatting waste crime

Illegal waste trafficking shows some specifics. In its 2011 report, Europol suggested that while mafia-style structures are able to participate in illicit large-scale waste management, there is evidence that smaller organisational structures are involved in the illegal export of waste and that these structures cooperate with legitimate businesses in the financial services, import/export, and metal recycling sectors.

Several studies on illegal waste transport have shown that the criminal actors in the waste sector are not only members of organised crime groups, but also people in business operating in the legitimate economy who have decided to turn to the black market (i.e., white-collar criminals). In most cases, this involves criminals operating at the transnational level, in particular those subjects who serve in the role of “brokers”. To reduce their costs and generate further profit, they are likely to avoid the duties associated with the correct and environmentally sound treatment of waste. Some reports highlight the importance of brokers and traders to the shipment of WEEE to Africa. These African-based waste tourist and brokers serve the European–African trade routes, either with small family-based and larger well-organized trading firms. They are difficult to track and often use false passports to periodically visit the EU to secure WEEE. Brokers are also linked to the legal/ illegal interface as legal intermediaries for illegal shipments. Also involved are metal dealers known to feed into unlawful transports. Shipping lines and terminal lines could be accused of a lack of due diligence, whereas shipping agents and expeditors may play a more deliberate role.

The Enforcement Action II project (IMPEL, 2011) describes a series of shipment inspections which occurred over 2 years (2008–2010) with the participation of 29 European countries. Of the 833 waste shipments found to be in violation, 52 % related to administrative violations, mainly relating to missing or incomplete documentation or contamination issues. The remaining 48 % could be regarded as more serious illegal exports where either notification to the regulatory agencies should have been made or where export was explicitly prohibited (hazardous waste). In terms of specific materials, the violations could be summarized as paper and cardboard (18 %), metals (16 %) and plastic (16 %). All had missing documentation (errors in paperwork) or contamination issues (possibly unacceptable levels of contrary materials). WEEE (14 %) was subject to export bans or missing documentation, while end-of-life vehicles (ELVs)/vehicle parts/tyres (5 %) were illegal exports without notification.