Tunis - In July 2025, the European Commission indicated that it had received around twenty requests from non-OECD countries for inclusion on list of countries eligible to import non-hazardous waste from EU, including Tunisia.

In line with the European Green Deal and second EU Circular Economy Action Plan, the new Waste Shipments Regulation establishes a new regime for the shipment of waste within the EU, as well as for imports and exports of waste into and from the EU.

The goal is to ensure that, instead of exporting its waste problems, the EU contributes to the environmentally sound management of waste, and better addresses the illegal trafficking of waste.

Tunisia has thus requested authorisation to import various categories of non-hazardous waste, including metals, recyclable plastics, rubber, industrial fibres, paper, textiles, as well as certain ceramic and organic waste from the agri-food sector.

In this regard, TAP submitted an official request to the Ministry of Environment seeking clarification on this new import and its purpose, five years after the case of Italian waste illegally imported into Tunisia, a case that had sparked national outcry and led to the arrest of senior officials, including a former minister.

As the national focal point for the Basel Convention, representing Tunisia before international bodies on all matters relating to waste transfers, the Ministry of Environment indicated that it had coordinated with the stakeholders, namely the Ministry of Trade, the Ministry of Industry and the Tunisian Confederation of Industry and Trade, to determine which waste they wish to import and to oversee the procedure with the European Commission.

In its response, the Ministry of Environment also emphasised that the import of hazardous waste, as defined by national legislation, remains prohibited and can only proceed with the approval of the Ministry of Trade, following consultation with other concerned ministries.

Strengthened European regulatory framework

For Hamdi Chebâane, a waste management expert, imports of waste from the European Union are not new for Tunisia.

"Tunisia has always imported waste from the EU. What is new is that the latter has renewed and tightened its laws as part of the ecological transition," he explained to TAP.

He pointed out that the country already imports certain waste intended for recycling or energy recovery, notably paper and certain rubbers.

However, the import of used oils and certain plastics has been halted. The main change now lies in European requirements: "The European Union requires an official request from the State and confirmation that recipient companies are capable of recovering the waste received and reintegrating it into the economy," he specified.

The expert also emphasised the need for greater selectivity, particularly concerning second-hand clothing.

"Authorities must decide precisely what should be imported and be more selective," he stated, adding that the import of second-hand clothing depends on several administrative authorisations and customs controls.

He thus called for the establishment of a clear list of authorised and strictly prohibited waste, as well as the requirement for a recycling and recovery capacity certificate for concerned companies, to avoid any drift comparable to the Italian waste case.

Hamdi Chebâane also called for broader consultation between the Ministry of Environment, the National Waste Management Agency (ANGED), the relevant ministries and the sector stakeholders, taking into account Tunisia's international commitments under the Basel, Bamako and Copenhagen conventions.

He further recalled that Tunisia also exports certain waste and scrap of non-ferrous materials to the European Union, within a strict regulatory framework providing for bank guarantees and compliance with international conventions.

National capacities under pressure

Nevertheless, the question of national capacities remains. Indeed, to obtain authorisation to import waste, candidate countries must provide the European Commission with detailed information on the facilities intended to receive it and demonstrate that it will be treated in structures authorised to carry out recovery operations, in accordance with Article 42 of the European regulation.

Yet the question remains: can Tunisia, where landfilling remains the primary mode of waste management, realistically import additional waste when it struggles to manage its own?

To this question, Samia Gharbi, an environmental science expert, is categorical: "A country that does not control its own waste should not import more."

Tunisia already faces significant difficulties in managing its municipal and industrial waste, with saturated landfills and toxic waste stored without adequate treatment, representing a major risk to groundwater, soil and air, she underlined.

How, she asks, under these conditions, can it guarantee rational and ecological management of imported waste?

Tunisia is already facing a major environmental emergency. In 2022, it generated approximately 3 million tonnes of municipal solid waste, a volume that could reach 6 million tonnes by 2050, according to a World Bank report published last January.

Each Tunisian produces an average of 0.80 kg of waste per day. While the collection rate reaches 72%, the cost of environmental degradation linked to imperfect management already amounts to USD 155 million (equivalent to TND 442 million) per year, the report further emphasises.

Today, this waste is visible everywhere, notably rubble and building materials littering roads and agricultural areas. These materials contain persistent organic pollutants (POPs) and represent a real danger to the environment.

"We are not capable of managing these existing wastes, so how can we import more?" the expert insists.

Analysing the list of waste Tunisia wishes to import, Samia Gharbi focused particularly on electrical and electronic waste (WEEE), which contains brominated flame retardants and plastics that are difficult to recycle.

"What will we do with the plastic from this waste? Will it actually enter the cycle?" she asks, specifying that many administrations already store millions of electronic waste items without a viable solution.

The country generates approximately 100,000 tonnes of WEEE for around 120,000 tonnes of equipment distributed, according to ANGED.

Other categories on the list also pose problems: textiles, tyres, battery slag or industrial ash. According to the expert, Tunisia already has large quantities of these wastes but lacks the infrastructure and technologies needed to treat them properly.

Waste remains a concern until its life cycle is clearly established

Even if these wastes are classified as "non-hazardous", this does not guarantee their harmlessness. "Any waste remains a concern as long as its life cycle, composition and treatment pathway are not clearly established," she explained.

The "non-hazardous" classification must remain conditional on the lack of persistent contaminants. Even the European Union requires rational management of these flows, aware of potential risks.

Furthermore, she pointed out, the list includes vague categories, such as "other metallic waste" or "other inorganic waste", raising serious questions about traceability and control.

Samia Gharbi considered that the priority must be to recover waste already present. Tunisian sectors are not yet sufficiently clear to ensure rational management, and opening up to new flows could increase environmental challenges.

She recalled that the Italian waste case remains a striking example of the risks associated with importation without rigorous control.

Given that eligible countries will be authorised to import these wastes after May 21, 2027, the countdown has begun. Tunisia will then need to demonstrate that it has the means and infrastructure necessary to manage these flows in a rigorous and transparent manner.

Otherwise, these new imports could add to the environmental fragilities already identified.

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