Exporting Scrap Metal and Waste from Spain: Waste Dealer or Broker Registration, Green List and Prior Notification

Regulation (EU) 2024/1157 on waste shipments (the EU Waste Shipment Regulation) entered into force on 20 May 2024. Most of it applies from 21 May 2026 and the majority of export rules apply from 21 May 2027. Since May 2026, everything is processed electronically through a central EU system (DIWASS): Annex VII, prior notification, confirmation of receipt and the certificate of recovery.

In Spain, MITECO (the Spanish Ministry for the Ecological Transition) authorises shipments to or from countries outside the EU, while the autonomous communities authorise shipments with other Member States and domestic shipments under Ley 7/2022 (the Spanish Waste and Contaminated Soils Act).

Keeping one basic rule in mind avoids many mistakes: scrap metal remains waste until it ceases to be waste in accordance with end-of-waste criteria. Buying and selling it does not turn it into a raw material.

A waste dealer (negociante) is anyone who buys and sells waste on their own account, and a waste broker (agente) is anyone who arranges its recycling or disposal on behalf of others, even if neither takes physical possession of the waste. A trader who buys from repair shops and scrapyards and sells to a foreign foundry is a waste dealer even if the load goes straight from origin to destination.

Both must file a prior communication (comunicación previa) with the autonomous community where their registered office is located (artículo 35 de la Ley 7/2022). It is not an authorisation: you can operate as soon as it is filed, the autonomous community registers it and it is valid throughout Spain. It is filed for specific wastes identified by their LER codes (European List of Waste codes), and your activity must match what you declare.

Registration is essential for exporting: Regulation 2024/1157 requires a waste dealer to be authorised or registered in order to arrange a green-list shipment (artículo 18.2), and only allows a registered dealer to act as notifier (artículo 5.1).

If you also store, sort or treat waste at your own facility, you need a waste manager authorisation (autorización de gestor) from the autonomous community, accompanied by a technical project: it is decided within 10 months, administrative silence means refusal, and it lasts for up to 8 years, automatically renewable following a favourable inspection.

Managora files your prior communication under the mandate you sign: we assign the LER codes, complete your autonomous community's form and send you the filing receipt and registration. We never ask for your digital certificate. You can see the current fee on our service page.

This depends first on the waste itself and what will be done with it (recovery or disposal); the destination country comes second. The green list comprises Annexes III and IIIB and the mixtures in Annex IIIA: if those wastes are destined for recovery and exceed 20 kg, no prior notification is needed; Annex VII and a contract are sufficient (artículo 18).

Prior written notification and consent are required for shipments destined for disposal and, if destined for recovery, for wastes in Annex IV, hazardous wastes, wastes with no specific entry in Annexes III, IIIB or IV, mixtures not listed in Annex IIIA, green-list wastes contaminated to an extent that increases their risks or prevents environmentally sound recovery, and wastes exceeding persistent organic pollutant limits.

Clean scrap separated by metal type is the natural candidate for the green list; scrap mixed with plastics, oils or hazardous components may fall outside it. That is why each batch must be classified under its own code rather than copying the code from a previous shipment.

Watch out for WEEE (RAEE, waste electrical and electronic equipment): until 31 December 2026, non-hazardous WEEE (GC010 and GC020) moves between Member States under artículo 18. From 1 January 2027, all WEEE shipped within the EU is classified as Y49 or A1181 and requires prior notification.

The person who arranges the shipment completes Annex VII with as much information as possible no later than 2 working days before the shipment starts. The actual quantity, the carrier and the container number can wait until before departure. All companies involved complete their part and make it electronically accessible, including during transport; if that fails, the information must accompany the vehicle.

If the person arranging the shipment is not the original producer, they must ensure that the producer also signs where practicable. If the destination is an interim recovery operation, the subsequent facility and subsequent R codes must be indicated.

The destination plant must be authorised or registered as a recovery facility and show you its authorisation before the shipment. It confirms receipt within 2 working days and issues the certificate of recovery no later than 30 days after completion of recovery and within 1 year of receipt.

The contract with the consignee must be in force no later than when Annex VII is completed, and remains in force until the certificate is issued. The facility operator also signs it if they are not the consignee. It identifies the parties, the waste with its codes, the quantity, the operation and the term of validity, and includes the obligation to take back the waste if the shipment or recovery fails or is illegal.

Managora prepares the classification, Annex VII and the contract with its mandatory clauses; you sign them as the person arranging the shipment.

The notifier submits it through the electronic system to all authorities concerned: in Spain, MITECO if the waste leaves the EU, and the autonomous community if it goes to another Member State. It includes the notification document (Annex IA) and the movement document (Annex IB), each with a single waste code unless an exception applies.

The original producer may act as notifier; the new producer, the collector and the waste dealer may only do so if permitted or registered. The waste dealer or broker must also attach written authorisation from the producer, new producer or collector to act on their behalf.

You must provide a copy of the contract with the consignee and a declaration that it exists, together with a declaration that a financial guarantee or equivalent insurance has been established (if the authorities allow it, proof of this may be submitted later, no later than with the movement document). The notification covers the entire journey up to final recovery or disposal.

No lorry leaves without written authorisation. We prepare the entire file and the notifier submits it, signs it and assumes liability.

Exporting waste outside the EU for disposal is prohibited, except to EFTA countries that are Parties to the Basel Convention and subject to conditions. Scrap metal exported for recycling is not covered by that prohibition, but it is subject to destination rules.

From 21 May 2027, green-list waste may only be exported to non-OECD countries included on the Commission's list. Countries had until 21 February 2025 to apply and the draft list was published on 18 September 2026. If your buyer is outside the OECD, check this before signing contracts that run past that date.

Then there is customs. The export declaration is filed by your company or a registered customs representative; we prepare the waste shipment file (Annex VII or authorised notification, contract and authorisations) so that it matches the customs declaration. To export, you also need an EORI number.

Within Spain, shipments travel with an identification document and, in certain cases, prior notification, to which the authority may object within 10 calendar days.

Recovered waste ceases to be waste if it meets 4 conditions: it is used for specific purposes, a market or demand exists for it, it fulfils the technical requirements and product standards, and its use will not lead to overall adverse environmental or human health impacts (artículo 5 de la Ley 7/2022).

For certain metals there are EU end-of-waste criteria: Regulation (EU) 333/2011 for iron, steel and aluminium scrap and Regulation (EU) 715/2013 for copper scrap. They require conditions on input waste, treatment and final quality, plus documentation and quality management; the copper regulation also requires a statement of conformity for each consignment.

Where no EU or national criteria exist, the autonomous community may grant end-of-waste status on a case-by-case basis, at the request of the waste manager and within their treatment authorisation, for use in a specific industrial activity or process within that autonomous community or in another autonomous community subject to a favourable report from the latter. Such a declaration therefore does not cover a buyer outside Spain.

In practice: anyone exporting scrap metal that meets the EU end-of-waste criteria is moving a product; anyone exporting untreated scrap is moving waste and needs registration and shipment documents.

The Critical Raw Materials Act (CRMA, Regulation (EU) 2024/1252) sets a 2030 benchmark for recycling to cover 25% of the EU's consumption of each strategic raw material, including rare earths for magnets. This is an EU-wide target, not an obligation for each individual plant. Strategic processing or recycling projects have a maximum permit-granting timeframe of 15 months, and in Spain facilities researching new waste treatments only require a prior statement of compliance (declaración responsable previa, artículo 34.3 de la Ley 7/2022).

Operators of tailings ponds or waste rock dumps at active mines must submit a preliminary study on the recovery of critical raw materials from that extractive waste to the mining authority by 24 November 2026 at the latest, unless they prove that it does not contain them in a recoverable form.

Products containing magnets listed in the CRMA (motors, wind turbines, vehicles, household appliances) will carry a label indicating the type of magnet and a data carrier with its weight, composition and removal instructions. If NdFeB, SmCo or AlNiCo magnets weigh more than 0.2 kg, the responsible party must publish the recycled content percentage for each metal by 24 May 2027 at the latest, or 2 years after the delegated act if later.

In its RESourceEU plan (3 December 2025), the Commission announced that it would propose, no later than the second quarter of 2026, restricting the export of permanent magnet scrap and waste. If you export used magnets or waste containing them, check before signing each contract whether that restriction has already been proposed or adopted.