This chapter examines how trade facilitation can support environment-related requirements across the product lifecycle. Using the OECD environment-related Trade Facilitation Indicators, it assesses how requirements linked to sourcing, production, use, circularity and end-of-life management are integrated into border systems. Results point to progress in transparency of trade-related information and basic digitalisation, but more uneven performance in interoperability, co-ordinated risk management and domestic and cross-border agency co-operation.
Better Borders for Trade, Traceability and Enforcement
3. Tracing product lifecycles requires trade facilitation adaptations
Copy link to 3. Tracing product lifecycles requires trade facilitation adaptationsAbstract
The carbon-intensity case examined illustrated a broader shift: border processes need to accommodate more and more information that originates across product lifecycles and complex supply chains. This raises a more fundamental question about the readiness of trade facilitation systems to support such requirements efficiently and at scale.
Using the OECD environment-related Trade Facilitation Indicators (env-TFIs), this chapter assesses how environmental requirements are integrated into border systems across OECD economies. By examining challenges associated with different stages of the product lifecycle, it evaluates the extent to which trade facilitation tools are evolving to support more information-intensive forms of trade and identifies where important implementation gaps remain. Many of the environmental requirements captured by the env-TFIs depend on the collection, transmission and use of product- and supply chain-related information across multiple actors and jurisdictions. The indicators therefore provide a useful lens through which to assess the readiness of trade facilitation systems to handle the increasing traceability demands associated with emerging regulatory requirements. While centred on environmental requirements, the findings offer broader insights into the preparedness of trade facilitation systems for a traceability-intensive trading environment.
3.1. Understanding the product environmental lifecycle
Copy link to 3.1. Understanding the product environmental lifecycleEnvironment-related measures can require traders to provide information on a product's composition, origin, production process, use and end-of-life treatment; obtain permits, licences, certificates and conformity documents; and comply with controls involving customs and specialised agencies. From a trade facilitation perspective, the central question is not the environmental ambition of these measures, but how they are implemented at the border: whether requirements are transparent, data and documents can be submitted efficiently, agencies co-operate, and controls are predictable, risk-based and non-duplicative (OECD, forthcoming[1]).
The product lifecycle provides a practical organising lens (Box 3.1). Environmental information may be generated during raw material extraction, input processing, manufacturing, distribution, use, repair, recycling and disposal. A lifecycle approach helps identify what information is needed, where it originates, which authorities must use it, and how it can be transmitted and verified across borders.
Box 3.1. Key segments of a product’s environmental lifecycle
Copy link to Box 3.1. Key segments of a product’s environmental lifecycleThe environmental lifecycle of a product comprises environmental impacts occurring during three main segments: production, use and end-of-life (Figure 3.1).
The production segment encompasses all activities related to sourcing raw materials, production of inputs, and the transformation of these inputs into intermediate or final goods. It involves actors such as suppliers, farmers, manufacturers and processors.
In contrast, the use and end-of-life segments refer to the movement of goods from producers to intermediate and end users – i.e. consumption and disposal or recycling of products (Figure 3.1). In the context of environmental policies, each segment presents distinct challenges and opportunities.
Policies targeting production activities often aim to reduce environmental impacts of a product’s supply chains. Measures targeting use and end-of-life stages generally focus on promoting consumption of more environmentally friendly products, end-use efficiency and responsible waste management (i.e., circularity, recycling and recovery of reusable inputs).
Figure 3.1. The product lifecycle consists of several segments
Copy link to Figure 3.1. The product lifecycle consists of several segments
Note: The “production” segment, as discussed in the text above, encompasses the materials extraction (1), manufacturing (2) and distribution (3) steps in the figure. The “use” segment aligns with step (4) in the figure, while the “end-of-life” segment aligns with step (5) in the figure.
Source: Based on (OECD, forthcoming[1]). Adapted from information made available by: US Environmental Protection Agency (EPA), Sustainable Materials Management Basics | US EPA; European Commission, Life Cycle Assessment & the environment Footprint methods.
3.2. Mapping lifecycle-related border challenges
Copy link to 3.2. Mapping lifecycle-related border challenges3.2.1. Complying with production environmental traceability can be complex for both customs and traders
Trade facilitation can support production-stage environmental objectives by enabling the verification of requirements based on non-product-related process and production methods (NPR-PPMs). As discussed in Section 2.1, NPR-PPMs refer to the conditions or methods under which a product is made, but which do not affect the physical characteristics or functional performance of the product itself. Examples of requirements based on NPR-PPMs include border carbon adjustment mechanisms and deforestation-related regulations: they target emissions or land use impacts embedded in production rather than attributes that customs can observe directly in the product (OECD, forthcoming[1]).
This creates a fundamental border challenge. Physical inspection cannot establish whether a shipment was produced with a given emissions profile or without recent deforestation. Compliance instead rests on upstream data, declarations, certifications and traceability systems, often involving firms, verifiers and regulators far removed from customs.
The resulting documentation can be complex and heterogeneous. Third-party certificates and prior validations may sit in databases outside customs systems, follow different formats and rely on different verification bodies across jurisdictions. Traders must navigate divergent requirements, while border authorities may lack the mandate, guidance, expertise or digital access needed to interpret the evidence consistently.
Risk management must also adapt. Customs selectivity systems have traditionally focused on revenue, safety and security. Incorporating environmental NPR-PPM criteria requires trusted data sources, new risk indicators and mechanisms for feeding compliance results back into risk profiles.
These requirements rarely fall within the remit of customs alone. Environmental authorities, trade ministries, standards bodies and public or private conformity assessment bodies may all participate in verification and enforcement. Without clear mandates, compatible systems and effective information transmission, multiple agency involvement can lead to duplication, gaps and inconsistent decisions.
3.2.2. Classifying and verifying goods in the use segment can be challenging at the border
In the use segment, trade facilitation supports environmental objectives mainly by reducing the cost and uncertainty of trading environmental goods and technologies. Classification ambiguities, documentary requirements and fragmented conformity assessment can all raise trade costs and slow their diffusion (APEC, 2021[2]; WCO, 2023[3]; Moisé and Tresa, 2025[4]; OECD, forthcoming[1]).
A first challenge is identifying environmental goods within the Harmonized System (HS). The OECD and Asia-Pacific Economic Cooperation (APEC) reference lists have mapped environmental goods to HS codes, while successive HS revisions have introduced more specific headings for environmental technologies. The HS 2028 amendments further distinguish categories relevant to plastics, recyclable materials and environmentally sensitive waste streams (WCO, 2026[5]). Initiatives such as the Agreement on Climate Change, Trade and Sustainability (ACCTS) translate these classification efforts into an operational need for shared interpretations and consistent treatment at the border (OECD, forthcoming[1]).
However, the HS is internationally standardised only at the six-digit level, and many environmental goods share codes with conventional products. Two workarounds are common. First, national “ex-outs” can isolate the environmentally relevant subset of a broader code, but differences in eight- or ten-digit classifications can produce inconsistent treatment across markets. Second, end-use certification can grant targeted treatment to dual-use goods, such as filters used in wastewater treatment. Both approaches depend on clear definitions, credible evidence and consistent implementation. They also create risks of misdeclaration, which may prompt additional controls.
Environmental goods are also frequently subject to authorisations, conformity certificates, importer registration, testing and mandatory labels covering characteristics such as energy use or emissions (Moisé and Tresa (2025[4])). When exporter certification is not recognised, border verification can generate extensive documentary requirements. Electronic submission, pre-arrival processing and Single Window integration can reduce these burdens; fragmented or manual procedures increase delays.
Some performance characteristics, including energy efficiency and emissions, cannot be verified through simple physical inspection. Effective risk management therefore depends on access to reliable certification data and common targeting systems, so that controls can focus on higher-risk shipments.
Finally, implementation often involves environmental agencies, energy regulators, standards bodies and consumer protection authorities alongside customs. These agencies may hold the relevant databases or technical expertise. Where documentation, IT systems and responsibilities are not aligned, institutional fragmentation can generate overlapping controls, inconsistent decisions and enforcement gaps (OECD, forthcoming[1]).
3.2.3. The end-of-life segment can create some of the most difficult classification and enforcement problems at the border
Trade facilitation can play an important role in managing cross-border movements of products and materials at the end of their lifecycle. This includes waste, recyclable materials, and products intended for reuse, repair or remanufacturing. Such movements can support circular economy objectives by allowing recoverable materials to reach specialised facilities and economies of scale in areas such as lithium-ion battery recycling, plastics recovery and other reverse value chains (Moïsé and Rubínová, 2023[6]; Moisé and Tresa, 2023[7]; Yamaguchi, 2022[8]). Yet end-of-life flows also create some of the most difficult classification and enforcement problems at the border (OECD, forthcoming[1]).
A central challenge is determining what constitutes waste. The HS largely classifies waste and scrap by physical characteristics, while national rules may also consider intended use, processing method, market value, contamination or degree of recovery. The same material may therefore be treated as a recyclable input in one jurisdiction and controlled waste in another. Differences over when waste ceases to be waste add further legal uncertainty (OECD, 2025[9]).
Box 3.2. Challenges identified as regards the operation of the PIC procedure under the Basel Convention
Copy link to Box 3.2. Challenges identified as regards the operation of the PIC procedure under the Basel ConventionA report by the United Nations Environment Programme on challenges in the implementation of the prior informed consent (PIC) procedure by the Parties to the Basel Convention notes that the PIC procedure is facing a set of persistent challenges that undermine its effectiveness and predictability (UNEP, 2024[10]):
Delays and lack of timely responses: Many Parties report significant delays in receiving acknowledgements or decisions from importing and transit states. In some cases, there is no response at all, leaving exporters uncertain whether shipments can proceed.
Inefficient communication channels: Outdated or incomplete contact information for competent authorities, reliance on paper-based systems, and inconsistent acknowledgement of notifications hinder smooth communication.
Divergent interpretations and definitions: Parties apply different definitions of waste (hazardous and non-hazardous), creating inconsistencies in classification and enforcement. This is particularly problematic for plastics and electronic waste.
Transit-related difficulties: Growing numbers of transit countries require consent, often with unclear or highly demanding documentation requirements. There is also a lack of harmonisation of what constitutes a “state of transit.”
Short permit durations and mismatched timelines: Export permits are sometimes issued with timeframes too short to be practical, while transit consents do not automatically align with the timelines set by importing states.
Capacity constraints: Many relevant authorities, particularly in developing countries, face resource and technical limitations that hinder efficient implementation of the PIC procedure (Box 3.4).
Inconsistent risk and compliance monitoring: Weak monitoring mechanisms limit the ability to track shipments and ensure environmentally sound management at their final destination. This also raises risks of illegal traffic.
Reluctance of carriers: Some shipping lines refuse to transport waste due to uncertainty over regulatory requirements and risks of shipments being blocked in transit.
Overall, these challenges are estimated to result in increased costs, procedural uncertainty, and risks of diversion to informal or illegal trade channels, undermining both trade predictability and environmental protection.
Source: UNEP (2024[10])).
International controls add another layer. The Basel Convention and the OECD Decision on Transboundary Movements of Waste Destined for Recovery Operations (hereafter “OECD Decision”) use notification and prior informed consent (PIC) procedures (Box 3.2), but differ in coverage, membership and flexibility.1 Shipments may require evidence on intended use, destination, material purity, recovery standards and conformity with national or regional rules. The OECD amber control procedure is designed to facilitate recovery movements among OECD Member countries through general notifications, tacit consent and pre-consented facilities, but national variations can still create inconsistent documentation and treatment (Box 3.3) (OECD, forthcoming[1]).
Used goods and secondary materials present a related problem. The Harmonized System does not systematically distinguish new from used products or identify goods by intended use, such as repair or remanufacturing. Items intended for reuse may consequently be classified as waste or scrap, while outwardly similar products may require different treatment depending on condition and destination. National ex-outs and declarations can help, but they are not internationally harmonised and often require supplementary evidence.
Box 3.3. Differences between the Basel Convention and the OECD Decision on Transboundary Waste Movements may affect how waste is processed at the border
Copy link to Box 3.3. Differences between the Basel Convention and the OECD Decision on Transboundary Waste Movements may affect how waste is processed at the borderThe Basel Convention and the OECD Decision both regulate transboundary movements of waste through notification and consent procedures designed to ensure environmentally sound management. While the Basel Convention provides a global framework for hazardous and other controlled wastes, the OECD Decision applies to OECD members and is specifically designed to facilitate waste destined for recovery operations through more streamlined procedures.
Key differences – which may affect how waste shipments are processed at the border – include:
Scope and membership: The Basel Convention has near-universal membership and covers hazardous and other controlled wastes, while the OECD Decision applies only to OECD members and focuses on waste destined for recovery.
Procedural flexibility: The OECD Decision provides shorter consent periods, allows tacit consent, permits general notifications covering multiple shipments, and recognises pre-consented recovery facilities.
Documentary requirements: Both frameworks require core documentation for controlled shipments, including a notification document, movement document, acknowledgement of receipt, consent/refusal decision, and confirmation of recovery or disposal. These documents contain information on the notifier, exporter, importer, waste classification and composition, quantities, transport arrangements, and receiving facility.
Low-risk waste streams: Under the OECD Decision, green-listed wastes generally move under simplified requirements, requiring only commercial documentation (e.g. invoice and transport documents), whereas the Basel Convention does not provide an equivalent simplification.
Overall, the OECD Decision largely mirrors the Basel Convention’s control architecture but seeks to facilitate legitimate recovery trade within the OECD area through more flexible consent procedures and reduced documentation requirements for lower-risk waste streams.
Source: OECD (forthcoming[1]).
Valuation and inspection add further complexity. Second-hand goods may lack clear transaction values or comparable market prices, requiring depreciation formulas, expert assessments or fallback valuation methods. Circular economy certificates, including evidence on recycled content or reparability, may not be standardised or machine-readable, increasing the risk of duplicative assessments and physical inspection backlogs.
Risk profiling is difficult because shipments vary widely and incentives for misdeclaration can be strong. Goods may be declared as scrap, refurbished products or non-functional items to avoid stricter controls or obtain lower tariffs. Effective enforcement therefore requires customs, environmental regulators, standards bodies and health or safety authorities to co-ordinate data, inspections and risk analysis (Box 3.4). Digital technologies can improve tracking and detection, but gaps in data quality, interoperability and access continue to limit their use across agencies and borders (Isarin et al., 2024[11]).
Box 3.4. Role of customs and inter-agency co-operation under the Basel PIC procedure
Copy link to Box 3.4. Role of customs and inter-agency co-operation under the Basel PIC procedureUnder the Basel Convention, the PIC procedure requires exporting countries to notify and obtain consent from importing countries before hazardous wastes or other controlled wastes are shipped. While the consent process is managed by designated competent environmental authorities, customs administrations are responsible for enforcing these requirements at the border. Their role includes verifying that shipments are accompanied by the correct Basel movement documents, checking that the content matches the approved consent, and preventing shipments that lack authorisation or appear fraudulent. Customs therefore serve as the operational gatekeeper that ensures the legal provisions of the convention are respected in practice.
Customs also play a key role in detecting and stopping illegal traffic, which the convention defines as criminal activity. This often involves identifying mis-declared shipments (e.g., hazardous waste presented as recyclable goods), stopping transits to unauthorised facilities, and seizing shipments that bypass the PIC procedure altogether. To do this effectively, customs aim to apply risk-profiling tools, targeting techniques and intelligence-led enforcement.
Because customs authorities do not themselves issue consents under the PIC procedure, close co-operation with national environmental authorities is essential. Environmental agencies should provide customs with information on authorised shipments, the scope of consent granted, and any restrictions that apply. Customs, in turn, should report back on shipments intercepted or suspected of being illegal. This two-way flow of information ensures that enforcement at the border is aligned with regulatory approvals.
In turn, the OECD Decision’s amber control procedure aims at simplifying the Basel PIC procedure for transboundary movements of wastes destined for recovery within OECD Member countries. Customs may work with general notifications covering multiple shipments, while the standardised OECD forms can help authorities apply more consistent checks. The use of pre-approved recovery facilities can also reduce the burden on customs at the border.
At the international level, customs authorities collaborate with bodies such as the World Customs Organization (WCO), INTERPOL, and the Basel Convention’s enforcement networks. Joint operations and information sharing across countries are critical, since illegal waste shipments often involve complex transboundary routes. Such inter-agency co-operation – both domestically and internationally – is therefore the backbone of effective PIC procedures enforcement, ensuring that hazardous waste is managed safely, and that environmental and health risks are minimised.
Source: Basel Convention Guidance Manuals, available at https://www.basel.int/Implementation/Publications/TrainingManuals/tabid/2364/Default.aspx (accessed 1 February 2026).
3.3. Integrating lifecycle requirements into trade facilitation systems through the environment-related TFIs
Copy link to 3.3. Integrating lifecycle requirements into trade facilitation systems through the environment-related TFIsThe env-TFIs build on the economy-wide OECD Trade Facilitation Indicators framework to examine where trade facilitation tools can support the implementation of environment-related requirements in efficient, transparent and non-discriminatory ways. The economy-wide TFIs assess whether core trade facilitation tools exist. The env-TFIs ask whether environment-related requirements are included in those tools. For example, where trade information is published online, the env-TFIs assess whether environmental permits, licences, certificates and procedures are also covered. Where a Single Window or digital customs system exists, they examine whether relevant environmental documents and data are integrated. Where border agency co-operation mechanisms exist, they assess whether environmental and other specialised authorities participate effectively.
The indicators therefore measure operational integration: whether environment-related requirements are visible to traders; whether documents and data can be submitted through streamlined and paperless channels; whether authorities share information and co-ordinate controls; and whether enforcement is predictable and risk-based.2
A higher env-TFI score does not indicate more ambitious or more effective environmental regulation. It means that existing environment-related requirements are more fully embedded in mainstream border systems. A lower score may reflect manual procedures, fragmented institutional arrangements or requirements managed outside core trade platforms for these specific areas. Nor do the env-TFIs identify environmental or circular economy goods for preferential treatment or evaluate the stringency and environmental impact of particular measures (OECD, forthcoming[1]).
The env-TFI framework covers four dimensions:
1. Transparency and predictability. This dimension assesses whether duties, procedures, forms, permits, licences, certificates, classification decisions, enquiry points, appeal mechanisms, fees and charges are accessible and up to date, and whether traders are consulted on regulatory changes. Higher scores indicate that environment-related requirements are easier to find, understand and anticipate.
2. Automation and streamlining. This dimension examines whether copies and electronic documents are accepted, documentation follows relevant standards, requirements are periodically reviewed, and procedures can be completed electronically. It also covers Single Window integration, electronic signatures, risk management, post-clearance audit and Authorised Operator programmes. Higher scores indicate less reliance on fragmented, duplicative or paper-based processes.
3. Domestic and cross-border agency co-operation. This dimension covers aligned data requirements, interoperable systems among government agencies, co-ordinated inspections, shared risk management and co-operation on certified traders, both within countries and across borders. Higher scores indicate that agencies can share information, target controls and reduce duplication.
4. Governance and impartiality. This dimension assesses whether institutional responsibilities are clearly defined and publicly described, and whether public reporting provides information on environment-related border activities. Higher scores indicate clearer accountability and more consistent implementation.
Together the env-TFIs provide a diagnosis of whether environmental information, documents, agencies and controls are connected to mainstream trade facilitation systems. This becomes important as traceability requirements span the full product lifecycle and depend on reliable information flows among firms, regulators and border agencies (OECD, forthcoming[1]).
3.4. Progress and gaps in integrating environment-related requirements into trade facilitation systems
Copy link to 3.4. Progress and gaps in integrating environment-related requirements into trade facilitation systemsThis section presents initial evidence on how environment-related requirements are incorporated into trade facilitation systems across OECD economies and across the product lifecycle. It shows the extent to which these requirements are reflected in border procedures and related trade facilitation tools. The analysis is based on publicly available customs and environmental authority websites, legislation, regulatory portals, Single Window platforms and other border documentation. The results should be interpreted as measures of observable integration of environment-related requirements into trade facilitation systems, not as assessments of environmental policy ambition (OECD, forthcoming[1]).
Five broad patterns emerge from the analysis.
1. Environment-related requirements are only partly integrated. In 2024, OECD trade facilitation systems covered, on average, around 55% of the lifecycle-related border challenges captured by the env-TFIs (Figure 3.2).
2. The digital front end is ahead of the institutional back end. Information is increasingly available online and basic documents can often be submitted electronically. Deeper integration – through Single Windows, joint-agency risk management, co-ordinated inspections and cross-border data sharing – remains much less common.
3. Stronger regulatory frameworks do not translate evenly into operational implementation. Advance rulings, appeal procedures and information availability are more strongly embedded in existing trade facilitation systems, while documentary requirements, agency co-operation, fees and consultations with traders are around one-third less embedded, equivalent to an average gap of roughly 25 percentage points. The relatively weak integration of mechanisms for consultation with the trade community is particularly noteworthy, as adapting border procedures to complex traceability requirements depends in part on regular engagement with the businesses responsible for generating, managing and reporting compliance-related information.
4. Progress has been uneven over time. Formalities and basic automation improved strongly, particularly between 2012 and 2017. Information availability also advanced steadily, while domestic and cross-border co-operation show signs of catching up. Appeal procedures, fees and charges, and engagement with the trade community remain weaker and slower moving.
5. End-of-life flows are where trade facilitation systems are tested most severely. Requirements linked to production, usage, reuse and remanufacturing are roughly twice as visible in trade facilitation systems as those linked to waste treatment. Waste and recyclable-material procedures combine difficult classification, permit and risk management questions with the greatest need for inter-agency and cross-border co-operation.
Figure 3.2. Environment-related border requirements are unevenly integrated into trade facilitation systems
Copy link to Figure 3.2. Environment-related border requirements are unevenly integrated into trade facilitation systemsAverage env-TFI score as share of the corresponding economy-wide TFIs score (%), 2024
Notes: The economy-wide TFIs ask whether core trade facilitation tools exist, while the env-TFIs ask whether environment-related border requirements are included in those tools. A higher env-TFI score implies that environment-related information, documents, agencies and controls are more fully integrated into trade facilitation systems. A lower env-TFI score does not imply weaker environmental regulation. It may mean that environment-related procedures exist, but are handled through separate, fragmented or less visible systems. “Weakly integrated” areas refer to those requirements that on average are handled separately or for which information is hard to find. “Partly integrated” areas refer to those requirements where on average some information or documents are included, but systems remain fragmented. “Well integrated” areas refer to those requirements where on average related information, documents, agencies and controls are integrated into mainstream trade facilitation systems. Based on the compilation of measures for OECD economies drawing on publicly available information.
Source: OECD (forthcoming[1]).
3.4.1. Progress differs sharply across the product lifecycle requirements
All lifecycle segments saw improvement in embedding environment-related requirements in the relevant trade facilitation area between 2012 and 2024, but from different starting points and at different speeds. Production-related measures started from the lowest base and have risen strongly, consistent with growing attention to upstream information and certification. Use-related measures have also improved substantially as countries clarify the classification and treatment of environmental goods and digitalise related procedures (Figure 3.3).
End-of-life segments follow a weaker trajectory. Measures for reuse and remanufacturing improved strongly up to 2017 but then levelled off. Measures for waste, scrap and recyclable materials also rose initially but have shown little subsequent progress. The contrast suggests that reforms advance fastest where information, classification and standard procedures can be added to existing trade systems. Progress slows where implementation depends on resolving waste/non-waste distinctions, aligning permits, linking multiple authorities and exchanging data across borders.
Figure 3.3. Progress across the product lifecycle is slowest for end-of-life segments
Copy link to Figure 3.3. Progress across the product lifecycle is slowest for end-of-life segmentsAverage all OECD economies, 2012‑24
Notes: A score closer to 2 means that environment-related requirements are more fully embedded in the relevant trade facilitation area. Based on publicly available information compiled across OECD members.
Source: OECD (forthcoming[1]).
3.4.2. Production traceability information is expanding, but is still fragmented
The env-TFIs do not capture the detailed design of individual NPR-PPM measures. They instead indicate whether countries possess the cross-cutting capabilities needed to implement them: accessible information, workable documentation, digital processing, risk management and agency co-operation (Figure 3.4).
Basic transparency of trade-related information is relatively widespread, but guidance is often dispersed across unconnected sources. Consultation mechanisms exist yet rarely address production-stage traceability explicitly. Electronic processing is expanding, but relevant documents are still only partly integrated into Single Windows, limiting data reuse and end-to-end traceability.
Customs risk management systems progressively incorporate environmental criteria, but integration is weaker in other agencies and feedback from controls or post-clearance audits is not consistently used to update risk profiles. The largest constraints arise when requirements span multiple authorities. Domestic co-ordination is improving, but single data entry and interoperable systems between agencies remain limited; structured cross-border transmission is rarer still. Institutional fragmentation, rather than the absence of individual digital tools, is therefore the main bottleneck. Public reporting also remains uneven, constraining benchmarking and peer learning (OECD, forthcoming[1]).
Figure 3.4. Trade facilitation for production segment requirements is held back by institutional fragmentation
Copy link to Figure 3.4. Trade facilitation for production segment requirements is held back by institutional fragmentationAverage OECD economies, 2012‑24
Notes: A score closer to 2 means that environment-related requirements are more fully embedded in the relevant trade facilitation area. Based on publicly available information compiled across OECD members.
Source: OECD (forthcoming[1]).
3.4.3. Classification frameworks for the use segment are evolving faster than their implementation
Information on environmental goods is generally available, but often spread across customs, environmental, energy and standards authorities. Traders may therefore need to assemble guidance from several sources to understand classification, conformity assessment and post-clearance obligations. Enquiry channels and consultation mechanisms are common, but specialised expertise and clear service standards remain uneven (Figure 3.5).
Electronic documentation is expanding, yet interoperability between customs and sector-specific systems remains partial. Risk-based controls and post-clearance audits become more important for performance characteristics that cannot be verified at the border, but audit results do not always feed back into common risk management systems. The main remaining challenge is therefore not the absence of information or digital tools, but connecting them across agencies and borders (OECD, forthcoming[1]).
Figure 3.5. The use segment requires better interoperability between customs and sector-specific systems
Copy link to Figure 3.5. The use segment requires better interoperability between customs and sector-specific systemsAverage OECD economies, 2012‑24
Notes: A score closer to 2 means that environment-related requirements are more fully embedded in the relevant trade facilitation area. Based on publicly available information compiled across OECD members.
Source: OECD (forthcoming[1]).
3.4.4. End-of-life circular flows expose the deepest operational gaps
Waste destined for disposal is governed by comparatively formal control regimes, but the information needed to comply is often dispersed across customs, environmental authorities and sector regulators. Digital tools support parts of the process, yet are frequently layered onto paper-based permits and consents rather than used to create end-to-end electronic workflows. Risk-based controls are common, but data alignment, co-ordinated inspections and feedback into shared risk profiles remain uneven. Cross-border harmonisation and information sharing appear among the weakest areas (Figure 3.6).
Waste destined for recovery presents a different trade-off: authorities must maintain environmental controls while facilitating legitimate, often time-sensitive circular supply chains. Requirements vary by material, contamination risk and treatment destination. Clear decision support is therefore crucial for distinguishing recovery from disposal, resolving waste/non-waste determinations and assessing documentary sufficiency consistently.
In this segment, information and formal appeal channels often exist but may not be sufficiently granular or fast for recycling markets. Predictable and proportionate fees and documentation are particularly important because burdensome formal channels can divert materials towards inefficient or informal destinations. Electronic workflows, data reuse and multi-agency risk management have considerable potential, but remain underdeveloped.
For goods intended for reuse or remanufacturing, the principal frictions arise less from PIC-style permits and more from classification, valuation, origin and evidence of condition or intended use. Guidance is often fragmented and not organised around a clear "used good versus waste" decision path. Advance rulings can provide valuable certainty, but evidence on their practical use in this area is limited. Repetitive documentation, testing and opaque fees can undermine circular business models.
Across all end-of-life flows, the policy implication is the same: digitalisation alone is insufficient. Effective facilitation depends on common definitions, connected data, co-ordinated risk management and trusted-operator pathways that distinguish legitimate circular trade from high-risk or illegal shipments (OECD, forthcoming[1]).
Figure 3.6. Trade facilitation efforts are most needed in the end-of-life segment
Copy link to Figure 3.6. Trade facilitation efforts are most needed in the <em>end-of-life</em> segmentAverage OECD economies, 2012‑24
Notes: A score closer to 2 means that environment-related requirements are more fully embedded in the relevant trade facilitation area. Based on publicly available information compiled across OECD members.
Source: OECD (forthcoming[1]).
References
[2] APEC (2021), “A Review of the APEC List of Environmental Goods”, APEC Policy Support Unit Report, https://www.apec.org/publications/2021/10/a-review-of-the-apec-list-of-environmental-goods.
[11] Isarin, N. et al. (2024), Digital Technologies for Better Enforceemnt of Waste Regulation and Elimination of Waste Crime, https://www.oecd.org/content/dam/oecd/en/publications/reports/2024/04/digital-technologies-for-better-enforcement-of-waste-regulation-and-elimination-of-waste-crime_5976ab1a/6739f625-en.pdf.
[6] Moïsé, E. and S. Rubínová (2023), “Trade policies to promote the circular economy: A case study of lithium-ion batteries”, OECD Trade and Environment Working Papers, No. 2023/01, OECD Publishing, Paris, https://doi.org/10.1787/d75a7f46-en.
[4] Moisé, E. and E. Tresa (2025), “Beyond the Tariff: Non-Tariff Measures Affecting Environmental Goods Trade”, OECD Trade Working Paper.
[7] Moisé, E. and E. Tresa (2023), Trade policies to promote the circular economy: A case study of the plastics value chain, https://doi.org/10.1787/e36f2d91-en.
[9] OECD (2025), Guidance Manual for the Control of Transboundary Movements of Recoverable Wastes - 2025 Update, OECD Publishing, Paris, https://doi.org/10.1787/506916e1-en.
[1] OECD (forthcoming), Expansion of the OECD Trade Facilitation Indicators in the area of environment.
[10] UNEP (2024), Draft report on challenges in the implementation of the prior informed consent procedure and best practices, possibleapproaches and initiatives to improve its functioning, as well asoptions for possible ways forward, https://www.basel.int/Portals/4/download.aspx?d=UNEP-CHW-OEWG.14-INF-4.English.pdf.
[5] WCO (2026), HS 2028 Amendments - Adapting the Harmonized System to Global Priorities and Trade Evolution, https://www.wcoomd.org/en/topics/nomenclature/instrument-and-tools/hs-nomenclature-2028-edition/amendments-effective-from-1-january-2028.aspx.
[3] WCO (2023), Report on the HS symposia series on Visualising a greener HS, https://www.wcoomd.org/-/media/wco/public/global/pdf/events/2022/greener-hs/report-on-visualising-a-greener-hs-symposia_en.pdf?la=en&utm.
[8] Yamaguchi, S. (2022), “Securing reverse supply chains for a resource efficient and circular economy”, OECD Trade and Environment Working Papers, No. 2022/02, OECD Publishing, Paris, https://doi.org/10.1787/6ab6bb39-en.
Notes
Copy link to Notes← 1. A recent case is electronic and electrical waste (e-waste). In June 2022, the Basel Convention was amended to require that transboundary movements of e-waste be subject to the prior informed consent (PIC) procedure, thereby introducing stricter controls. Among OECD members, no consensus was reached on the (automatic) incorporation of this amendment into the OECD Decision. As a result, each OECD member now applies controls to the transboundary movements of e-waste, in conformity with its own domestic legislation and international law. Some members continue to apply the current OECD Decision rules for e-waste, while others have adopted the Basel Convention controls.
← 2. As environment-related procedures rely on the wider trade facilitation infrastructure, an env-TFI score cannot exceed the corresponding economy-wide TFI score.