Working Group 2 - Waste & Illegal Pesticides

From its establishment in 2015, the working group has exchanged experiences and best practices in combating violations of the EU Waste Shipment Regulation.

For 2024, it will expand its activities to the problem of the sale and use of illegal pesticides.

The group comprises eight specialist environmental prosecutors representing eight different European nations and meets on a quarterly basis to discuss and agree training needs, and the outputs needed to meet them including the organisation and delivery of events and guidance.

ENPE Waste & illegal Pesticides Working Group Workshop - Illegal Waste Transfer & Activity in Central Europe; Tallinn, Estonia, 07-08 December 2023

This workshop focussed on prosecuting illegal waste activities in Europe and was held  in Tallinn, Estonia on the 07-08 December 2023. In total, 23 delegates attended representing government prosecuting organisations from 12 different countries. Presentations and case studies were shared with group activities and discussions resulting in the reporting of common challenges experienced by the participants in the regulation and enforcement of illegal waste activity. In particular, waste classification, lack of control of movement, interpretation of waste legislation and lenient sanctions were all presented as the most significant barriers to effective regulation.

International co-operation and collaboration, through Joint investigation Teams (JITS) and Mutual Legal Assistance (MLA) had proved to have a positive impact on cases with examples included in the presentations. Going forward, continued sharing of experience, including advice on interpretation of changing legislation is recommended through networks such as ENPE and further targeted training as required. Furthermore, international collaboration involving the countries participating in the workshop is envisaged to be eased following the sharing of common barriers and successes in the regulation of waste activities.

[The Workshop report, including a short summary of each presentation, will soon be available for download below.]


Forward Look: Illegal Pesticides - proposed ENPE workshop 2024

The use of Illegal pesticides in Europe is a growing problem and one that involves many areas of environmental crime. The Europol coordinated Operation Silver Axe V , led in 2020  to the seizure of 1 346 tonnes of illegal pesticides. This quantity could be enough to spray 207 000 km2, or more than all the farmland in Germany (which accounts for nearly half the country), almost 75% of farmland in France or more than 150% of the farmland of Romania. Illegal profits are huge. (

These figures leave no doubt that criminal law has a role to play in this. A recent questionnaire completed within the ENPE network confirmed the urgency of the matter. Several dozen prosecutors and other colleagues expressed their interest in going more deeply into the subject, for example, to study case law, exchange of practices etc.

Therefore, to address this urgent issue, ENPE intends to organise a workshop on this topic in 2024. 


LIFE-ENPE project - Waste Working Group (WG2)

Historically, and as part of the LIFE-ENPE project (2015-2020) this working group was focussed on tackling waste crime only, exploring the major causes of non-compliance with the Waste Shipment Regulation (1013/2006) and the issues these create for efficient and effective prosecution and adjudication. This includes the practical effects of the amendment to the Waste Shipment Regulation (implemented in May 2014) as seen by prosecutors and judges. The group was first convened at the outset of the LIFE-ENPE project operating from 2016-20 as the 'Waste Working Group (WG2)' and its outputs, in 2020, comprised:

  • a written report on the barriers and solutions to effectively tackling offences under the Waste Shipment Regulation, in particular the issues prosecutors and judges encounter in practice in interpretation and practical application of that Regulation
  • presentations on the working group’s interim and final findings as delivered by the group at the ENPE annual conferences
  • training materials addressing the matters set out above, and including:
    • training presentations
    • case studies
    • guidance on minimum standards and best practice
    • a database of European waste crime cases


This Working Group comprised 8 specialist prosecutors from 7 different countries and met around 3 times per year, including at the annual conference:

LIFE-ENPE Waste Working Group (WG2) activities & outputs

Final Report - August 2020

The Final Report for LIFE-ENPE Working Group 2 (Waste crime) was published as part of the LIFE-ENPE project outputs and is available as a pdf below. The report includes details of all of the groups activities since December 2017 as well as details of all outreach activities including awareness raising and training materials. 

Waste Shipment Regulation webinar

In addition, Kristina Persson, in conjunction with Rob de Rijck and Lars Magnusson, all of whom are practising government environmental prosecutors, completed a webinar which provides guidance on interpretation of the WSR and follows on from the WSR training animation which was first delivered at the WG2 workshop in Nicosia in March 2019 and subsequently shown at the ENPE annual conference in The Hague. Please see below to access the webinar.

Waste Shipment Regulation training animation

Developed, scripted and produced by Rob de Rijck and colleagues, this short training animation is an excellent overview and summary of the WSR. It has been shared widely and received much praise and is available below.

Waste Working Group contribution to the Public Consultation on the Evaluation of the Waste Shipment Regulation

The Working Group, under the direction of its Chair Mr Rob de Rijck, and with full contribution from all of its members, provided a collated ENPE contribution to the recent EU Public Consultation on the Evaluation of the Waste Shipment Regulations. The multi-national composition of the group, together with its unique specialism, facilitated a comprehensive and truly pan-European response which we look forward to hearing more about in due course. The contribution is available as a pdf below. 


For more details on this Working Group, including activities from 2017, the presentation delivered at the ENPE annual conferences and the WSR consultation, please see the reports below which are availablel to download.



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ENPE Waste & Illegal Pesticides Working Group workshop, Tallinn