COMBATTING WASTE CRIME

Based on three recent reports from the Interpol and the Waste Force project funded by the EU presenting recent cases of various waste crimes, a modus operandi list has been created. However, as highlighted in the WasteForce Crime Alert#2 report, in most cases only the type of crime was reported without specifying the modus operandi.

Unauthorized waste activities

• Storage of waste without authorisation. In some instances, offenders stockpile the waste in drums and declare bankruptcy before disposal.
• Dumping and disposal of waste without authorisation. Usually, illegal dumping is conducted by small number of persons who are knowledgeable in disposal and who ‘satisfy’ licensing standards. The offences are committed by systematically defrauding the waste generators by guaranteeing a service never actually provided. Indicative examples: dumping in isolated areas, storage in drums that dissolve over time, filling of unfilled landfills, and burning. In some instances, offenders also report that they made use of boreholes leading to abandoned mines, whereas others dumped the waste into convenient sewers or nearby bodies of water and took advantage of the technological inadequacies and carelessness of inspectors.
• Burial of waste without authorisation.
• Waste management without authorisation.
• Mismanagement of waste.
• Commercial activity with waste without authorisation.

Unauthorized waste sites

• Unauthorized waste treatment facility.
• Unauthorized landfill.
• Abandoned site or opened area.
• Roadside.
• Agricultural land.
• Private property.
• Company or commercial site.
• Discharge in water.

Irregular documentation

• Missing documents (i.e. identification documents, travel documents, authorisations) or lack of a permit.
• Incomplete paperwork and administrative errors.
• False declaration of waste types (including misclassification and partial declaration).
• False declaration of waste as non-waste or not declared at all. Indicatively, toxic sludge passed as an agricultural fertilizer.
• Mislabelling and forged documents.

Illegal exports and imports of waste

• Lack of required treatment of waste for import or export. Indicatively, valid license for plastics waste import but the stock at stake is contaminated with chemicals substances which cannot be recycled or reused.
• Online illegal waste trade.
• Breach of import and export bans (i.e. exports of used goods without notification).

Interrelated illegal activities

• Smuggling.
• VAT fraud in exporting wastes.
• Tax fraud and evasion. Indicatively, frauds involving recycling fees and landfill taxes.
• Illegitimately claims of money through government-backed Producer Compliance Schemes for collecting and recycling waste that in reality the company at stake had never handle.