In 2015, during my doctoral research entitled — ‘The Basel Convention and the Transboundary Movements of Hazardous Waste to the Developing World: A Study of Regulatory Violations and the Problem of Legal Compliance’ — I examined how regulatory loopholes and weak enforcement under the Basel Convention enabled the illegal flow of hazardous waste, often disguised to appear as recyclables.
The Basel Convention is a global treaty that controls hazardous waste exports and requires consent from receiving countries, aiming to protect those with limited disposal capacity.
A decade later, on 1 January 2025, long-awaited amendments to the Convention came into force, directly addressing some of those gaps. This article reflects on those earlier findings, incorporates recent enforcement cases, and re-examines how criminal networks continue to thrive in the global waste trade.
Green criminology and the criminal web
This is a branch of criminology that examines environmental harm through the lens of law, justice, and power – highlighting how ecological damage, like illegal waste dumping, often results from systemic inequality and regulatory failure. One example is the global recycling industry, which, though widely promoted as environmentally responsible, has in many cases become a cover for the transboundary trafficking of toxic materials. Rather than being safely processed locally, to the extent possible —as the Basel Convention originally intended— many shipments labeled as ‘recyclables’ are diverted, dumped, or burned in countries with limited oversight and inadequate waste infrastructure.
From a criminological perspective, this is more than an oversight — it is a systematic failure rooted in profit and evasion. The harm caused from poisoned ecosystems to serious health impacts, is often obscured by layers of paperwork and international complexity. The majority of illegally exported or misclassified waste ends up in regions least equipped to manage it safely – particularly Sub-Saharan Africa, Southeast Asia, and Latin America. These patterns reflect structural inequalities.
The human cost of a hidden crime
In February 2025, Croatian authorities dismantled a network responsible for burying 35,000 tons of mislabeled hazardous waste. Shipped from Italy, Slovenia, and Germany, and declared as recyclable plastic, the waste was instead buried in illegal landfills, poisoning ecosystems and generating €4 million in illicit profits. The group underbid legal providers in Italy, then falsified documents and transported untreated waste to Croatia. Thirteen people were arrested, with several facing charges related to environmental crimes, fraud and illegal waste management. This reflects a broader pattern: corrupt intermediaries, and outdated systems continue to enable hazardous materials to cross borders under a green disguise.
Behind the waste: people and consequences
These crimes don’t occur in back alleys — they involve licensed firms, brokers, and sometimes complicit officials. Waste is misclassified, documents falsified, and routes redirected to avoid detection. The global waste trade’s structure — built on complex logistics, uneven regulation — has fostered exploitation. Some actors operate in legal gray zones using loopholes to shield harmful practices.
The consequences are not abstract — they are deeply human. In West Africa, Southeast Asia, and Latin America, people live amid toxic smoke, leaking chemicals, and polluted water. In 13 Latin American countries alone, e-waste generation rose by nearly 50% between 2010-2019, while in Asia, over 24.9 million tons of e-waste were produced in a single year. Unsustainable practices like biomass burning have also driven dangerous air pollution across Southeast Asia: in northern Thailand, PM2.5 levels regularly exceed safe thresholds, with serious health implications.
This is more than a regulatory failure — it is a matter of justice. Communities that contribute the least to global waste often suffer its most devastating effects. This dynamic — where hazardous waste from wealthier countries is systematically exported to less developed regions — is often referred to as toxic colonialism. It reflects a global pattern in which environmental burdens are imposed on countries with fewer protections, weaker enforcement mechanisms, and limited power to resist exploitation.
But these communities are not silent. In Ghana, the Basel Action Network has worked with local partners to expose illegal e-waste dumping and push for stronger enforcement. In Chile, grassroots movements turned textile waste into protest art at the Atacama Fashion
Week, calling out the dumping of foreign clothing in the desert. Thailand and Malaysia have returned waste shipments to the Global North, and as of 2025, Thailand implemented a full ban on plastic waste imports – a clear rejection of becoming a global dumping ground. These actions reflect growing resistance to environmental justice and a call to end the legacy of toxic colonialism.
Amendments of the Basel Convention
The 2025 Basel amendments represent a step forward. All electronic waste exports now require prior informed consent which is a regulatory requirement under the Basel Convention that mandates exporting countries to notify and obtain approval from receiving countries before any transboundary shipment of hazardous waste takes place. Definitions under Annexes I, II, and VIII have been clarified, closing loopholes previously exploited. These changes addressed weaknesses I highlighted in 2015 — especially vague classifications and reliance on self-reporting.
Yet reform alone isn’t enough. In early 2025, 102 containers of toxic steel dust were rerouted across multiple borders and stranded in Albania. In North America, hazardous waste exports to Mexico and Canada have surged, with marginalized communities bearing the brunt. Enforcement remains fragmented, and transnational crime continues to outpace regulation. While the Basel Convention Secretariat reviews national reporting and monitors compliance processes, actual enforcement depends on how seriously each country implements the treaty at the national level.
Toward an equitable global waste regime
To effectively combat environmental crime, we must go beyond legal texts and embrace coordinated enforcement. Transnational investigations, real-time shipment tracking, and stronger custom mandates — including anti-corruption safeguards — led by national agencies and supported by international cooperation, are essential. This is organized cross-border crime, with real consequences for health, safety, and equity.
Harmonized definitions and classification systems are also needed to close legal loopholes. Waste receiving countries — often under-resourced — must be supported through funding, capacity-building, and legal tools, provided by mechanisms such as the Basel Convention Secretariat, UN Environment Programme, and international donors. These were among my key recommendations in 2015. Without thorough and consistent implementation, even the strongest treaties fall short.
If we fail to name and dismantle the criminal structures hiding behind the promise of recycling, we risk letting green-disguised environmental crime flourish.