National Threat Assessment 2008. Organised Crime - Politie

• making several stopovers, whereby various ports are visited to create
confusion in the paper trail and to make it difficult to trace illegal loads
(this is known as ‘port hopping’);
• using legal trade routes to conceal the illegal activities (e.g. transporting
domestic waste labelled as ‘waste paper’ to a country such as India, which
is often the destination for waste paper transports);
• not following the appropriate procedure (notification/permission) or forging
documentation;
• frequently changing the owner of the waste, which creates greater
confusion;
• using detours for transports. Until 2006, for example, Hong Kong was a
frequently used detour en route to China, as waste legislation in Hong Kong
used to be vague. Fishing boats were used at night to transport shipments
from Hong Kong directly to China.
3.5.3 Scale
The overall market for waste and recycling in the Netherlands in 2005 was
estimated at around 10 billion euros. The overall market consists of the waste
collection and processing market (5.1 billion), the recycling market (1.2 billion)
and the group of companies that trade in waste materials (3.9 billion).
According to data from CBS, the total amount of waste in the Nether lands in
2005 was 71,956 kilotons, of which more than 61,000 kilotons were created
in the Netherlands itself. According to CBS, the total amount of waste exported
from the Netherlands was almost 12,500 kilotons. This was not only waste
generated in the Netherlands, but also waste that was first imported into the
Netherlands (i.e. both export and transhipment of waste). It is difficult to
establish to what extent the shipment of waste involves criminal activities.
The chance of violations being detected is small in the waste sector. Indications
of the scale of violations can be derived from inspections. The Inspectorate of
the Ministry of Housing, Spatial Planning and the Environment has established
that violations occur regularly during the transport and processing of waste
materials. Violations include failure to follow the correct procedures, handling
waste materials that do not meet the prescribed criteria or processing waste
other than in the prescribed manner.
During enforcement operations in 2003, a total of 1709 inspections to check
compliance with the EU Regulation on the Shipment of Waste were performed
in the Netherlands. Violations were found in more than 20% of the inspections.
A report published in 2006 about IMPEL-TFS Seaport Project II revealed that
violations occur quite regularly in cross-border waste transports at the European
chapter 3 – Fraud and money laundering
123