End-of-Waste (EoW): What Will Change in 2027?
A new procedure for applying for end-of-waste (EoW) classification will become available in Finland in 2027.
At the beginning of 2027, amendments to the Finnish Waste Act will introduce a new procedure allowing the classification of a substance or object as a by-product or the determination of its end-of-waste status through a decision separate from the environmental permitting process.
Turning waste or industrial side streams into marketable products can create new business opportunities for companies and reduce the consumption of virgin raw materials.
What Does End-of-Waste (EoW) Mean?
End-of-waste (EoW) refers to a procedure through which a substance or object previously classified as waste can cease to be waste under certain conditions. For a material recovered from waste to be classified as a product, it must meet the end-of-waste criteria set out in the Finnish Waste Act (646/2011).
The material must have a specific intended use and an established market or demand. It must also meet the technical requirements for its intended use, comply with applicable product and chemical legislation, and be safe for human health and the environment.
Until now, case-specific determinations of by-product or EoW status in Finland have primarily been made as part of environmental permitting procedures. This process has sometimes been burdensome for companies whose primary need is to clarify the legal classification of a particular material.
What Will Change in End-of-Waste Classification and the Finnish Waste Act?
The end-of-waste classification process will become more straightforward on 1 January 2027, when amendments to the Finnish Waste Act (311/2026) introduce a new application-based procedure for obtaining a classification decision. The new procedure allows authorities to determine whether a substance or object qualifies as a by-product or whether its classification as waste can be terminated.
Classification decisions will be issued by the Finnish Supervisory Agency (LVV). Classification matters may also continue to be resolved as part of an environmental permit or a notification decision under the Environmental Protection Act, provided they relate to the activity being assessed.
The amendment aims to facilitate the commercialisation of recovered materials and accelerate the implementation of circular economy solutions.
How Can Companies Apply for EoW or By-Product Status in 2027?
From the beginning of 2027, case-specific classification decisions can be obtained by submitting an application to the Finnish Supervisory Agency (LVV) when no applicable EU-level or national assessment criteria exist for the substance or object and the classification is not being resolved through an environmental permit procedure.
The new procedure is separate from environmental permitting, but obtaining by-product or EoW status still requires sufficient evidence. Applicants must reliably demonstrate compliance with the requirements laid down in Sections 5a to 5e of the Finnish Waste Act.
The application must demonstrate how the EoW criteria are met and include information on:
- The waste material and its properties
- The recovery process
- The intended use of the material
- Existing markets or demand
- Health and environmental risks
- Quality assurance
- Compliance with chemical and product legislation
The Finnish Ministry of the Environment is currently preparing a decree that will further specify the information required in classification applications. The decree aims to improve application quality and streamline the administrative process.
In addition, the Finnish Environment Institute and the Ministry of the Environment are preparing the RASTERI guidelines to support risk assessments and regulatory decision-making in case-specific EoW determinations.
How Should Companies Prepare for an EoW Application?
An application for the classification of a substance or object requires sufficient technical and environmental evidence to support the requested status.
Before preparing an application, companies should assess:
- Whether the material has a clearly defined intended use and an established market
- How well the material’s quality and variability are understood
- What analyses and risk assessments are required
- How continuous quality assurance will be organised
- Which product and chemical regulations apply to the material
A well-prepared application facilitates the review process and reduces the need for additional information or supplementary assessments. The supporting documentation must demonstrate how the material meets the applicable end-of-waste criteria.
What Obligations Apply After Obtaining By-Product or EoW Status?
A favourable by-product or EoW classification decision removes the material from the scope of waste legislation, subject to the conditions specified in the decision. The material is then classified as a product or raw material and may become subject to requirements such as:
- Chemical regulatory requirements under REACH and CLP
- Legislation governing fertilising products
- Construction product requirements
- Product safety obligations
- Standards and quality requirements specific to the intended use
- Product information and sustainability documentation required by customers
How Can Ecobio Support EoW Applications and By-Product Classification?
Ecobio supports companies throughout the by-product and end-of-waste classification process. Our services can be provided as a comprehensive solution or as support for individual stages of the process.
We conduct preliminary assessments to determine whether a material may qualify for by-product or EoW status and evaluate the available procedural options.
We assist in preparing applications and the required documentation, as well as identifying applicable obligations under product and chemical legislation. We also support companies in ensuring product compliance and establishing effective quality management practices.