Block 20: Competent Authority Consent/Objection

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Block 20 — Quick Reference

Competent Authority Consent/Objection

Records the formal written consent or objection received from each competent authority contacted in Blocks 8, 9, and 10.

Basel Article

Article 6(2) & 6(4)

Rejection Risk

Critical — No consent = no movement

Response Window

60–90 days typical

What Block 20 Captures

Block 20 is completed after — not before — the CAs identified in Blocks 8, 9, and 10 have responded to the notification. It records the consent reference number, date of consent, and any conditions attached to the consent from each authority. If an authority objects, the objection basis is recorded here. The waste movement cannot legally begin until Block 20 contains written consent from all required CAs. Moving waste before consent is received constitutes illegal traffic under Article 9.

How to Complete Block 20

1

Leave blank at initial submission.

Block 20 cannot be completed when the notification is first submitted — no consent exists yet. Submit with Block 20 blank and update via amendment once each CA responds.

2

Record each consent as received.

For each CA that responds: enter the authority name, consent reference number, consent date, and validity period. If conditions are attached, summarise them and note the condition reference.

3

Track tacit consent deadlines.

Under Article 6(4), if a CA does not respond within 60 days of notification acknowledgement, tacit consent may apply — depending on the CA's national legislation. Not all countries accept tacit consent. Confirm with each CA whether silence constitutes consent before acting on it.

4

If objection received — do not proceed.

Record the objection basis in Block 20. An objection may be withdrawn if the notifier addresses the CA's stated concern and resubmits. Moving waste against an active objection is illegal traffic.

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No Movement Without Consent

A shipment dispatched before written consent is received from all required CAs is illegal traffic under Article 9 of the Basel Convention. The exporter, carrier, and importer are all potentially liable. Block 20 must be fully completed — and all consents valid — before the first shipment departs.

Common Errors → Correct Approach

❌ Wrong

Treating 60 days of CA silence as automatic tacit consent without verifying the CA's national legislation

✅ Correct

Confirm with each CA whether tacit consent applies under their domestic law before proceeding. Many countries require explicit written consent regardless of the 60-day window.

❌ Wrong

Proceeding with shipment when one CA has consented but another has not yet responded

✅ Correct

All required CAs must have responded before movement begins. Partial consent is not sufficient — every authority in Blocks 8, 9, and 10 must be accounted for in Block 20.

Frequently Asked Questions

How long is a CA consent valid?

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Consent validity periods vary by CA. Most issue consent for the duration of the notification validity period declared in Block 11, up to 12 months for general notifications. Some CAs issue consent tied to specific shipment dates. Always check the consent document itself for the stated validity period and do not ship after it expires.

Can a CA withdraw consent after it has been granted?

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Yes. A CA can withdraw consent if circumstances change materially — for example, if the receiving facility loses its operating permit, if new information emerges about the waste, or if the notifier fails to comply with conditions attached to the original consent. Withdrawn consent must be recorded in Block 20 and the movement halted immediately.

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DexMetal Expert Tip

Keep a consent tracking log — a simple spreadsheet listing each CA, date notified, date responded, consent reference, and expiry date. With multiple CAs across multiple shipments, a tracking system prevents the most dangerous error: shipping on expired or incomplete consent.

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Block 19: Reason for Export

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Block 21: Specific Conditions or Objection Reasons

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