Block 11: Disposal/Recovery Operation
Block 11: Disposal/Recovery Operation
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Block 11 – Quick Reference
Disposal/Recovery Operation
Declares the approved R or D operation code, the technology employed, and the reason for export.
Basel Basis
Annex IV-A/B, Basel Convention
Field Type
Operation code (R/D), technology, reason
Required For
All Basel movements
What Block 11 Captures
Block 11 declares what will actually happen to the waste at the receiving facility. It contains three sub-fields: the R or D operation code, the technology employed, and the reason for export. Competent authorities use Block 11 together with Block 10 (facility identity) to verify that the declared operation matches the facility's permit scope and that the technology described is environmentally sound.
If Block 10 tells authoritieswherethe waste is going, Block 11 tells themwhat happens to it. A mismatch between these two blocks is one of the most common causes of notification rejection.
R-Codes: Recovery Operations
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ULAB Note
Lead-acid battery recycling for lead recovery usesR4(metals and metal compounds). Confirm against the receiving facility's authorization before declaring.
D-Codes: Disposal Operations
How to Complete Block 11
1
Confirm the operation type.
Determine whether the movement is for disposal or recovery. This must match Block 3 (B(i) or B(ii)).
2
Select the operation code.
Choose the single most accurate R or D code. Do not list multiple codes unless the waste genuinely undergoes multiple operations.
3
Describe the technology.
Specify the actual process used at the facility. "Recycling" alone is not sufficient. Examples:
pyrometallurgical smelting for lead recovery
,
hydrometallurgical leaching and electrowinning
.
4
State the reason for export.
Required by the Basel Convention. Examples:
No certified lead smelting capacity exists in the country of export
,
No domestic facility holds authorization for this waste type
.
5
Verify against facility permit.
Cross-reference with Block 10 to confirm the declared operation is within the facility's authorized scope.
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R12/R13 and D13–D15 Interim Operations
If the declared operation is an interim code (R12, R13, D13, D14, or D15), you must attach an annex identifying all subsequent facilities and the final R1–R11 or D1–D12 operation where processing is completed.
Common Errors – Correct Approach
Wrong
Technology field left blank or states only "recycling"
Correct
Specify the actual process — e.g., pyrometallurgical smelting, hydrometallurgical processing
Wrong
Reason for export left blank
Correct
Required by Basel Convention — state the specific reason domestic treatment is not used
Wrong
R and D codes used interchangeably
Correct
Recovery (R) and disposal (D) are legally distinct categories — use the correct one
Wrong
R13 declared as final operation
Correct
R13 is interim only — attach annex naming the subsequent R1–R11 facility
Wrong
Code does not match facility permit scope in Block 10
Correct
Verify the facility is authorized for the exact declared operation before submitting
Frequently Asked Questions
Can I change the operation code after consent is granted?
▼
No. Any change to the declared operation requires a formal variation through the competent authority before the shipment departs. Changing codes on the movement document without authority approval is a compliance breach.
What if my waste goes through an interim operation before final recovery?
▼
Declare the interim operation (e.g., R13 for accumulation) in Block 11 and attach an annex identifying the subsequent facility where the final operation (e.g., R4) takes place.
Is the reason for export required for all movements?
▼
Required by the Basel Convention. The OECD Decision does not require it, but most competent authorities — including in OECD countries — expect it. Always include it.
What is the difference between Block 10 and Block 11?
▼
Block 10 identifies the facility — who and where. Block 11 declares the operation — what happens to the waste. Both must be consistent with each other and with the approved consent.
Supporting Documents
- vCOP8 Official Form and Completion Instructions — Block 11— Official Basel source for R/D code definitions and completion rules.
- Basel Convention Annexes IV-A and IV-B— Complete disposal and recovery operation code lists.
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DexMetal Expert Tip
Block 11 is consistently cited as a top cause of notification rejection. Vague technology descriptions and missing reason-for-export text are the two most frequent triggers. Write both as complete sentences before submitting.
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Block 10: Disposal/Recovery Facility
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Block 12: Waste Designation
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