Understanding the Risks of Plastic Waste Trade in Financial Crime

Publication date 20-05-2025

J5 Sector Insight: UK-NL Trade in Plastic Waste

Plastic waste is big business—and big risk. The Netherlands and the United Kingdom are key players in the global trade of plastic scrap, a complex market shaped by shifting regulations, producer responsibility schemes, and varying environmental standards. But behind the recycling narrative lies a vulnerable sector susceptible to trade-based money laundering (TBML), fraud, and environmental crime.

In a joint project, the Dutch Fiscal Intelligence and Investigation Service (FIOD), Dutch Customs, and HMRC examined trade flows and financial irregularities in this sector. The findings reveal how legal grey zones, misdescriptions, phantom shipping, and fragmented oversight create opportunities for criminal abuse. Between 2010 and 2024, Dutch authorities traced €145 million in suspicious transactions linked to plastic waste companies—highlighting the sector’s appeal to illicit actors.

From contaminated containers falsely labelled as clean recyclables, to cash payments from high-risk jurisdictions, the risks are real. This knowledge report provides insight into the economic chain, the regulatory landscape, and the tactics used to disguise criminal proceeds within the plastic waste trade.

By understanding these risks, investigators, supervisors and financial institutions can better detect illicit flows and prevent environmental and financial harm.

👉 Download the full sector report (PDF)

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