ABSTRACT
In Case C-203/96 Chemische AF v Alstoffen Düsseldorf BV v Minister Van Volkshuisvesting, it was held that the principles of self-sufficiency and proximity set out in Art 5 did not apply to shipments of waste for recovery rather than disposal and Regulation 259/93 does not apply the principles to shipments of waste for recovery. Article 176 (was 130t) which permits Member States to maintain or introduce more stringent rules than those adopted by the Community cannot be used to extend the principles to waste for recovery. See Agustin, Garcia Uretin, Case Commentary [1998] 5 Env Liability 157.
