The stakes are enormous on the European side of the transaction. Eurostat data show the EU exported 35.1 million tonnes of waste to non-EU destinations in 2023, worth 18.5 billion euros, with 49 percent flowing to non-OECD countries. Exports of recyclable raw materials reached 39.3 million tonnes that year, including 12.2 million tonnes to Türkiye, 5.2 million tonnes to India, and 1.7 million tonnes to Egypt. Used textiles follow a different map: 46 percent of EU used-textile exports went to Africa in 2019, and countries including Ghana, Kenya, Angola, and Benin received very large volumes of second-hand clothing in 2022. Nigeria’s current share is modest, but the 2025 application would lock in a continuing role as a destination for Europe’s discards.

Technically, the case for the imports is not frivolous. Low-cost secondary textiles can lower input costs for Nigerian industry, and refuse-derived fuel genuinely can cut carbon emissions when it displaces fossil fuel in cement kilns, which operate at temperatures high enough to destroy many organic contaminants. Studies of alternative fuel production suggest cement plants using processed waste can shrink their environmental footprint while recovering energy that would otherwise be lost. For a country where cement is a major industry and energy costs are punishing, the economic logic is real. The study acknowledges these benefits directly rather than dismissing them, which is what makes its warnings about regulatory capacity so pointed.

Those warnings center on infrastructure that does not yet reliably exist. The authors identify weaknesses in port inspection, emissions monitoring, laboratory testing, and engineered disposal as the critical vulnerabilities. If imported waste streams are misclassified, contaminated, or diverted to open dumping, the promised benefits evaporate and the burdens land on communities least equipped to resist. Nigeria already generates roughly 32 million tonnes of waste annually, with Lagos alone producing an estimated 13,000 tonnes per day, much of it ending in open dumps. Research at the Solous landfill in Lagos State has documented elevated respiratory and skin disorders among residents living near the site, and studies of dumpsite fires at Olusosun have evaluated chronic pulmonary and neurological effects on nearby populations. Adding heavy-metal and particulate pollution from expanded imports, the study argues, would compound risks for communities already carrying a disproportionate exposure load.

The public health evidence extends beyond dumpsites. Waste pickers in Lagos, who form a large informal workforce sorting discarded materials by hand, face documented livelihood and health challenges. Groundwater contamination near waste dumps and informal recycling operations has been assessed seasonally and found to pose meaningful risks. Cement plants themselves are not benign neighbors: research on topsoil around a mega cement factory in Nigeria has mapped heavy metal contamination, and community health appraisals near cement plants have recorded social and health impacts. The paradox the study highlights is that a policy marketed as cleaner fuel and cheaper raw materials could, without oversight, deepen the very pollution problems it claims to solve.

To structure the decision, the authors lay out four policy pathways. The first maintains imports but ties them to real-time port and emissions monitoring, an option that preserves industrial benefits while demanding sophisticated, continuous verification. The second permits phased imports subject to verifiable environmental safeguards, allowing capacity to build incrementally. The third imposes a time-bound moratorium while Nigeria develops domestic textile-waste recovery and alternative-fuel capacity, betting that locally sourced feedstocks can substitute for imports. The fourth prohibits the two waste streams entirely, prioritizing health protection over industrial cost savings. Each option involves distinct trade-offs among industrial costs, regulatory capacity, administrative feasibility, and health protection, and the study declines to pretend that any of them is costless.

The timing of the analysis is significant. At the time of the article’s final revision in September 2026, the European Commission had published a draft assessment that did not recommend Nigeria for inclusion in the first list of eligible non-OECD countries, citing deficiencies in evidence on treatment capacity, enforcement, inspections, emissions monitoring, and waste-stream-specific management. That assessment independently echoes the regulatory-capacity concerns the researchers identified, though it remains a draft working document that has not been adopted or endorsed by the Commission. Crucially, the authors note, the EU review does not resolve the deeper questions: how benefits and risks would be distributed within Nigeria, what safeguards would be needed if imports continue, and whether locally recovered materials offer a viable longer-term path.

Those distributional questions are where environmental justice theory does its work. Drawing on frameworks from scholars like Robert Bullard and David Schlosberg, and on political ecology’s attention to power in resource flows, the study frames the waste trade not as a neutral market exchange but as a political arrangement that can shift environmental burdens onto vulnerable populations. The history is sobering: Nigeria’s experience with toxic waste dumping at Koko in the 1980s helped catalyze the Basel Convention, and scholars have since described newer, legal forms of waste colonialism operating through regulatory loopholes and economic asymmetry. Civil society organizations in Nigeria condemned the government’s import plan, warning of environmental crisis and urging focus on domestic waste management instead, and the federal government faced sharp public criticism after the application became known.

What distinguishes this analysis is its insistence that the answer is not simply prohibition or acceptance, but conditionality. The authors argue that any future EU-Nigeria waste trade should be tied to demonstrated regulatory capacity, independent verification, transparent cost-benefit disclosure, and meaningful community participation. That last element matters because communities near landfills, cement plants, and ports have historically been excluded from decisions that determine their exposure, a pattern documented in participatory-process failures from Nigeria to the Dakota Access Pipeline. The Aarhus Convention’s principles of access to information, public participation, and access to justice offer a template, but implementing them requires institutions with funding and authority, and Nigeria’s environmental regulator has faced persistent capacity challenges.

The broader lesson reaches well beyond one application. As the EU tightens its export rules, dozens of countries will face similar choices about whether to become verified destinations for European discards, and the verification itself becomes the battleground where environmental health is won or lost. Nigeria generates enough of its own textile waste and municipal refuse to feed cement kilns and industrial processes without imports, and Lagos has already moved to ban textile waste at its landfills, suggesting domestic feedstocks are available. Whether the country builds the monitoring infrastructure, laboratory capacity, and enforcement machinery to manage any waste stream safely, foreign or domestic, will determine whether the circular economy becomes a shared project or simply a new geography of slow violence, in Rob Nixon’s phrase, in which the costs of consumption are exported to those with the least power to refuse them.

Subject of Research: Environmental justice and public health assessment of Nigeria's application to import non-hazardous EU waste under the EU Waste Shipment Regulation

Article Title: Environmental justice, public health, and resource politics: assessing Nigeria’s application to import EU waste

Article References: Giwa, A., David, F. A., & Ige, K. M. (2026). Environmental justice, public health, and resource politics: assessing Nigeria’s application to import EU waste. Journal of Environmental Studies and Sciences. https://doi.org/10.1007/s13412-026-01149-1

Image Credits: AI Generated

DOI: 10.1007/s13412-026-01149-1

Keywords: environmental justice, waste trade, Nigeria, European Union, refuse-derived fuel, textile waste, public health, waste governance, Basel Convention, cement industry, waste colonialism, regulatory capacity