In early July, 102 containers loaded, according to customs documents, with iron oxide, sailed from Albania's port of Durres for Thailand.
But according to information provided to the Basel Action Network (BAN) by a whistle-blower, they were also carrying electric furnace dust (EAFD).
The latter is a hazardous byproduct of steel-making that must be stored and transported under very strict conditions.
Refused by Thailand, the waste is now on its way back to Albania, after several months at sea and stopovers in Spain, Portugal, Italy and Turkey. Prosecutors in Durres have opened an investigation.
"The 102 containers of suspected hazardous waste are due to arrive in Durres on October 27 aboard the Turkish-flagged container ship Burak Bayraktar," NGO director Jim Puckett wrote in a letter to the Albanian tourism and environment ministry, a copy of which was obtained by AFP.
He demanded that the "content of the containers be tested quickly and transparently" and added that representatives of the NGO might be present in Durres when the waste arrives.
Puckett also requested permission for the NGO to join the Albanian team to take a sample to be sent to an independent laboratory.
"We fear that the failure to implement a well-executed plan for the receipt and sampling of suspected waste will lead to the proliferation of conspiracy theories and a lack of transparency", the letter said.
The Albanian government has remained silent over the issue for weeks.
Contacted by AFP, the environment ministry did not reply by Tuesday afternoon.
Enormous amounts of waste are regularly sent to developing countries -- part of a global industry that sees Western nations outsourcing its treatment to Asia and Africa.
The practice has long been denounced by environmental organisations.
Despite the criticism, the waste management trade continues to be a multibillion-dollar enterprise.
The handling of illicit material generates between nine billion and 11 billion euros each year, according to the Financial Action Task Force, a leading watchdog tracking illegal trade.
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