Before you arrange transport - 5 things you need to know about your waste
Waste transport is not just a matter of logistics. It is a process that requires knowledge, precision and compliance with regulations. The wrong waste classification, the wrong carrier or the wrong entry in the documents can cost you more than the transport itself. Check these five things before you outsource your transport.
Identification of waste - the first and most important step
The first step is to identify the waste correctly. This is a deceptively simple activity, but in practice leads to many mistakes. The main dividing line is between hazardous and non-hazardous waste. The former contains substances that may pose a risk to human health or the environment - such as heavy metals, chemicals or asbestos. The latter - although less harmful - also require proper recording and management.
Within both categories there are additional classifications by:
- source of generation (e.g. municipal, industrial, medical waste),
- physico-chemical properties (toxic, explosive, flammable, corrosive, etc.).
- the industry that produces them (e.g. construction, medical, food, automotive)
- disposal method (recyclable, recoverable, landfill)
Why is this important?
Incorrect identification can lead to the wrong waste code being identified. This, in turn, results in incorrect documentation, errors in reporting to systems such as BDO or SENT, and the selection of the wrong carrier. This multi-faceted classification unfortunately increases the risk of mistakes, which is why
If in doubt, it is advisable to seek the assistance of an adviser who will indicate the correct code.
Waste code - six digits that matter
The waste code is a key piece of the whole puzzle. It consists of 6 digits:
- The first 2 digits are the waste group (e.g. 20 - municipal waste),
- 2 another is a subgroup (e.g. 01 - household waste),
- The last 2 are a specific waste fraction (e.g. 01 - paper and cardboard).
Structure of the waste code
(e.g. 20 - municipal waste)
(e.g. 01 - household waste)
(e.g. 01 - paper and cardboard)
Legal basis - what provisions apply?
Depending on the type of waste and its code, different legislation applies:
- Waste Act (OJEU 2023, item 1587) - sets out the rules for waste management, record-keeping, responsibility for waste and sanctions for irregularities.
- The Road Transport Act (OJEU 2023, item 959) - contains requirements for hauliers, including the need to have a BDO registration and relevant permits.
- Waste Catalogue Regulation (OJ 2020, item 10) - defines waste codes, classification and designations.
- Act on the monitoring system for road and rail transport of goods and trade in heating fuels (Journal of Laws 2023, item 951) - regulates notification obligations in the SENT system, including for selected waste codes and groups.
- ADR Convention - concerns the international carriage of dangerous goods by road, including waste designated as hazardous.
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Consequences of errors - liability and penalties
It is in the interest of everyone involved in the transport of waste to have all the necessary authorisations and means to provide services in accordance with the law. However, what happens if either party fails to comply with the formalities or their failure to comply with their obligations puts the environment at risk?
For example, in the case of transboundary shipments of waste, the legislation, specifically Law on International Shipments of Waste of 29 June 2007, indicate the following amounts that should be paid depending on the offence:
| PARTICIPANT IN A WASTE SHIPMENT OPERATION | REASON FOR PENALTY | AMOUNT OF THE PENALTY |
|---|---|---|
| SENDER/ NOTIFYING | - illegal shipment | from PLN 10,000 to PLN 1 million |
| - shipping more waste than declared - sending more transports than indicated in the notification | from PLN 5 000 to PLN 200 000 | |
| TRANSPORT | - transport by a route other than that specified in the documentation - transport despite the lack of inclusion in the documentation as a carrier of this particular waste - transport carried out on the basis of incomplete or unsigned documentation | from PLN 5,000 to PLN 100,000 |
| RECEIVER | -collection of waste shipped illegally | from PLN 10,000 to PLN 1 million |
| -acceptance of more waste than was documented - failure of the recovery facility to acknowledge receipt of the waste within the deadline of 3 days - failure to carry out the obligation to recover or dispose of waste | from PLN 5 000 to PLN 200 000 |
Carrier entitlements - who can carry out the transport?
As we mentioned earlier, any transport company wishing to haul waste in Poland must be duly authorised. He will obtain them by making an entry in the BDO Register in section VII. There, he must have entered the specific waste codes corresponding to those he is to transport for the customer. Failure to have the correct code on file is a straightforward route to receiving a fine during an inspection and having to return the load to the shipper or stopping the transport until the matter is clarified. In the latter case, the consequences can be long-term. After all, time is money and a driver who does not perform the transport does not earn money.
Tip
Do you know your waste code? Check that the haulier you want to hire is listed in the BDO Register and that his permit includes this code. Alternatively, you can contract a haulier who already has the waste codes you are interested in. Also make sure that the recycler to whom your waste is to go has the authorisations and technological capacity to properly manage the waste you have generated.
Waste documentation - what do you need to include?
The transport documentation (KPO, CMR, Annex VII) must include:
- the full name of the waste,
- waste code,
- source of waste,
- the state of aggregation (e.g. liquid, solid),
- type of packaging (e.g. bulk, barrel),
- net and gross weight.
You don't want to expose yourself to the costs mentioned in this article, do you? Remember, in waste management even the smallest mistake can result in serious consequences.
Confused about how to manage your waste? Need help with your waste transport? Write to us: dispo@ekologistyka24.pl - Our specialists will help you go through the whole process safely and in accordance with the regulations.
