Waste classification: how to determine whether a waste is hazardous or not?

Classifying waste as hazardous or non-hazardous depends on a 5-step methodology, including identification, composition, hazardous properties (HP) and the presence of persistent organic pollutants (POPs).

Marie Faucon
EHS Consultant
Update : 
12.09.2025
Publication: 
12.12.2019
Contents
Example H2
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Identifying hazardous waste is an important step in waste classification. Different rules apply depending on whether the waste is hazardous or not.

A European communication [1] details a methodology for assessing the nature of a waste and classifying it as hazardous or non-hazardous. This method prevents hazardous waste from being incorrectly classified as non-hazardous when stored with other waste. We'd like to introduce you to this method.

Classification of hazardous and non-hazardous waste: 5-step methodology

Step 1: Check the applicability of the Waste Framework Directive

This step involves checking that the object in question :

  • meets the definition of "waste" as defined by the Waste Framework Directive [2] "waste: any substance or object which the holder discards or intends or is required to discard".
  • and that it is not excluded from the scope of the directive (e.g. gaseous effluents emitted into the atmosphere, waste water, etc.).

Step 2: Identify the corresponding item on the waste list

At this stage, the waste must be characterized by an item on the waste list.

Note: the list of wastes can be found in Decision 2000/532/EC of May 3, 2000 [3]. Annex 1 of the communication also reproduces it and contains a method for determining the corresponding waste heading.

There are three possible options:

  • the waste is classified as "Hazardous in absolute terms" (marked with an asterisk) => the assessment stops at this stage;
  • the waste is classified as "Non-hazardous in absolute terms" => the assessment stops at this stage;
  • the waste falls under at least two headings, one of which corresponds to a hazardous waste and the other to a non-hazardous waste: this is a "mirror entry" => further assessment is required to classify the waste as either a "hazardous mirror entry" or a "non-hazardous mirror entry".

Step 3: Gather information on waste composition

This step involves gathering information on the composition of the waste to determine whether it may present one or more hazardous properties of type HP 1 to HP 15. For example, this information may be information relating to the manufacturing process or information supplied by the supplier, such as safety data sheets (SDS).

Step 4: Determining whether the waste has a hazardous property HP1 to HP15

The properties that make waste hazardous are defined in Annex III of the Waste Framework Directive: explosive (HP 1), oxidizing (HP 2), flammable (HP 3), irritant - skin irritation and eye damage (HP 4), specific target organ toxicity (STOT)/aspiration toxicity (HP 5), acute toxicity (HP 6), carcinogenic (HP 7), corrosive (HP 8), infectious (HP 9), toxic for reproduction (HP 10), mutagenic (HP 11), release of an acutely toxic gas (HP 12), sensitizing (HP 13), ecotoxic (HP 14) and waste capable of exhibiting one of the above hazardous properties not directly present in the original waste (HP 15).

This stage involves applying at least one of the following methods to determine whether the waste has one or more hazardous properties HP1 to HP15: calculation and/or testing.

Annex 3 of the Communication provides specific methods for determining hazardous properties.

If, at the end of this stage, the waste has at least one hazardous property, it will be classified as a "hazardous mirror entry". Otherwise, step 5 must be followed.

Step 5: Determine whether the waste contains persistent organic pollutants (POPs)

In this last stage, the aim is to determine whether the waste contains POPs and whether the POP content exceeds the limit values defined in the POPs regulation [4].

Note: POPs are chemical substances which, whether produced intentionally or not, accumulate easily in living organisms and are particularly toxic to human health and the environment. In addition to pesticides (DDT, Aldrin, Chlordane, etc.), the main POPs are dioxins and furans, PCBs and polycyclic aromatic hydrocarbons (PAHs). When produced unintentionally, POPs are mainly generated by incomplete combustion. Industrial processes involving combustion (waste incineration, metallurgy, etc.) are therefore the main emitters.

If the waste contains no POPs, or if its POP content is below the limit values, it must be classified as "non-hazardous mirror". If this is not the case, the waste will be classified under the "hazardous mirror" heading.

In conclusion, when classifying waste, it is important to determine whether it is hazardous or non-hazardous waste, so that you know how to manage it and discuss it with your waste management service providers with the right information. This also has an impact on costs, as generally speaking, hazardous waste costs much more to treat than non-hazardous waste. The methodology presented here can help you to carry out your waste classification.

[1] Communication from the Commission - Technical recommendations on the classification of waste [OJEU, 9 April 2018].

[2] Directive 2008/98/EC of November 19, 2008 on waste [OJEU of November 22, 2008].

[3] Decision no. 2000/532/EC of May 3, 2000 [OJEU of September 6, 2000].

[4] Regulation No. 850/2004 of April 29, 2004 on persistent organic pollutants [OJEU, April 30, 2004].

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