Non-hazardous waste: Traceability of treatment streams

Even without a waste tracking slip (BSD), non-hazardous waste (NHW) must be tracked. Producers must maintain a register, ensure carrier compliance, and obtain a recovery certificate.

Marie Faucon
Consultante HSE
Mise à jour : 
30.06.2026
Publication : 
10.12.2016
Table of Contents
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🔎 Key takeaways

  • Mandatory traceability without unnecessary paperwork: Although exempt from a waste tracking slip (BSD), non-hazardous waste (NHW) must be recorded in an internal chronological register, which must be kept for 3 years to prove flow compliance during inspections.
  • Rigorous carrier oversight: As soon as a load exceeds 500 kg, the collection company must hold a prefecture declaration receipt (valid for 5 years), a document that the waste producer is responsible for requesting and verifying.
  • The importance of annual recovery certificates: To validate sorting efforts (paper, wood, plastic, glass, metal), service providers are legally required to provide their clients with an official certificate detailing the volumes and final destination of recovered materials by March 31st of each year.
  • Strict control of landfill access: Disposing of NHW in a storage facility (landfill) requires extensive prior acceptance formalities, including weighing, leaching tests, and proof of upstream sorting to ensure that only the final, non-recoverable portion is landfilled.

    • Please note: This article concerns French legislation. The requirements described may not apply in other countries.

    While they remain exempt from waste tracking slips for now, non-hazardous waste (NHW) is subject to specific regulatory provisions designed to oversee and control its treatment channels.

    A summary of the main formalities to follow to ensure traceability and guarantee the compliance of your waste streams.

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    Waste register entry

    Since July 2011, shipments of non-hazardous waste must be recorded in the waste register kept by any operator producing or shipping waste. As a reminder, this register must include the following information for each outgoing waste stream:

    • Waste shipment date
    • Nature of the waste (nomenclature code)
    • Quantity of waste
    • Name and address of the destination facility
    • Name and address of the carrier, along with their declaration receipt number
    • D or R code corresponding to the treatment performed at the destination facility
    • Classification of the final treatment from the following list: preparation for reuse, recycling, other forms of recovery including energy recovery, or disposal.

    This register, which must be kept for 3 years, is now interconnected with government tools. To centralize flow traceability, your register data and exports must align with the requirements of the National Waste Register (RNDTS) accessible via the Trackdéchetsecosystem. Additionally, facilities generating more than 2,000 tons of non-hazardous waste per year must still report the quantities produced as part of the annual GEREP declaration.

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    Non-hazardous waste: what are we talking about?

    Non-hazardous waste is defined, by default, as waste that does not possess any of the properties characterizing hazardous waste. It was previously referred to as "common waste."

    We generally distinguish between the following types of waste:

    • Mandatory recyclable streams (The "7 to 9 stream" sorting): Driven by the AGEC law, source sorting is a legal obligation for businesses. It now covers 7 to 9 streams depending on your sector (paper/cardboard, metal, plastic, glass, wood, as well as textiles and mineral fractions/plaster).
    • Bio-waste (Full rollout): Since January 1, 2024, source-sorting and recovery of bio-waste (food waste, canteen scraps, green waste) have become mandatory for all businesses, from the very first kilogram produced, with no minimum threshold.
    • Mixed waste: Residual "ultimate" waste that cannot be recovered and is destined for final treatment.

    Selecting a carrier

    Whenever the quantity of non-hazardous waste (NHW) per load may exceed 500 kg, companies collecting and transporting NHW must file a declaration with the prefecture. Only companies exclusively collecting household waste on behalf of public authorities are exempt from this declaration requirement.

    Under the requirement that any waste producer or holder must ensure that the party to whom they hand over waste is authorized to handle it, it is advisable to request and keep a copy of your NHW carriers' declaration receipt.

    As a reminder, this receipt must be kept on board every vehicle and is valid for 5 years.

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    Collection of annual non-hazardous waste recovery certificates

    Collection service providers and operators of facilities recovering waste from your regulatory sorting streams (paper, wood, plastic, glass, metal, textile, plaster, and bio-waste) are required to provide producers or holders who have transferred these categories of waste to them during the year with a source-sorting and recovery certificate specifying

    • the quantities handled
    • the nature of the waste entrusted for recovery
    • and their final recovery destinations.

    This certificate must be issued before March 31st of the following calendar year.

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    Admission procedures for non-hazardous waste disposed of in landfill sites

    Non-hazardous waste similar to household waste

    For the admission of non-hazardous waste similar to household waste, the producer or holder must provide the operator of the final waste storage facility (CSDU) with:

    • Prior information containing the basic characterization elements of the waste. This includes: origin, composition, appearance, nomenclature code, leaching test results, etc.
    • A certificate justifying a prior collection or sorting operation for the purpose of material or energy recovery. This formality is intended to reinforce the ban on admitting unsorted non-hazardous waste to CSDUs.

    The prior information and the certificate must be renewed once a year.

    Non-hazardous waste not similar to household waste

    For their admission, the producer or holder is required to follow a prior acceptance procedure including the following steps:

    • Transmission of the waste's basic characterization data to the CSDU operator. Transmission of the certificate justifying the extraction of its recoverable portion.
    • Performance of an annual compliance check. The goal is to ensure that the waste still conforms to the results of the basic characterization.
    • Issuance by the operator of a prior acceptance certificate (CAP) valid for 1 year. This is based on the results of the basic characterization and subsequent annual compliance checks.

    Every delivery of non-hazardous waste to a CSDU is then subject to an arrival inspection, including:

    • verification of the existence of prior information or a CAP,
    • weighing,
    • a visual inspection,
    • a check for non-radioactivity of the load.

    The CSDU operator must then issue a written acknowledgment of receipt for each accepted delivery. In the event that one of the required documents is not presented or the received waste does not conform to the declared waste, the operator is required to inform the waste producer or holder without delay. A copy of the reasoned notification of refusal of the load is sent to the prefects of the departments where the producer/holder and the operator are located.

    In conclusion, the analysis of these various formalities clearly reveals the legislator's new drive to strengthen traceability requirements for non-hazardous waste (NHW) streams. While regulatory constraints do not yet match those imposed on hazardous waste, the administrative management of non-hazardous waste shipments undoubtedly requires more resources today. It also demands increased vigilance from producing facilities. In this context, using a waste management software can be the solution to simplify and fully master the tracking of NHW streams.

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    Step / Formality Obligations & content Duration / Deadline / Threshold
    Waste register Mandatory record of each outgoing stream: date, nature (nomenclature code), quantity, destination site address, carrier's name and receipt, treatment code (D or R) and its final classification. Retention: 3 years
    GEREP declaration required if > 2,000 tonnes/year
    Selecting a carrier The carrier must hold a declaration registered with the prefecture. The producer must request and keep a copy of this receipt (which must be carried on board the vehicle). Threshold: load > 500 kg
    Receipt validity: 5 years
    Recovery certificate Collection/recovery providers must issue a certificate (paper or electronic) stating the quantities and nature of the waste (paper, wood, plastic, glass, metal, textile, plaster and biowaste), as well as its final destination. Deadline: before 31 March of the following year
    Admission to landfill (CSDU)
    (Assimilated waste)    		 Mandatory provision to the site operator of prior information (characterisation, origin, composition, leaching) and a prior certificate of separate sorting/collection. Renewal: Every year
    Admission to landfill (CSDU)
    (Non-assimilated waste)    		 Mandatory prior acceptance procedure including submission of basic data, a certificate confirming extraction of the recoverable portion, a compliance check, and the issuance of a Prior Acceptance Certificate (CAP). CAP validity: 1 year
    Systematic checks on arrival (weighing, visual inspection, radioactivity)