Non-hazardous waste: Traceability of treatment processes

Even without a BSD, non-hazardous waste (NHW) must be traced. Producers are required to keep a register, ensure the compliance of carriers and obtain a certificate of recovery.

Marie Faucon
EHS Consultant
Update : 
07.11.2025
Publication: 
10.12.2016
Contents
Example H2
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Although non-hazardous waste (NHW ) is still exempt from tracking slips, it is subject to specific regulatory provisions designed to monitor and control its treatment circuits.

A reminder of the main formalities to be complied with to ensure traceability and guarantee the conformity of your supply chains.

Entry in the waste register

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
  • Type of waste (nomenclature code)
  • Quantity of waste
  • Name and address of destination facility
  • Carrier's name, address and declaration receipt number
  • D or R code corresponding to the treatment carried out at the destination facility
  • Qualification of final treatment from the following list: preparation for reuse, recycling, other forms of recovery including energy recovery, or disposal.

This register, which can be drawn up in electronic format, must be kept for 3 years and made available to the authorities in the event of an inspection. In addition, plants generating more than 2,000 tonnes of NHW per year must declare the quantities produced as part of their annual GEREP declaration.

Non-hazardous waste: what are we talking about?

By default, non-hazardous waste is defined as that which does not exhibit any of the properties that characterize hazardous waste. It was previously referred to as "common waste".

A general distinction is made between waste :

  • Recyclables: glass, metals, cardboard, paper, wood, plastics, textiles...
  • Organic biodegradable or biowaste: green waste, organic food waste...
  • Mixed: household refuse

Carrier selection

As soon as the quantity of NHW per load exceeds 500 kg, companies collecting and transporting NHW must file a declaration with the prefecture. Only companies that only collect household waste on behalf of public authorities are exempt from this requirement.

In line with the requirement that any producer or holder of waste must ensure that the person to whom it is handed over is authorized to take charge of it, it is advisable to demand and keep a copy of the receipt of declaration from your HHW carriers.

For the record, this receipt must be carried on board every vehicle and is valid for a limited period of 5 years.

Collection of annual certificates of recovery of non-hazardous waste

Collection service providers and operators of facilities that recover paper, wood, plastic, glass and metal waste are now required to issue producers or holders who have sold them these categories of waste during the year with a certificate stating:

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

These certificates must be issued in paper or electronic form by March 31 following the previous calendar year.

Admission procedures for non-hazardous waste disposed of in landfills

Hazardous waste assimilated to household waste

For the admission of NHW assimilated to household waste, the producer or holder must provide the operator of the landfill for final waste (CSDU) with :

  • Preliminary information containing the basic characterization of the waste. It contains: origin, composition, appearance, nomenclature code, leaching test results, etc.
  • Proof of prior separate collection or sorting for material or energy recovery. This formality is designed to reinforce the ban on unsorted DND being accepted in landfill sites.

Prior information and certification must be renewed once a year.

Non household waste

For their admission, the producer or holder is required to apply a prior acceptance procedure comprising the following stages:

  • Transmission of basic waste characterization data to the CSDU operator. Transmission of the certificate justifying extraction of the recoverable part of the waste.
  • Annual verification of compliance. The aim: to ensure that the waste still complies with the results of the basic characterization.
  • The operator issues a preliminary acceptance certificate (CAP) valid for 1 year. This depends on the results of the basic characterization and annual compliance checks.

All deliveries of non-hazardous waste to landfills are then inspected on arrival:

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

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

In conclusion, an analysis of these various formalities clearly reveals the legislator's new determination to reinforce traceability requirements for non-hazardous waste streams. While regulatory constraints are not yet on a par with those imposed for hazardous waste, the administrative management of non-hazardous waste shipments undeniably requires more resources today. It also calls for increased vigilance on the part of producing establishments. In this context, the use of waste management software can be the solution to simplify and fully control the monitoring of non-hazardous waste streams.