Non-hazardous waste: Traceability of treatment processes

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🔎 Things to remember

Mandatory traceability without unnecessary paperwork: Although non-hazardous waste (DND) is exempt from the requirement to use a tracking slip (BSD), it must be recorded in an internal chronological log, which must be retained for 3 years to demonstrate compliance with waste management requirements in the event of an inspection.

Strict oversight of carriers: As soon as the weight of a load exceeds 500 kg, the company responsible for collection must have a receipt of registration from the prefecture (valid for 5 years), a document that the waste generator is responsible for requiring and verifying.

The Importance of Annual Recycling Certificates: To validate sorting procedures (paper, wood, plastic, glass, metal), service providers are legally required to provide their customers, by March 31 of each year, with an official certificate detailing the volumes and final destination of the recycled materials.

Strict controls on access to landfills: The disposal of non-recyclable waste at waste storage facilities (CSDU) requires extensive prior acceptance procedures, including weighing, leaching tests, and proof of prior sorting, to ensure that only the final, non-recyclable portion is landfilled.

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.

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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 record, which must be retained for 3 years, is now integrated with government systems. To centralize the traceability of waste streams, the data and extracts from your records must comply with the requirements of the National Waste Registry (RNDTS), accessible through the Trackdéchets ecosystem. In addition, facilities generating more than 2,000 metric tons of non-hazardous waste (DND) 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?

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 :

Mandatory Recyclable Waste Streams (The “7-to-9-Stream Sorting” Program): Under the AGEC Act, source separation is a legal requirement for businesses. It now covers 7 to 9 waste streams, depending on your industry (paper/cardboard, metal, plastic, glass, wood, as well as textiles and mineral/plaster fractions).
Biowaste (Full Implementation): As of January 1, 2024, source separation and recycling of biowaste (food waste, cafeteria leftovers, yard waste) have become mandatory for all businesses, starting with the very first kilogram produced, with no minimum threshold.
Mixed waste: Non-recyclable "final" residual waste intended for final disposal.

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.

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Collection of annual certificates of recovery of non-hazardous waste

Waste collection service providers and operators of facilities that recover waste from your mandated sorting (paper, wood, plastic, glass, metal, textiles, plaster, and biowaste) are required to issue a certificate of source separation and recovery to the producers or holders who transferred these categories of waste to them during the year, stating

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

This certificate must be issued by March 31 of the year following the previous calendar year.

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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.

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Step / Formality	Requirements & Content	Duration / Maturity / Threshold
Waste Registry	Each outgoing shipment must be recorded, including: date, type (billing code), quantity, destination site address, carrier name and receipt, processing code (D or R), and final classification.	Shelf life: 3 years GEREP declaration if > 2,000 metric tons/year
Carrier selection	The carrier must have a declaration on file with the prefecture. The producer must request and keep a copy of this receipt (which must be on board the vehicle).	Threshold: load > 500 kg Validity of the receipt: 5 years
Certificate of Recovery	Waste collection and recycling service providers must issue a certificate (in paper or electronic form) specifying the quantities and types of waste (paper, wood, plastic, glass, metal, textiles, plaster, and biowaste) as well as their final destination.	Deadline: by March 31 of the following year
CSDU Intake (Similar Waste)	The facility operator must be provided with advance information (characterization, origin, composition, leaching) and a certificate confirming prior separate sorting/collection.	Renewal: Every year
CSDU Intake (Non-Recyclable Waste)	Mandatory preliminary acceptance procedure, including the submission of basic data, certification of the extraction of the recoverable portion, a compliance check, and the issuance of a Preliminary Acceptance Certificate (CAP).	CAP validity: 1 year Routine inspections upon arrival (weighing, visual inspection, radioactivity screening)