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Waste Classification
Waste, especially a mixture, can exhibit hazardous characteristics that cause it to fall under several hazard classes or substance groups, or its composition may not be precisely known.
Therefore, classifying waste will require knowledge of its physical and chemical characteristics, the use of Safety Data Sheets (SDS) for the products making up the waste, the potential expert opinion of a chemist, and the application of procedures defined by ADR.
Classification of Specifically Named Substances or Those Presenting a Single Hazard
If the waste consists of a substance specifically named in the ADR, it will be classified under that entry:
Example : Waste consisting of gasoline: UN 1203 WASTE GASOLINE, 3, II, (D/E) ENVIRONMENTALLY HAZARDOUS
If the waste consists of substances presenting only a single hazard or substances that are not specifically named, the most precise collective entry for the waste within the relevant hazard class will be used:
Example: Waste consisting of gasoline and diesel: UN 3295 WASTE LIQUID HYDROCARBONS N.O.S. (Gasoline, diesel), 3, II, (D/E) ENVIRONMENTALLY HAZARDOUS
Classification of Waste Presenting Multiple Hazards (Mixtures)
Step 1: Precedence of Hazard Classes :
If waste exhibiting several hazardous characteristics meets one of the following classes or groups of substances, it will automatically be classified under the class or group of substances presenting the predominant hazard, in the following order:
- Class 7 - Radioactive materials
- Class 1 - Explosives
- Class 2 - Gases
- Desensitized explosives (Classification code D) of Class 3 (e.g., UN 1204 Nitroglycerin, alcoholic solution; UN 2059 Nitrocellulose, flammable solution)
- Self-reactive substances (Classification code SR) and Desensitized explosives (Classification code D) of Class 4.1 (e.g., UN 1344 Trinitrophenol (picric acid), wetted with not less than 30% (mass) water…)
- Pyrophoric substances (ignite on contact with air) of Class 4.2
- Class 5.2 Organic peroxides
- Substances of Class 6.1 which meet the criteria for toxicity by inhalation of Packing Group I
- Class 6.2 - Infectious substances
Step 2: Precedence of specifically designated substances :
If one of the following specifically mentioned substances is present, the waste must be classified under the UN number of that substance:
- Class 3 (UN 1921 and 3064),
- Class 6.1 (UN1051, 1185, 1259, 1613, 1614, 1994, 2480, 2481, 3294) and
- Class 8 (UN 1052, 1744, 1790, 2576),
- Class 9 pertaining to UN numbers 2315, 3151, 3152, 3432,
Step 3 (most common case):
If the waste does not fall into any of the categories listed above, the hazard precedence table in 2.1.3.10 ("two-way entry") allows for the determination of the primary hazard class and subsidiary hazard(s), and the waste will be classified under a collective entry for that primary class.
Example : Mixture of ethanol (Class 3, II) and hydrochloric acid (Class 8, III)
According to the hazard precedence table in 2.1.3.10, classification under Class 3 (flammable) packing group II takes precedence. The mixture will therefore be classified as Class 3 with subsidiary risk 8 – Corrosive:
Collective entry : UN 2924 WASTE FLAMMABLE LIQUID, CORROSIVE, N.O.S. (ETHANOL, HYDROCHLORIC ACID), 3 (8), II, (D/E)
Waste whose composition is not precisely known (2.1.3.5.5):
In the case of waste whose composition is not precisely known, classification may be based on the consignor's knowledge of the hazards of that waste.
In case of doubt, the highest degree of hazard must be chosen.
In this case, except for UN codes 3077 and 3082 (environmentally hazardous substance), it is not possible to assign packing group III: packing group II must be assigned to the waste, if it can be demonstrated that it does not meet the criteria for packing group I.
The entry " WASTE CONFORMING TO 2.1.3.5.5" shall be affixed to the transport document (the BSD if used as an ADR transport document)
Example : Effluent which the consignor knows presents a flammability risk but whose composition is not precisely known:
UN 1993 FLAMMABLE LIQUID N.O.S., 3, II, (D/E) WASTE CONFORMING TO 2.1.3.5.5
REMINDER : Please remember that, even if you rely on the expertise or resources of a third party (particularly a waste service provider), as the consignor, you remain responsible for the classification of your waste.
Selection of packaging and preparation of packages
Packaging Selection
Packaging selection is made by identifying the packaging instructions mentioned in Table A of the ADR, for each UN number.
The general rule is the use of approved packaging (meeting various tests: drop, pressure, etc.) for the transport of dangerous goods.
- The approval certificate : The site must ensure (as the packer) that it holds a copy of the packaging approval certificate.
- Service life of rigid plastic packaging: Rigid plastic packaging has a service life of 5 years maximum (ADR 2025 novelty – Paragraph 4.1.1.21.7: 2.5 years in the case of waste containing chlorinated compounds, in particular) from the date of manufacture.
- Use of Intermediate Bulk Containers (IBCs): IBCs are subject to periodic inspection by an approved body every 2.5 years
Adaptations for certain waste
Packaging instructions may deviate from this rule (with conditions) for certain waste (used aerosols, mixed batteries, UN 2794 acid electrolyte batteries, discarded packaging 3509, etc.).
For example:
Uncleaned empty discarded packaging (UN 3509): Uncleaned empty discarded packaging shipped under UN 3509 may be packed in non-approved packaging meeting packing instructions P003/RR9, IBC08/BB3, or LP02/LL1. Packaging must be rigid and leak-proof. Flexible packaging may be used if there is a complete absence of liquid (e.g., non-approved pallet box).
Discarded aerosols: Discarded aerosol dispensers must be packed in accordance with packing instruction P207: rigid non-approved outer packagings with a maximum net mass ≤ 55 kg (cardboard) or 125 kg (materials other than cardboard)) and special provision P
The latter stipulates that packaging must be properly ventilated to prevent the formation of dangerous atmospheres and pressure build-up. Furthermore, the packaging must be provided with means to retain any released liquid that may escape during transport, for example, an absorbent material or sachet.
Marking and labeling of packages
Next, proceed with:
Marking: UN number (characters must generally be at least 12 mm high) and any additional prescribed marks or statements (Example of special statement: "LITHIUM BATTERIES FOR RECYCLING" for used batteries containing lithium cells or batteries transported under special provision 377 or 636)
Labeling : Main and subsidiary hazard labeling (if applicable) of the package, based on column 5 of ADR Table A: labels of 10 x 10 cm (except for exceptions)
Intermediate Bulk Containers (IBCs) with a capacity exceeding 450 litres and large packagings must bear labels on two opposite sides.
ENVIRONMENTALLY HAZARDOUS mark
Packages containing environmentally hazardous substances (see CLP hazard statements H400, H410, H411, H412, H413, H420) must bear the mark “environmentally hazardous substance”, unless they are single packagings or combination packagings having, per single packaging or per inner packaging of a combination packaging, as appropriate:
- A quantity of 5 l or less for liquids; or
- A net mass of 5 kg or less for solids.
ADR 2025: Repackaging of discarded chemical product packaging
Creation of articles 4.1.1.5.3 and 5.4.1.1.3.3
If your site is faced with the disposal of liquid or solid residues contained in inner packagings of different sizes and shapes for which you no longer have the original outer packaging (example: disposal of chemical product bottles for which you no longer have the original approved carton), you can now repackage them in another outer packaging. The main conditions are:
- The inner packaging must contain goods of classes 3, 4.1, 4.2, 4.3, 5.1, 5.2, 6.1, 8 or 9 only
- The outer packaging must be a packaging (1H2, 1A2, 3A2, 3H1, 3H2, 4A, 4H2), an IBC (11A, 11H1, 11H2) or a large packaging (50A, 50H),
- The outer packaging must withstand the tests for packaging group I (most resistant packagings),
- The chemical compatibility of the polyethylene (PE) packaging is demonstrated if the chemical compatibility of PE with all reference liquids has been verified for a 1H1 or 3H1 polyethylene packaging,
- The common packaging restrictions (« MP ») are complied with,
- Packaging is carried out by personnel who have received appropriate and detailed training.
Selection of service providers and carriers
A waste service provider must be engaged who holds a declaration receipt for waste transport activities and has appointed a safety advisor for the transport of dangerous goods (CSTMD). In addition to the CSTMD certificate, it may be useful to ask carriers for their CSTMD declaration certificates on the government portal.
Preparation of the transport document
Use of TRACKDECHETS Waste Manifests: It is permitted to use the waste manifest (BSD)
TrackDéchets digital manifest as a dangerous goods transport document, if it includes all the particulars required by ADR : Official transport designation, number and description of packages, quantities, additional particulars as may be prescribed (Example: the entry "DANGEROUS FOR THE ENVIRONMENT" for substances meeting this criterion).
The entry WASTE or WASTE IN ACCORDANCE WITH 2.1.3.5.5 will be added to the designation as appropriate and according to the classification procedure (see above):
Examples:
UN 1203 WASTE GASOLINE, 3, II, (D/E) ENVIRONMENTALLY HAZARDOUS
UN 1993 FLAMMABLE LIQUID N.O.S., 3, II, (D/E) WASTE IN ACCORDANCE WITH 2.1.3.5.5
Estimated quantity: Since ADR 2023, it is possible to indicate an estimated quantity under certain conditions. The entry ESTIMATED QUANTITY IN ACCORDANCE WITH 5.4.1.1.3.2 must be included on the transport document.
Partial exemption 1.1.3.6 : If applying the partial exemption of 1.1.3.6 then it will also be necessary to
provide a summary of the total quantities and "calculated values" (factored) for each transport category on the transport document. In this case, it may be useful to use a loading summary accompanying the waste tracking forms.
Reminder : The estimated quantity cannot be used under this exemption, which is based on the quantities actually loaded onto the transport unit.
Shipment Control
It is recommended to complete control checklists to verify the provisions applicable to shipments, within the scope of the responsibilities of the establishment where loading takes place, as defined in 2.1 of Annex I of the amended decree of May 29, 2009, known as TMD:
- Driver Training Certificate Check (ADR driver certificate)
- Vehicle Marking Check: orange placards (package transport)
- Check for compliance with co-loading prohibitions (with explosives)
- Check of package securing and lashing
- Check and handover of the transport document (TRACKDECHET Waste Tracking Document if used as a dangerous goods transport document)
Training for your personnel
ADR 1.3 training must be provided to personnel, particularly those responsible for:
- The selection, purchase packaging, service providers,
- The drafting of the transport document (Creation and verification of ADR mentions on BSDs in TRACKDECHET if it is used as a transport document)
- The preparation of packages: choice of containers, marking and labeling
- The loading of transport units
- The control of shipments.
Refresher courses for this training must be periodically undertaken to account for regulatory changes (TMD decree and ADR every two years), but no formal periodicity is specified in the ADR.
Experience Feedback Management
It is necessary to have an experience feedback system to identify the types and number of incidents, accidents, and events related to waste management and treatment (implementation of corrective or improvement actions).
Event Declaration
Furthermore, the dangerous goods transport mission (MTMD - responsible within the Directorate General for Risk Prevention for the regulation of dangerous goods transport) implemented a service in 2024 to online reporting of "events involving dangerous goods" (via 'Cerbère' authentication).
Reminder : The serious accidents or incidents referred to are those occurring during the loading, filling, transport, or unloading of dangerous goods if the consequences exceed certain criteria set out in 1.8.5.3 of the ADR:
- Personal injuries: Death, intensive medical treatment, hospital stay of at least 1 day, inability to work for 3 consecutive days, or
- Product loss : Quantities exceeding 50, 333, or 1,000 litres/kg, depending on the transport categories of the goods (0 and 1 / 2 / 3 and 4), or
- Note : It should be noted that this criterion also applies if there is an imminent risk of product loss, particularly if damage to the means of transport (packaging, tank, etc.) is too significant to continue transport safely.
- Material damage : Exceeding €50,000 (excluding the cost of transport equipment), or
- Intervention by authorities or emergency services: Evacuation of people or closure of road infrastructure for at least 3 hours.
What about the DGSA?
The ADR requires that any undertaking whose activities include the consignment or transport of dangerous goods by road, or related packing, loading, filling or unloading operations, appoint one or more safety advisers
The decree of May 29, 2009 (TMD decree) specifies the exemptions from appointing a CSTMD in France. Specifically exempted are:
- Shipments of dangerous goods in packages, in quantities below the thresholds defined in 1.1.3.6 of the ADR, and packaging, loading, or unloading operations of dangerous goods in packages in quantities, per operation, below these thresholds,
- Occasional loading or shipping operations of packages in a transport unit for national transport, if the number of operations carried out per year does not exceed two...
Any site carrying out at least one shipment in a tank is de facto subject to the obligation to appoint a CSTMD.
The declaration of your CSTMD must be made on the platform of the Ministry of Ecological Transition. Your CS's annual report should only be uploaded to this platform if requested by the administration (DREAL, DEAL, DRIEE, DRIEA...).