We bring you the latest news related to the entry into force of RD 180/2015. Special attention for companies in Catalonia:
The Agència de residus de Catalunya (ARC) published last May 18 an informative note trying to clarify how waste should be managed, adapting to the requirements of the new state royal decree (RD 180/2015) and maintaining consistency with the autonomous decree (D93/199) in force.
What waste documentation must be processed in Catalonia?
The treatment contract for all shipments between waste manager and waste producer (a single contract can be made for all waste between the same producer and manager).
Apart from this contract, the D93/1999 continues to apply, i.e. the same procedures for waste management as before, but with some exceptions:
Hazardous waste that does not need an acceptance form according to the Catalan Decree 93/1999 on waste management procedures.
Waste destined for disposal operations that do not need an acceptance form according to the Catalan Decree 93/1999 on waste management procedures.
Mixed household waste (LER 200301) destined for recovery.
Wastes destined for incineration facilities classified as recovery (R1/V61).
These 4 cases will require an Identification Document and a Prior Notification of Shipment (the contents of these documents are detailed in Annexes I and II of RD 180/2015).
For cases in which the Catalan decree requires an acceptance form, this is already considered a Prior Notification, just as the Monitoring Sheet is equivalent to the Identification Document.
In cases where the acceptance form is not required, a delivery note, invoice, letter, etc. will be accepted as a valid identification document. (as long as it contains the information in Annex I of RD 180/2015).
Very important: what to take into account
Acceptance forms opened as of 9 May 2016 are valid for 3 years (instead of 5, as at present).
RD 180/2016 establishes that Prior Notifications shall be valid for a maximum of 3 years and, as mentioned above, an acceptance fiche is considered a Prior Notification.
In conclusion, it will be necessary to keep an eye out for any updates in this regard, as this state regulation entails an increase in the documentation to be processed for cases that were exempt in Catalonia. In these cases, the use of the State forms (available at this link), the Identification Document and the Prior Notification, which are not subject to fees in Catalonia, are considered.
What to do in case of further doubts about the procedures for managing your waste?
If you still have any doubts about how to manage your waste, contact us and we will answer you immediately. We will be happy to help you.
Let us be your environmental department!