Assign the right EWC (European Waste Catalogue) code
The task of assigning the identification code of each waste is not so obvious and those who have tried their hand at this practice know well how recognition is not always certain and unambiguous.
Often, however, these difficulties are attributable to defects in technical evaluation and regulatory interpretation. It is therefore necessary to clarify this procedure, which must be carried out in accordance with the D.Lgs. 152/06. The legislator has introduced a specific list (European Waste Catalogue), in relation to Decision 2000/532/EC, within which, depending on the type of activity, each waste finds its precise location. The list of these identification codes (called EER 2002) is attached to Part Four of Legislative Decree 152/06 and is divided into 20 classes, each of which groups together waste deriving from the same production cycle.
Anatomy of the EWC code
Each waste is assigned a 6-digit numerical code. Each pair of numbers identifies different information.
- The first two digits identify the class: sector of activity from which the waste derives
- The central digits identify the Subclass: production process of origin
- The last two digits identify the specific type: the single waste produced
For example: Class 06.00.00: Waste from inorganic chemical processes; subclass 06.09.00: waste from the production, formulation, supply and use of phosphorous products and chemical phosphorus processes; Category 06.09.02: Phosphorous waste.
How is waste classified?
But how is the classification carried out? To carry it out correctly, it is necessary, first of all, to identify the production process from which the waste originates: in this way the first pair of digits (class) is identified. Then it is necessary to identify the specific phase of the production activity from which the waste originates: from here the second pair of numbers (subclass) is identified. Finally, it is necessary to identify its specific description and thus identify the last two digits (the specific type).
Let’s take an example. If I have to label a waste consisting of plastic bags, I cannot code it with CER 170203 (demolition and construction plastic), since this code is related to the class of waste generated by construction and building demolition operations. I will then have to use the 150102 code that identifies plastic packaging waste.
All these data to be condensed lead to handling several codes together, often generating confusion: identical waste from a chemical-physical point of view will have different codes, if they originate from different production processes.
Plastic, for example, can be classified with the code 170203 if it derives from the demolition of buildings, with the code 150102 if it is packaging or with the 191204 if it derives from mechanical treatments carried out on waste.
Most common mistakes in waste classification
Making mistakes during the evaluation is easy: so let’s see which are the most common ones:
- Assign a code based on description and not on provenance. It happens that the code assignment is based on the category, but this is a mistake. The figures to refer to are the first two, those relating to origin.
- Choose the code according to the transporter’s permissions. If the EWC code becomes an impediment in the delivery of waste to a transporter, because the latter is not authorised to manage that specific CER code, it is wrong to assign a code just to be able to easily deliver it to the transporter. Economic implications aside, it is not lawful from a legislative and procedural point of view.
- Thinking that a material or substance with an EWC code is waste. The first step is always to verify whether the substance can be configured as waste, i.e. that it is a substance or an object that the holder must get rid of or has the obligation to do so. This distinction is fundamental as the inclusion of a given good in the list of EWC codes does not mean that this material is waste in all circumstances.
- Determining whether a waste is hazardous or not, without proper analysis. To understand if a waste is hazardous, there are two alternative ways: the waste is classified as absolutely hazardous or it is a mirror item of a so-called “mirror EER code”. In the first case, there is no doubt: some waste is originally indicated as hazardous on the basis of the production cycle of origin or because it has dangerous chemical-physical characteristics. The second case includes waste which, depending on the manufacturing process, may or may not include hazardous substances based on the quantities contained. In this case, it will be necessary for the waste producer to take and chemically analyze a sample, to establish whether the concentrations of hazardous substances exceed the legal limits and, therefore, whether to classify the hazardous waste with EWC and asterisk.
Waste identification: the guide indicated by the legislation
These are just some of the most common errors in CER code attribution, but they are certainly not the only ones. It should be emphasized that, in case of difficulty, the legislation indicates four steps as a guide to the identification of waste, which we report verbatim:
- Identify the source of the waste by consulting the titles of Chapters 01 to 12 or 17 to 20 to find the six-digit code for the waste in question, with the exception of the codes of those chapters ending in the digits 99. Note: Packaging waste that has been separately collected (including combinations of different packaging materials) should be classified under heading 15 01 and not under heading 20 01.
- If none of the codes in Chapters 01 to 12 or 17 to 20 is suitable for the classification of a particular waste, Chapters 13, 14 and 15 should be examined to identify the correct code.
- If none of these codes is suitable, the waste shall be defined using the codes in Chapter 16.
- If a particular waste cannot be classified even by the codes of Chapter 16, code 99 (waste not otherwise specified) preceded by the digits of the chapter corresponding to the activity identified in point 2 shall be used.
This mini guide can help you recognize and limit errors in the management of your waste, but clearly it cannot be exhaustive of such a rich and complex subject.
How many times is the CER 99 abused when the specific code cannot be identified? And how many times, in front of a EWC code with a mirror voice, does it happen for convenience to assign the code of hazardous waste without being sure of its real nature, instead of proceeding with a chemical analysis? These are some of the most common practices we witness: practices that appear to be decisive, but which generate higher management costs and rather demanding bureaucratic implications.
If you don’t want to make management mistakes or if you have already made them and no longer want to rely on chance approximately, contact Eurocorporation for the analysis of your waste: we use the official methods IRSA-CNR, UNICHIM, EPA, NIOSH, OSHA, or the specifications of the sector in question.
Is there no official procedure? No problem, we can develop internal analytical practices.
