There have recently been important changes regarding the MUD, which we remember is the Single Model of Environmental Declaration (MUD) that bodies and companies must submit annually.
This change comes with the Prime Ministerial Decree of 03 February 2023, published in the Official Gazette on 10/03/2023.
The deadline for submitting the MUD has therefore been postponed by 120 days from the date of publication, to Saturday 8 July 2023.
Let’s see, concretely, what these changes are in the MUD and how they affect companies.
The publication of the attachments is the responsibility of the Ministry of the Environment and Energy Security.
On the ministry’s website we find various documents and insights, which are used for correct communication: Annex 1: Instructions for filling out the Single Environmental Declaration Model; Annex 2: Simplified waste communication; Annex 3: Data collection models; Annex 4: Instructions for electronic submission.
The MUD, however, does not have to be presented on the MASE website but, after creating a special file, on the Ecocerved InfoCamere platform – Telematic MUD portal. (www.mudtelematico.it).
Coming to the numerous changes to the model, we remember above all that they concern:
- data on the volume and quantity of waste accidentally fished;
- methodology and minimum quality requirements for the uniform measurement of food waste levels;
- the methodology for collecting data from non-domestic users that can be disposed of outside the public service for the collection of their urban waste;
- new calculation methodologies contained in ARERA Resolution 363/2021/R/RIF and ARERA Resolution no. 2 DRIF/2021;
- data relating to distributors of electrical and electronic equipment (EEE) who collect the relevant WEEE “one for one or one for zero” and who can deliver this waste directly to the treatment plant without going through the municipal collection centre;
- an item dedicated to PET bottles.
There has also been a change in the following sections:
- Registry Section;
- Communication of Urban Waste and collections under agreement;
- Communication Section, Packaging (item dedicated to PET);
- Communication of waste from electrical and electronic equipment.
It should also be remembered that art. 258 of Legislative Decree no. 152/2006, paragraph 1, states that failure to communicate or inaccurate or incomplete communication is punished with an administrative fine ranging from € 2,000.00 to € 10,000.00.
The penalty is reduced for those who, after the deadline for communication but within 60 days, make a late submission. The administrative penalty in this case will be from € 26.00 to € 170.00.
The subjects obliged to submit it do not change and are all the subjects who carry out waste management in a professional manner, waste management consortia and the initial producers of hazardous waste as well as the initial producers of non-hazardous waste deriving from industrial and artisanal processes.
However, there are some exempt subjects: agricultural entrepreneurs, companies that transport their own non-hazardous waste and companies that initially produce non-hazardous waste with less than 10 employees, plus other small exceptions.
There is also the possibility for some subjects to submit simplified communication only when the following conditions are met at the same time:
- Declarants are initial producers required to submit the declaration for no more than seven wastes;
- the waste is produced in the local unit to which the declaration refers;
- for each waste produced, they do not use more than three transporters and more than three recipients;
- deliver the waste to recipients located on the national territory.
Since there are heavy penalties for those who submit a MUD with errors, or not at all, it is always preferable to rely on industry leaders such as Eurocorporation.
A company that has within it esteemed and competent professionals who possess the regulatory knowledge to advise the company, retrieve information and provide the tools for correct compilation.
