The correct disposal of these products is governed by the Consolidated Environmental Law 152/2006 and provides, in the event of non-management, liability for companies: here is a mini guide to be sure to comply with this rule
If for private citizens disposing of toners is one of the responsibilities to be fulfilled by considering different options as producers of household waste, for companies, offices or commercial activities producers of professional waste, the regulations are more stringent and you face legal responsibilities in the event of non-compliance. But who is required in the company to take care of the correct disposal of toners?
This is a responsibility that falls directly on the business owner (or on the holder of the VAT number in the case of freelancers), who is required to properly dispose of the waste he produces. What does it mean, however, to dispose of them correctly? It means complying with Legislative Decree 152/2006, which obliges commercial activities to prove what happened to toner and cartridges purchased and consumed for professional purposes. The disposal procedure differs according to the type: hazardous or non-hazardous.
The first step to be taken to understand how to dispose of this waste is to identify the type of waste. To do this, it is necessary to identify the EWC (European Waste Catalogue) code of the toner: this numerical code identifies the product and must necessarily be present on the packaging of the article and/or within the indications for use. The presence of an asterisk (*), positioned at the end of the numerical code, indicates hazardous waste.
As regards non-hazardous toner waste, the company must prepare specific containers called “ecoboxes”, in order to isolate only this waste. Ecoboxes are recycled cardboard containers: they come in various shapes and sizes, they are easy to transport and it is possible to brand them. The company is required to empty the ecoboxes at least once a year. A task in this case, not too onerous for companies.
The company is also required to request the “Waste Loading and Unloading Register” from the local Chamber of Commerce: within this document, all operations relating to the production, storage, transport and disposal of hazardous waste generated during work must be noted within 10 days of their performance. The register must also be kept by the company (or the VAT holder) for 3 years, starting from the date of the last recorded transaction. Finally, there is one last document to be paid by the company: the MUD (Single Environmental Declaration Model), in which all movements relating to the waste generated, hazardous and non-hazardous (if the company has more than ten employees) must be reported. This documentation must also be kept and shown to the competent authorities for any checks on the waste disposal methods adopted by the company.
In any case, whether they are hazardous or not, the actual disposal of toners must be entrusted to a specialized company that will produce the FIR (Waste Identification Form), which must always accompany each waste in its phases from collection, to the destination plant, hazardous or not. The copies of the FIR intended for the Customer/Producer are the first (on the occasion of collection) and the last (with stamp and actual weighing of the destination plant) which certifies that the disposal has taken place in accordance with the law. The only way to certify that you have carried out all the procedures correctly is to show the FIR, the “identity card” of the waste: it contains all the information relating to the type of waste, the producer, the transporter and the recipient. With this precaution, not only are you sure that you are absolutely in compliance with the waste management of your business, but you are equally sure that you can legally prove that you have taken charge of recycling materials. The register and MUD must be kept not only for hazardous toner, but also for non-hazardous if the company has more than 10 employees.
Attention: it is important that the company to which you entrust your special waste is registered in the Register of Environmental Managers and has a regular transport authorization (specific for the waste code assigned to used printing toners) and recovery authorization (specific for the waste code assigned to used printing toners), such as Eurocorporation. The penalties provided for by art. 258 relating to the “violation of the obligations of communication, keeping of mandatory registers and forms”, concerns cases of failure to receive and store the FIR Form (waste identification form) and failure to verify the registration of the transporter and the recipient in the National Register of Environmental Managers and their authorizations. In case of doubt, or to find out more, ask us for advice, we would be happy to provide you with the answers you are looking for and protect you from “salty” consequences.
