Communiqué on the Road Transportation of Waste

The Communiqué on the Road Transport of Waste was published in the Official Gazette No. 29301 on 20 March 2015 and entered into force on the date of publication (Article 20). It repealed the 2013 communiqué (Article 19). The current text includes two amendments, published on 8 July 2019 (No. 30825, repeated issue) and 1 August 2021 (No. 31555).

Which waste transport does the communiqué cover?

The communiqué sets out the rules for transporting by road the waste with asterisk (*) codes in the waste list of the Waste Management Regulation and the waste specified in Annex 1. Transport of end-of-life vehicles, mining waste and radioactive waste is excluded (Article 2). The Regulation on the Carriage of Dangerous Goods by Road and ADR also apply; waste is carried in vehicles that hold an ADR or vehicle conformity certificate (Article 5).

What licences are needed to transport waste?

Companies and vehicles carrying waste obtain a waste transport licence from the provincial directorates, issued through the Mobile Waste Tracking (MoTAT) system. A company licence is valid for five years and is issued together with at least one vehicle licence; a vehicle licence cannot outlast the company licence, and licences cannot be transferred (Article 13). A vehicle applying for a licence may not be older than 10 years from first registration; it must carry a mobile device, be registered under an authorisation certificate and be covered by financial liability insurance (Articles 14-16). Companies must employ at least one environmental officer or buy services from an environmental consultancy, and drivers must hold an SRC5/ADR training certificate (Article 5).

How do MoTAT and the national waste transport form work?

Before transport begins, the waste producer completes the online national waste transport form (UATF) and approves the transfer request; the system generates a transport control number (TKN) and a transport verification number (TDN). The producer enters the TKN and the carrier enters the TDN on the mobile device; when they match, a discharge approval number is generated and transport starts. The waste treatment facility enters this number to accept the waste and the transport is completed (Article 12). If the mobile device breaks down, transport continues with a printed UATF provided the fault is certified. Forms are kept for at least five years (Article 5).

• Except for medical waste, a licensed vehicle is not required for loads under 50 kg per trip, but a UATF is still used for recording (Article 5).
• Except for medical waste, waste must be delivered to the treatment facility within ten days of loading, and no later than thirty days in cases of force majeure (Article 5).
• Medical waste is not carried in the same vehicle as other waste (Article 5).

What are the duties of the producer, the carrier and the facility?

The waste producer registers on the Ministry's online system, completes and approves its section of the UATF and does not use carriers whose licence is missing or expired (Article 8). The carrier fulfils licence, insurance and UATF obligations and must inform the provincial directorate within 15 days if any submitted documents change (Article 9). A facility with an environmental licence does not accept waste without a UATF or mobile record, performs a consistency check and reports the waste accepted through the mass balance system (Article 10).

What does it mean for destruction and recycling?

Waste sent to a disposal or recycling facility must be moved in a licensed vehicle and traceably; waste is transported to treatment facilities holding a temporary operation certificate or an environmental permit and licence (Article 5). Waste oils, waste vegetable oils and waste batteries and accumulators may be sent to an authorised organisation or to storage areas defined in the relevant regulations before going to licensed facilities.

What should companies pay attention to in practice?

Roadside inspections check the vehicle licence, emergency instructions, first-response equipment, driver certificate, printed UATF and authorisation certificate record (Article 17). Breaches are subject to the sanctions of the Environment Law (Article 18). If a company licence is cancelled for violations, the vehicle licences linked to it are also cancelled and no new licence is issued to the company for six months (Article 13). Waste producers should check their carriers' licences and validity periods before each shipment.