In the field of waste management, traceability, control and regulatory compliance are essential to ensure safe and responsible waste handling. In this context, and according to Royal Decree 553/2020 regulating the shipment of waste within the territory of the State, prior notification (NP) is a key tool to ensure that waste shipments -both hazardous and non-hazardous- are carried out under control and traceability, to authorized facilities and with duly authorized managers.
What is prior notification and what is its function?
Prior notification is a mandatory administrative procedure for certain waste shipments within Spanish territory, and also for some transboundary movements. It is a communication that the operator must process and send before starting the shipment, in order to inform the competent authorities about the characteristics of the waste, its origin, destination and final treatment.
Its main purpose is to guarantee the traceability of waste from its generation to the receiving facility, avoiding illegal shipments, bad practices or inadequate treatments. In addition, it allows the autonomous communities to oppose the shipment if there are justified environmental, health or legal reasons.
In Catalonia, there is also an Acceptance Form (AF). This is a document similar to the NP, contains the same information, and is processed in the same way (through the SDR). The only difference lies in the type of waste to be managed, the quantity, and the final destination of this rejection.
What wastes require prior notification?
Prior notification does not apply universally to all waste shipments, but is aimed at those that, due to their nature, characteristics or final treatment, require greater administrative and environmental control. Specifically, shipments that meet the following characteristics are required to submit prior notification:
Hazardous and non-hazardous waste for disposal
Any shipment of hazardous waste, as well as non-hazardous waste destined for a disposal operation and according to the classification set out in Annex II of Law 7/2022 on waste and contaminated soils for a circular economy, must be preceded by prior notification. These operations include incineration without energy recovery, landfill, storage prior to disposal and other forms of treatment that do not involve recovery of the materials.
This requirement seeks to ensure that these wastes, which can present significant risks to human health and the environment, are managed only in duly authorized facilities.
Hazardous wastes and mixtures of household wastes for valorization
Prior notification is also required in the case of shipments destined for recovery operations (energy recovery, recycling, composting, etc.), provided that:
- Hazardous waste, such as solvents, used industrial oils, paints, chemicals or contaminated materials.
- Mixed household waste identified with LER code 20 03 01, which includes the non-separated fraction of municipal waste generated in households or similar activities.
Although these wastes can be recovered, they require exhaustive monitoring to ensure their correct treatment and avoid possible detour to inappropriate operations.
Other wastes to be determined by regulation
In addition to the aforementioned wastes, the regulations leave open the possibility of establishing other categories of waste that require prior notification by the legislator, depending on their evolution, hazardousness, complexity of treatment or volume of generation.
Exceptions to the obligation of prior notification
Not all waste movements are subject to this procedure. There is a specific exception for shipments destined exclusively for laboratory analysis. In these cases, waste is moved in small quantities for the sole purpose of determining its composition, hazardousness or viability for future recovery or disposal.
However, even in these situations, the shipment must be accompanied by an identification document, and the quantity transported must be strictly that necessary to carry out the corresponding analysis.
This clear classification of wastes subject to prior notification allows producers and shipment operators to know precisely when it is mandatory to comply with this procedure, thus avoiding penalties and ensuring responsible and compliant management.
How is prior notification handled?
The entire procedure is carried out electronically through the Waste Information System (eSIR).. This system is integrated with the Waste Production and Management Register and centralizes the documentation related to shipments. In certain autonomous communities, they use their own platform, as in the case of Catalonia, which uses the SDR or the Valencian Community the ADCR.
The general process consists of:
What should the advance notice include?
The document should contain detailed information such as:
- Data of the operator and the producer of the waste.
- Type of waste, LER code, quantity and characteristics.
- Destination facility and type of treatment.
- Authorized carrier data.
- Intermediate facilities, if any, as well as the foreseen final treatment.
This content ensures that all actors involved in the management chain are correctly registered and that the waste is managed in accordance with the law.
How long does an advance notice remain in effect?
The NP can be processed on an ad hoc or general basis:
- Timely notification applies to a specific transfer.
- The general (or multiple) covers several transfers with the same characteristics, to the same addressee. It is valid for a maximum of 3 years.
Once this period has expired, or if any essential condition of the transfer changes, a new notice must be issued. In addition, the regulations require that notices be retained for three years from their expiration.
Key to traceability and regulatory compliance
Prior notification is a fundamental piece in the control of waste management in Spain, ensuring that shipments are carried out legally and that each waste arrives at its authorized destination. It also promotes transparency, traceability and compliance with circular economy principles.
We accompany our clients in all the steps related to the document management document managementincluding the processing of prior notifications. Do not hesitate to contact us if you need technical advice, environmental or accompaniment in your obligations as a waste producer or manager.
