Waste — documentation duties and officers (Germany)
A list of checks and obligations with their cadence, ready to add to your agenda.
For companies that produce, transport, trade in or dispose of waste in Germany. Covers the German waste record system (disposal certificate, consignment note, waste register), the electronic eANV procedure, the GewAbfV separate-collection documentation and the waste officer (Abfallbeauftragter). Since the September 2026 batch it also covers the end-of-life streams that come out of fire-safety and first-aid equipment: classification of decommissioned extinguishers, the two-tonne threshold for the waste producer number, PFAS firefighting foams and the lithium batteries of defibrillators. Does not cover treatment plant permits, transfrontier waste shipments, or packaging (VerpackG) and WEEE (ElektroG) take-back duties.
Questions about this product?
Ask what is in the manuals, how often the maintenance is due and what it takes to do it.
What it already has at hand
- No manual on this page
- 13 planned checks, the most frequent every 12 months since the last inspection
Planned checks
Informative summary verified on 12/09/2026. It does not replace legal advice: the regulation cited prevails. If you spot an error, report it.
Some checks are only mandatory in certain countries: pick yours and the list follows.
In Italy this product has no planned checks: the ones listed apply to other countries.
In France this product has no planned checks: the ones listed apply to other countries.
- 01
Keep the waste register and retain it for 3 years
Producers, holders, collectors, traders, brokers and disposers of hazardous waste keep a register recording quantity, type, origin and destination of the waste, producible on request by the authority. Registers must be kept at least 3 years from the entry, carriers at least 12 months; the evidence is the register itself, on paper or electronic. Applies in full to hazardous waste, while for non-hazardous waste the duty mainly concerns waste management plants; private households are excluded.
continuous check, confirm every 12 monthsLegal obligationKrWG § 49 i.V.m. NachwV §§ 23-25Germany onlySourceverified on 11/09/2026 - 02
Complete and file a consignment note for every shipment
Every individual shipment of hazardous waste travels with a consignment note signed by producer, carrier and receiving plant; the producer files its copy in the waste register. The evidence is the set of consignment notes carrying the disposal certificate number, and the monthly check confirms that every returned copy has come back. Applies to shipments of hazardous waste; it is not required for the small quantities covered by the handover note.
continuous check, confirm every 1 monthsLegal obligationNachwV §§ 10 und 11Germany onlySourceverified on 11/09/2026 - 03
Keep the disposal certificate valid (5 years maximum)
For every hazardous waste stream sent for disposal or recovery the producer keeps a disposal certificate confirmed by the authority, or runs it under the privileged procedure; the confirmation is valid for at most five years and must be renewed before it expires. The evidence is the numbered certificate with the declaration of responsibility, the plant's acceptance declaration and the authority confirmation: set the reminder at least three months before the date printed on the confirmation. Applies to producers, holders and disposers of hazardous waste; below 2,000 kg per year and waste type the small-quantity rule of § 2 Abs. 2 NachwV replaces the certificate with a simple handover note.
every 60 months since the last inspectionLegal obligationNachwV § 5 Abs. 4 i.V.m. KrWG § 50Germany onlySourceverified on 11/09/2026 - 04
Run the waste records electronically (eANV)
Hazardous waste records must be handled electronically through the ZKS-Abfall clearing house, with a qualified electronic signature and transmission within the prescribed deadlines. The evidence is a valid signature certificate, the operator number and the transmissions logged in ZKS: the most useful annual check is the certificate expiry date, which blocks the whole flow. Applies to producers, carriers and plants handling hazardous waste above the small-quantity thresholds; small-quantity producers may use an authorised representative.
continuous check, confirm every 12 monthsLegal obligationNachwV §§ 17-22 (Abschnitt 4: elektronische Nachweisfuehrung)Germany onlySourceverified on 11/09/2026 - 05
Document the separate collection of commercial waste
Producers of commercial municipal waste document compliance with the separate-collection duty for the listed fractions, or the technical or economic reasons for deviating, using site plans, photographs, delivery or weighing notes and recipient declarations stating mass, type of recovery and destination. The file must be produced on request by the authority, electronically if asked, and the annual check keeps it complete. Applies to every company producing commercial municipal waste (paper, glass, plastics, metals, wood, textiles, bio-waste and others); any deviation for technical impossibility or economic unreasonableness must be justified in writing.
continuous check, confirm every 12 monthsLegal obligationGewAbfV § 3 Abs. 3 (und § 4 Abs. 5 für Gemische)Germany onlySourceverified on 11/09/2026 - 06
Dispose of PFAS firefighting foam correctly
The ban is no longer in preparation: the POP Regulation and REACH Annex XVII prohibit PFOA, its salts and C9-C14 PFCA substances in firefighting foams, with a replacement deadline that expired on 4 July 2025. What is still under assessment is the much wider REACH restriction on all PFAS substances, which is a different matter. For the waste itself: concentrates, premix and rinsing water with AOF of 5 µg/l or more are hazardous (EWC 16 10 01*), water below the threshold falls under EWC 16 10 02. Discharging to the sewer or releasing deliberately remains a criminal matter.
continuous checkLegal obligationVerordnung (EU) 2019/1021 (POP) i.V.m. Anhang XVII REACH; LAGA-Merkblatt PFAS-haltige Abfälle (Mai 2025)Germany onlySourceverified on 12/09/2026 - 07
Send the waste officer to refresher training every 2 years
The appointing company must ensure the waste officer regularly attends refresher courses recognised by the competent authority, at least every two years. Even where the role is outsourced to an external consultant, the company keeps the evidence, namely the attendance certificate. Applies to every appointed waste officer, internal or external.
every 24 months since the last inspectionLegal obligationAbfBeauftrV § 9Germany onlySourceverified on 11/09/2026 - 08
Classify decommissioned fire extinguishers correctly
When an extinguisher leaves service, the waste classification follows the extinguishing agent, and the split is clean: foam, water (even merely dosed with additives) and halons are hazardous waste; ABC or BC powder and CO2 are NON-hazardous waste. This is the verifier correction to the old intermediate category of "special but not hazardous", which does not exist. In neither case may the appliance go into municipal collection: a specialist route is always needed, dealer, manufacturer or authorised collection point. The duty lies with the waste producer, that is the company disposing of it.
continuous checkLegal obligationAVV (Abfallverzeichnis-Verordnung); Merkblatt bvfa zur Entsorgung von FeuerlöschernGermany onlySourceverified on 12/09/2026 - 09
Appoint the waste officer in writing
Companies exceeding 100 tonnes per year of hazardous waste or 2,000 tonnes per year of non-hazardous waste, and the listed installations (permitted plants, landfills, hospitals, waste water treatment plants), appoint a waste officer in writing and notify the authority. The evidence is the appointment document with the notification and the proof of technical competence; the annual check is a recalculation of the thresholds against the previous year's quantities. Thresholds refer to the calendar year and must be recalculated every year, and a single officer may cover several installations of the same operator.
continuous check, confirm every 12 monthsLegal obligationKrWG § 59 i.V.m. AbfBeauftrV § 2Germany onlySourceverified on 11/09/2026 - 10
Obtain the waste officer's annual report
The waste officer draws up an annual written report to the operator on the waste management measures taken and planned, as § 60 Abs. 2 KrWG requires. No fixed statutory date applies: the first quarter of the following year is the usual practice, and the evidence is the signed, dated report. Applies only to companies subject to the appointment duty.
every 12 months since the last inspectionLegal obligationKrWG § 60 Abs. 2Germany onlySourceverified on 11/09/2026 - 11
Return the lithium batteries of defibrillators
The lithium batteries of defibrillators fall under the general free take-back duty of the German batteries act: producers and retailers must take them back at no cost, and those under 500 grams — the typical size for an AED — may be handed in at ordinary battery collection points. They never go into general waste or into the company mixed stream. The text of the batteries act was not reread while writing this card and the framework is moving towards the European batteries regulation: confirm the route with your supplier.
continuous checkLegal obligationBattG; Verordnung (EU) 2023/1542Germany only - 12
Request the producer number above 2 t per year
Anyone producing more than two tonnes of hazardous waste a year enters the full documentation regime and needs a waste producer number issued by the competent authority. The threshold is reached faster than it looks: around two hundred water extinguishers a year are enough. The count is made once a year across all hazardous streams of the company, not per waste type, and must be redone after an extraordinary disposal of equipment.
continuous check, confirm every 12 monthsLegal obligationNachwV i.V.m. KrWG; Merkblatt bvfa zur Entsorgung von FeuerlöschernGermany onlySourceverified on 12/09/2026 - 13
Document separation of construction and demolition waste
On construction sites the client and the contractor separate the ten fractions listed in § 8 GewAbfV and document the separation in the same way as under § 3, site by site. The evidence is the site file with plans, photographs and weighing notes. Applies to construction companies and clients; it does not apply to projects producing a total waste volume of 10 cubic metres or less.
continuous check, confirm every 12 monthsLegal obligationGewAbfV § 8 i.V.m. § 3 Abs. 3Germany onlySourceverified on 11/09/2026
In Switzerland this product has no planned checks: the ones listed apply to other countries.
In Austria this product has no planned checks: the ones listed apply to other countries.
In United Kingdom this product has no planned checks: the ones listed apply to other countries.
In Spain this product has no planned checks: the ones listed apply to other countries.
In Portugal this product has no planned checks: the ones listed apply to other countries.
In United States this product has no planned checks: the ones listed apply to other countries.
In Other country this product has no planned checks: the ones listed apply to other countries.
Something not right on this page?
Help us keep it accurate: every report is read by a person.