First-quarter environmental declarations: what is due before 31 March

Why they all fall in the first quarter

Most environmental reporting obligations refer to the previous calendar year. The authorities need closed data for their inventories and to report in turn to the Spanish central government and the European Union, so the deadlines are set in the first months of the year.

The practical problem is that they all coincide and depend on information that is usually scattered: waste identification documents, packaging purchases, emission controls, solvent consumption. If that data has been recorded throughout the year, the declarations take a few days to prepare; if not, March becomes difficult.

Annual industrial waste declaration (DARI)

It is filed by producers of industrial waste with data on the waste generated at each site during the previous calendar year. It is governed by Decree 93/1999 on waste management procedures, as amended by Decree 88/2010.

It must be filed before 31 March, exclusively online, through the waste declaration system (Sistema Documental de Residus, SDR) of the Waste Agency of Catalonia. There is a standard version and a simplified version. If the activity carries out waste management operations, the applicable return is the specific one for waste managers (DARIG).

Annual hazardous waste report

Article 65 of Law 7/2022 on waste and contaminated soil requires producers of hazardous waste, among others, to send an annual report to the regional government before 1 March.

In Catalonia, the Waste Agency states that producers who have documented their hazardous waste shipments electronically in the SDR, or in eSIR when the destination is in another region, have already fulfilled this obligation, and that for industrial activities it is also deemed fulfilled by filing the DARI. If your case does not fit either scenario, it is worth checking before that date.

Annual packaging information

Under Royal Decree 1055/2022 on packaging and packaging waste, producers of product listed in the packaging section of the Producer of Product Register (RPP) must send the Ministry for the Ecological Transition information each year on the packaging they have placed on the market, before 31 March of the following year.

Those placing less than 15 tonnes of packaging per year on the market may submit the information in simplified form. This is a separate obligation from the returns the company submits to its collective extended producer responsibility scheme (SCRAP), which have their own deadlines.

PRTR register

Industrial establishments covered by Royal Decree 508/2007 report their emissions to air and water and their waste transfers every year. In Catalonia the report is made to the department responsible for the environment, which validates the data before passing it on to PRTR-España.

For industrial establishments the deadline is the first quarter, up to 31 March. The same campaign is also used to report the results of the self-monitoring referred to in Article 22.1(i) of the consolidated text of the Law on integrated pollution prevention and control (Royal Legislative Decree 1/2016).

Solvent management plan

Installations carrying out any of the activities in Annex I of Royal Decree 117/2003 and exceeding the solvent consumption thresholds in its Annex II must send the authorities each year the data needed to verify that they comply with the emission limits for volatile organic compounds. In Catalonia it is submitted before 31 March of the following year, through the Generalitat's online procedures.

Annual safety adviser report

This is not strictly an environmental declaration, but it usually coincides on the calendar. Companies that load, unload or transport dangerous goods and have appointed a safety adviser must submit the adviser's annual report in the first quarter of the following year, online, to the authority responsible for transport.

How to prepare the campaign without a last-minute rush

1. January
   check which declarations apply to you according to your activity, your permits and what you filed the previous year. Make sure your log-in details and digital certificates are still valid.
2. February
   gather the data for the closed year: waste documents in the SDR, packaging placed on the market, emission control results and solvent consumption.
3. Before 1 March
   confirm that the annual hazardous waste report is covered by the SDR or by the DARI.
4. First half of March
   file the declarations and keep the receipts. Leaving it to the last few days exposes you to platform outages.

Other obligations that are not due in March

Some procedures run on a multi-year cycle and should not be confused with the first-quarter campaign. The basic DUCA (Water Use and Pollution Declaration) is renewed every four years, in the last quarter of the year in which it expires, and the waste minimisation study has its own timetable. Keeping them in a deadline register avoids surprises.