Waste shipments: treatment contract, prior notification, identification document and eSIR

What changed with Royal Decree 553/2020

Royal Decree 553/2020 of 2 June governs the shipment of waste within Spanish territory. It came into force on 1 July 2020 and replaced Royal Decree 180/2015, which we discussed on our old website. It keeps the logic of its predecessor (contract, notification and identification document) but makes electronic processing the norm and strengthens traceability: the waste, the origin, the carrier and the destination must match in every document.

Today the procedure relies on the national eSIR platform (Sistema Electrónico de Información de Residuos, the electronic waste information system) of the MITECO ministry, which receives and validates notifications and identification documents and cross-checks them against the waste production and management register. The autonomous regions have gradually been integrated into eSIR; in Catalonia the process runs through the waste documentation system (Sistema Documental de Residus, SDR) of the Waste Agency of Catalonia.

The three documents

• Treatment contract. Mandatory for any shipment. It is signed by the shipment operator (normally the producer) and the destination waste manager. It identifies the waste (LoW/LER code), the quantities, the treatment operation, the frequency and the obligations in the event of rejection. No contract, no shipment.
• Prior notification of shipment (NT). Only for shipments of hazardous waste (for recovery or disposal), of non-hazardous waste destined for disposal and of mixed municipal waste (LER 20 03 01). It is submitted at least ten days before the first shipment and is authorised by the regions of origin and destination; if they do not object within that period, it is deemed accepted. A single NT can cover several shipments of the same waste, origin and destination for up to three years.
• Identification document (DI). Accompanies each movement. Part A is completed before the waste leaves the site; Part B is completed by the waste manager on receipt, accepting or rejecting it. It is the document that, in an inspection, is checked against the chronological record and the quantities collected.

What the authorities check

In compliance notices and inspections, what is usually checked is the consistency of the chain: that the LER code in the contract is the same as in the DI, that the carrier and the destination are the authorised ones, that the quantities in the chronological record tally with the DIs and with the annual report, and that hazardous waste does not exceed the storage time limits at the point of origin. A wrong code or an expired contract is enough for the waste manager to reject the waste or for a compliance notice to arrive.

Checklist before each shipment

1. Valid treatment contract
   With the destination waste manager, for that LER code and that treatment operation.
2. Accepted NT, where applicable
   For hazardous waste and for non-hazardous waste destined for disposal. Check the expiry date.
3. DI issued before departure
   Part A complete and consistent with the contract and the NT. Keep Part B once the waste manager accepts the waste.
4. Authorised carrier
   Registered for that type of waste.
5. Chronological record up to date
   Record the movement on the same day. It is the basis of the annual report.