Company waste management: what needs to be put in place

Verified 20 June 2025 - Directorate for Legal and Administrative Information (Prime Minister)

Any company that produces or holds waste shall be responsible for their management. It must identify its waste, set up sorting at source, keep track of it in a register, ensure that it is recovered and comply with other regulatory requirements.

Company responsibility for waste

The company is responsible for the management of its waste. This applies to companies in one or more of the following situations:

  • The company's activity waste product.
  • The staff produces waste.
  • The company is in possession of waste.
  • The company carries out processing operations waste, leading to a change in the nature or composition of such waste (grouping, recycling, etc.).

This responsibility implies that the company must ensure compliance with all regulations applicable to the management of its waste.

Non-compliance with these obligations is subject to sanctions.

Penalties for abandonment of waste

The fact ofto abandon, deposit or cause to be deposited waste shall be punished by a maximum of 4 years in prison and €150,000 of fine (natural person) or €750,000of fine (legal person).

FYI  

The failure to comply with a formal notice under a waste prevention and management offense may be severely punished when the fauna, flora or water quality is directly exposed to a immediate risk of serious and lasting harm (may last at least 7 years). The penalty shall then be 3 years imprisonment and €250,000 fine (natural person) or €1,250,000 fine (legal person). This amount may be increased up to three times the advantage derived from the commission of the infringement.

In order to ensure compliance with their obligations, companies must determine the characteristics of their waste. Specifically, for each waste, it must be determined whether it is:

  1. Waste dangerous, including waste containing persistent organic pollutants
  2. Product new non-food or a product food
  3. Waste to be sorted at source (paper, metals, plastics, glass, wood, bio-waste, textiles, mineral fractions and plaster).

What is hazardous waste?

Any waste is considered hazardous if it has one or more hazardous properties (indicated by the abbreviation “HP” with a number).

  • Explosive (HP 1)
  • Fuel (HP 2)
  • Flammable (HP 3)
  • Irritating to skin and eyes (HP 4)
  • Toxic to a target organ (STOT) or toxic by aspiration (HP 5)
  • Very toxic (acute toxicity) (HP 6)
  • Carcinogen (HP 7)
  • Corrosive (HP 8)
  • Infectious (HP 9)
  • Toxic to reproduction (HP 10)
  • Mutagen (HP 11)
  • Releasing an acutely toxic gas (HP 12)
  • Sensitizer (HP 13)
  • Ecotoxic (HP 14)
  • Waste capable of exhibiting one of the dangerous properties mentioned above that does not directly exhibit the original waste (HP 15).

Any waste that does not have any of the properties that make a waste hazardous is considered non-hazardous.

Non-hazardous waste that contains hazardous waste is considered hazardous waste (for example: a jerry can of petrol).

FYI  

In order to identify with certainty whether a waste is hazardous waste, the company must find its number. A decision by theEuropean Union lists all categories of waste. They are detailed in theindex document.

The hazardous waste is indicated by an asterisk (*), after their 6-digit number.

Classification of waste categories

European Union

Pour en savoir plus

One European Commission document provides technical recommendations for the classification of waste. It can help understand how to classify waste and identify hazardous waste.

What is a waste that contains persistent organic pollutants?

Persistent organic pollutants are a set of substances that degrade slowly, accumulate in living organisms, are toxic and easily transported over long distances.

They are listed in Annex IV to a European regulation, the text of which is regularly updated by Parliament.

FYI  

Waste containing persistent organic pollutants which are hazardous within the meaning of the definition of hazardous waste, are subject to hazardous waste obligations.

Companies have an obligation to to separate at source the waste they produce or hold.

All obligations are detailed in the fact sheet dedicated to waste sorting at source.

Maintenance of a waste tracking register

Companies should keep for at least 3 years a register in which are listed all information concerning their waste, namely:

  • Quantity, nature and origin of waste that the company produces, returns to a third party or takes over
  • Quantity of products and materials resulting from the preparation for re-use, recycling or other recovery operations of such waste
  • Where appropriate, the destination, frequency of collection, means of transport and method of treatment or disposal envisaged for such waste.

The detailed content of the register which needs to be kept is available on Legifrance.

In case of control (e.g. by the municipal police), the company will have to provide this register.

FYI  

The company is not obliged to keep this register for waste declared on Trackwaste.

Statement on Trackwaste Platform

The state has put in place a on-line service for waste tracking slip management. This is Trackwaste.

The following wastes must be declared on the Trackwaste portal:

  • Dangerous, including those containing persistent organic pollutants
  • Asbestos
  • Refrigerants
  • Infectious Healthcare Waste (DASRI)
  • End-of-life vehicles (ELV).

This declaration shall be made via waste tracking slips, in a dematerialized manner, on the platform.

Information on other categories of waste can be reported via Trackwaste. It is not mandatory for non-listed categories of waste.

Managing the traceability of waste and asbestos (Trackwaste)

Please note

Where the information is declared by the company, it shall be retained and made available to the State on the online service. This will enable them to be communicated to the authorities in charge of controls.

The declaration of all the waste of the company shall exempt from the obligation to keep a waste tracking register.

Penalties provided for

For companies affected by the obligation to keep a waste tracking register, 2 penalties are provided for where there is no register, refusal to provide it or incorrect information. They shall also apply for offenses relating to the declaration on Trackwaste.

These are:

  • The fine provided for contraventions of 4e class, of an amount of €750 (natural person), or €3,750 (legal persons)
  • One offense, exposing to 4 years imprisonment and €150,000 of fine (natural person), or €750,000 fines (legal persons).

Penalties may be added.

Waste management with a view to recovery

The company is responsible from the management of its waste until its disposal, or valorization final, even when the waste is transferred to a third party for treatment.

The company must to ensure or cause to be ensured the management of its waste by a third party (company of collection, transport, recovery of waste, etc.).

The management and sorting of waste produced or held by the company shall be carried out with the aim of recovering that waste. 2 possibilities management systems exist.

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Recovering waste yourself

The company can recover its waste itself, provided it complies with certain obligations.

Waste treatment or storage as part of their recovery must take place in waste treatment plants, which may fall under the Classification of classified installations for the environment (PCI) subject to declaration, registration or authorization. The company must then make sure to respect the legislation applicable to such installations.

The hierarchy of processing modes waste must be used. It consists of prioritizing, in order:

  1. Preparation for reuse
  2. Recycling
  3. Any other valorization, including energy recovery
  4. Elimination

Waste recovered by the company producing or holding it shall not be subject to the obligation to sort at source.

However, if the absence of sorting affects their ability to be prepared for reuse, recycling or other recovery operations, they must be sorted at source.

Construction and demolition waste may be used for development, rehabilitation or construction work, provided that:

  • The company is able to justify to the competent authorities (mayor, president ofEPCI: titleContent or prefect) the nature of the waste used and its use in a recovery purpose and not elimination.
  • And either the company does not bury or deposit waste on agricultural landor it buries and deposits only waste in the following cases:
    • Use in agricultural land development works
    • Use as fertilizing materials or culture media.
  • And either the recovery of that waste is not not accompanied by a financial contribution, or it is accompanied by a financial contribution and the project is a road work or quarry in operation.

Dispose of the waste to a collection or transport intermediary or directly to the operator of a recovery facility

Waste not dangerous and no inert can be supported by a storage and incineration plant only if the company certifies compliance with its sorting obligations.

To justify it, the company must transmit every year one sworn certificate to the operator of the storage and incineration plant before receiving any waste for the current year. It must be signed by the company's legal representatives. The certificate shall state:

  • The list of company sorting obligations
  • A description of the elements capable of demonstrating compliance with those obligations, and in particular the list of separate collections set up and the associated sorting instructions.

When the waste is transferred to a third party, the company must provide all the information necessary for its treatment.

Every year, the company to which the waste is transferred must issue a certificate to the company delivering the waste. The certificate shall state, in respect of waste collected separately for recovery in the previous year:

  • Quantities of waste expressed in tons
  • Nature of waste
  • Destinations for final recovery.

The model attestation to be completed is available (Annex I-A):

Template for attestation of the disposal of company waste

To find where and to whom to dispose of company waste, SINOE Waste maintains waste directories of economic activities:

Find where to deposit waste from economic activities (Yearbook)

Warning  

The company delivering the waste shall ensure that the person to whom the waste is returned is authorized to take them over, including where they have been mixed with other waste or entrusted to an operator for treatment outside France. The penalty for handing them over to an unauthorized person is a fine by an amount of €750 (natural person), or €3,750 (legal persons).

Warning  

As of February 12, 2025, it is no longer possible to transfer the company's waste to its community's public waste collection service.

Penal sanctions

In the event of non-compliance with the company’s waste management obligations, the following procedure shall apply:

  1. The company shall be notified the facts alleged, the penalties incurred and the measures prescribed to regularize his situation. It may submit its observations.
  2. After 10 days, if the situation is not regularized, she may be forced to pay a fine of up to €15,000 (natural person) or €75,000 (legal person), and be given formal notice to carry out the necessary operations within a specified period.
  3. If the period of notice has elapsed and the company has not complied, the State shall be penalized by one or more of the following measures:
    • Record an amount equal to the cost of carrying out prescribed measureswhich will be returned as they are implemented
    • Immediately pay the necessary fees the execution of the prescribed measures
    • Suspend, at its expense, the installations and structures, the carrying out of works and operations, or the carrying out of activities which give rise to the infringements found
    • Pay a penalty payment daily by a maximum of €1,500 until the prescribed operations have been carried out
    • Pay a fine of up to €150,000 (natural person) or €750,000 (legal person).

FYI  

The failure to comply with a formal notice under a waste prevention and management offense may be severely punished when the fauna, flora or water quality is directly exposed to a immediate risk of serious and lasting harm (may last at least 7 years). The penalty shall then be 3 years imprisonment and €250,000 fine (natural person) or €1,250,000 fine (legal person). This amount may be increased up to three times the advantage derived from the commission of the infringement.

Waste may be freely transported when the quantity transported is less than:

  • 0,1 ton per load of hazardous waste
  • And 0.5 tons per shipment of non-hazardous waste.

The following persons shall also be allowed to transport waste freely, including above the thresholds indicated:

  • Persons who transport the waste they produce
  • Persons collecting household waste solely on behalf of public authorities
  • Persons collecting or transporting clean and sorted uncontaminated land, waste bricks, concrete, tiles, ceramics and other demolition materials, rubble and stones
  • Persons carrying out the delivery of new products and equipment which take back similar waste from final consumers, including packaging, in the context of their distribution activities
  • Operators of classified environmental installations (PCIs) falling within heading 2710 of the classification of classified installations.
  • Persons providing collection of end-of-life vehicles (ELV).

In other cases, it is mandatory to declare the waste collection or transport activity to the prefect of the department where their head office is situated, if it is a legal person, or their domicile, if it is a natural person.

Who shall I contact

The information to be transmitted to the prefect in the context of the declaration of the waste collection or transport activity is as follows:

  • Name or corporate name of the company:
  • Address, telephone, fax:
  • Siret No:
  • Specify the nature of the waste to be taken into account:
    • Hazardous waste
    • Non-hazardous waste
  • Specify the name and contact details of the person to be contacted in the event of an accident or incident
  • Name:
  • Telephone:
  • Fax:
  • “I commit to:
    • Only transport waste to treatment facilities complying with the Law of 19 July 1976 as amended on classified installations for the protection of the environment;
    • Take over and dispose of the waste transported by me which, if necessary, I would abandon, discharge or divert to a destination which does not comply with the waste treatment regulations;
    • Inform without delay, in the event of an accident or accidental dumping of waste, the prefect of the department with territorial competence.’
  • Name of the company’s legal guardian or representative:
  • Date:
  • Signature:

Please note

The activity of collecting or transporting by road waste classified as waste dangerous goods shall be subject to authorization. Authorizations issued for the transport of dangerous goods allow the transport and collection of other waste without declaration to the prefecture. The regulations governing the transport of dangerous goods are set out in an order accessible on Légifrance.

Companies are sometimes subject to other waste management obligations.

In case of doubt, the company can ask for information from its professional organization.

Tableau - Obligations of companies relating to the management of certain wastes

The company is concerned if...

Does the company have obligations?

What are the obligations?

The company produces, imports or distributes new non-food products intended for sale (clothes, household products, furniture...)

The company is subject to specific obligations relating to the management of new non-food unsold goods

Find the information you need to know in the fact sheet for unsold.

The company produces, imports or distributes food products

The company is subject to specific obligations relating to the management of unsold foodstuffs

Find the information you need to know in the fact sheet for unsold.

The company manages inert waste

The company is subject to specific obligations relating to the management of inert waste

To learn more, the company can inquire with its professional organization and to the next link.

The company manages hazardous waste

The company is subject to specific obligations relating to the management of hazardous waste

Find the information you need to know in the fact sheet for hazardous waste.

The company manages products subject to Extended Producer Responsibility (EPR)

The company is subject to specific obligations relating to the management of waste subject to extended producer responsibility.

Find the information you need to know in the fact sheet for Extended Producer Responsibility (EPR) sectors.

The Extended Producer Responsibility (EPR) companies are those that manage at least one of the following product categories or the components and materials used in their manufacture:

  • Packaging used to market products consumed or used by households, including those for which the final consumer is uncertain and those consumed outside the home, printed paper (except books) and graphic papers, intended for end-users producing household and similar waste
  • Packaging used to market products consumed or used by professionals (regardless of industry)
  • Construction products or materials of the building sector for households or professionals
  • Electrical and electronic equipment (EEE), whether intended for use by individuals or professionals

Electrical and electronic equipment (EEE) included in this REP stream are:

  • Heat exchange equipment : large refrigerating appliances, refrigerators, freezers and air-conditioning appliances and other air-conditioning equipment (heat pumps...)
  • Screens, monitors and equipment comprising screens with a surface area exceeding 100 cm² : screens, monitors, laptops, small laptops, tablets and smartphones with a screen area greater than 100 cm²
  • Lamps
  • Large EEE (examples: washing machines, water heaters, dishwashers, stoves, VMCs, microwave ovens, electric heaters, electric fans, etc.)
  • Small EEE (examples: vacuum cleaners, irons, toasters, hair dryers, toothbrushes, razors, scales, e-cigarettes, etc.)
  • Small computer and telecommunications equipment (examples: printers, manual electric labellers, photocopiers, internet box, home phones, mobile phones, smartphones with a screen area of 100 cm² or less, external hard drives and usb keys, etc.)
  • Photovoltaic panels
  • Assisted pedaling cycles (electric bicycles) of a maximum continuous rated output of 0,25 kilowatt, and other motorized personal transport equipment (examples: electric scooters, hoverboards, gyropods, etc.).

EEE that is excluded from this REP stream are:

  • EEE which is specifically designed and settled to fit into a type of equipment excluded from the categories indicated above
  • EEE linked to the protection of the essential security interests of the State, arms, munitions and other war material, if linked for exclusively military purposes
  • Non-electrical bulky components permanently attached to the building or floor, either for housing, protecting, guiding, supporting an EEE, or for transporting fluids to or from an EEE, or set in motion by EEE when they can be easily disconnected during on-site disassembly
  • Large stationary industrial tools (e.g. printing machines, packaging or bottling machines, etc.)
  • Filament bulbs
  • Equipment intended to be sent into space
  • Large-scale fixed installations, with the exception of EEE in such installations which are not specifically designed and fitted for integration and can therefore fulfill their function even if they are not part of the large fixed installation on which they are fitted (examples of large installations concerned: lifts, object conveying systems, etc.)
  • Non-road mobile machinery intended exclusively for professional use
  • Equipment specifically designed for research and development purposes only and available only in a business-to-business context
  • Active implantable medical devices, as well as medical devices and in vitro diagnostic medical devices, where such devices normally become infectious before the end of their life cycle without the possibility of disinfection, sterilization or dismantling of soiled parts prior to their disposal being provided for

Please note

One full list of EEE concerned is available in a review about Légifrance.

  • Batteries
  • Contents and containers of chemicals may have a significant risk to health and environmentwhose waste from these products is likely to be collected by the public waste management service

Contents and containers of chemicals of this EPR channel are:

  • Pyrotechnic products
  • Fire extinguishers and other extinguishing appliances
  • Hydrocarbon products
  • Adhesion, sealing and repair products
  • Materials treatment and coating products and surface preparation products
  • Special care or protective products
  • Common chemicals
  • Solvents and diluents
  • Household biocidal and plant protection products
  • Household fertilizers
  • Textile dyes and dyes
  • Inks, printing and photographic products
  • Aerosol dispensers and gas cartridges

Of details of those products are indicated in a order on Legifrance.

  • Medicines
  • Puncture medical devices used by patients on self-treatment and users of HIV self-testing, including associated electrical and electronic equipment not covered by the EPR scheme
  • Furnishing elements, including cushioned products for sitting or sleeping and textile decorative elements

The furnishings included in this REP stream are:

  • Living room, living room or dining room furniture
  • Supplementary furniture
  • Bedroom furniture
  • Bedding
  • Office furniture
  • Kitchen furniture
  • Bathroom furniture
  • Garden furniture
  • Seats
  • Technical, commercial and community furniture
  • Upholstered products for sitting or sleeping
  • Textile decorative elements such as carpets, curtains and net curtains, and their accessories, whatever the materials of these accessories.

The furnishings excluded from this REP stream are:

  • The specific fittings of professional premises constituting fixed installations which are:
    • Custom-made
    • Assembled and settled by a professional fitter
    • Intended to be used permanently as an integral part of the building or structure, at a predefined dedicated location
    • And may be replaced only by a similar element specifically designed for that purpose
  • Urban furniture elements settled on the estate and in public spaces
  • Floor, wall and ceiling coverings covered by the EPR ‘building products or building materials’, including carpets intended to be permanently settled in buildings
  • Furniture falling under the EPR ‘electrical and electronic equipment’
  • New textile clothing products, shoes or household linen intended for individuals and new textile products for the house
  • Toys
  • Sports and leisure equipment, including bicycles and non-motorized transport equipment (scooters, skateboards, etc.)
  • DIY and garden items
  • Passenger cars, vans and motor vehicles 2 or 3 wheels and motor quadricycles
  • Tires, whether or not combined with other products, including solid tires and tires fitted to a shroud by design
  • Mineral or synthetic oils, lubricating or industrial
  • Recreational or sports vessels
  • Tobacco products equipped with filters composed in whole or in part of plastic and products which are intended for use with tobacco products
  • Synthetic chewing gum non-biodegradable
  • Single-use sanitary textiles : wipes, personal protective equipment, linens and clothing, paper hygiene products, absorbent hygiene and personal protective products, products used for medical care, etc.
  • Fishing gear containing plastic

Companies subject to EPR shall not be not just those who make these products. Those concerned shall carry out at least one of the following actions on products subject to EPR:

  • Elaboration
  • Manufacture
  • Manipulation
  • Treatment
  • Sale
  • Importing

Example :

A company can be submitted to REP for several different sectors. For example, a company selling sporting goods, DIY, electronics and batteries may be subject to EPR under the streams:

  • Sports and leisure equipment
  • DIY and garden items
  • Electrical and electronic equipment
  • Batteries
  • Household packaging (for packaging in which it sells certain of its articles)

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