Ordinances & WMA

How to Correctly Classify Your Company's Waste

15 March 2025 · 8 min read

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Waste classification

Every business that generates waste is legally required to classify it correctly before storage, transport and handover. Incorrect classification carries administrative fines and can lead to serious environmental violations.

What is the European Waste Catalogue (EWC)?

The EWC (European Waste Catalogue) is a standardised list of six-digit codes describing the origin and nature of each type of waste. In Bulgaria the catalogue was introduced by Ordinance No. 2 of 23 July 2014 on waste classification.

The codes are organised into 20 main groups (chapters), each describing waste from a specific sector or activity. For example:

  • 18 01 — Waste from obstetric, diagnosis, treatment of diseases in humans
  • 20 01 31* — Cytotoxic and cytostatic medicines (hazardous)
  • 20 01 32 — Medicinal products other than 20 01 31* (non-hazardous)
  • 16 05 06* — Laboratory chemicals (hazardous)

Codes marked with an asterisk (*) denote hazardous waste.

Hazardous vs Non-Hazardous Waste

Waste is hazardous if it exhibits one or more of the 15 hazardous properties listed in Annex III of Directive 2008/98/EC: flammability, toxicity, infectiousness, mutagenicity, corrosivity, etc.

Practical tip: If you are unsure whether your waste is hazardous, request the Safety Data Sheet (SDS) from your supplier. It contains the physical and chemical property data needed for classification.

Steps for Correct Classification

  1. Identify the production process — waste is classified by the activity from which it originates, not solely by its physical appearance.
  2. Find the appropriate chapter in the EWC — look for the chapter describing your sector. If the waste does not fit there, search in Chapter 16 (general waste) or Chapter 20 (mixed waste).
  3. Determine whether the code is hazardous — check whether the code ends with (*). For "mirror" codes, determine the properties of the specific waste.
  4. Document the classification — maintain internal records pursuant to Art. 44 of the WMA, including the Waste Production and Quantities Register (WPQRO).

Responsibilities of the Waste Generator

Under Art. 35 of the WMA, anyone whose activities generate waste is required to transfer it only to persons holding a permit or registration document. Handing waste over to unlicensed parties is an administrative offence subject to a fine of up to BGN 20,000 for legal entities.

Green Shield Logistics is a licensed waste carrier with RIOSV permit No. 12-РД-2661-00. You can entrust us with the transport of your waste with a guarantee of full WMA compliance.

Common Classification Mistakes

  • Classifying by physical appearance rather than origin
  • Ignoring the asterisk (*) for hazardous codes
  • Mixing hazardous and non-hazardous waste without a permit
  • Lack of internal documentation

Need transport for your classified waste?

Green Shield Logistics provides documented ADR transport of hazardous and non-hazardous waste across Bulgaria.

Send an enquiry View our services

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