Service
Destruction of Expired Food Supplements
We handle the write-off of whole batches of food supplements and nutraceuticals: from your warehouse to a licensed facility, with the documents that close the batch off both financially and environmentally.
What does the service include?
Food supplements are almost never hazardous waste. The risk they carry is a different one: the batch bears your brand, your batch number and your lot, and if it reappears on the market or in a mixed municipal waste skip, the liability returns to you rather than to the carrier. That is why we work by batch rather than by load. Green Shield Logistics collects the batch from your warehouse, assigns the code, transports it and returns the documents that prove to BABH, RIOSV and the NRA that the product has left circulation for good.
- Inspection of the batch and classification under Ordinance No. 2/2014, usually code 16 03 06 (discarded batches, organic, non-hazardous)
- Preparation and filing of a waste classification worksheet where you do not hold an approved one
- Separation of product from packaging where the packaging carries your brand
- Transport to a facility for disposal or for energy recovery
- A document set for the accounting write-off and for your NIWMS reporting
- Attendance by your own representative at handover, if your write-off protocol requires it
How does the process work?
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Stock list
Send us the items, the quantities in units and approximate weight, the type of packaging and the expiry dates. For batches over one pallet that is enough for us to quote.
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Classification and worksheet
We assign the code. If you hold no approved worksheet for it under Annex 5 to Ordinance No. 2/2014, we prepare one and file it with RIOSV on your behalf. Without an approved worksheet the batch cannot be handed over lawfully. This is the most common cause of delay on a first write-off.
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Collection
We collect from your loading bay with our own vehicles, in a single run, with no intermediate storage and no standing time on a publicly accessible site.
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Handover and documents
The batch is weighed on arrival at the facility. You receive the consignment document, the weighbridge ticket and the acceptance confirmation. We record the quantities in the WMA reporting.
Documents, legal compliance and codes
Writing off food supplements passes through two bodies of law at once. As food: until the moment of write-off the product is food within the meaning of the Food Act and Regulation (EC) No 178/2002. Article 14 prohibits placing unsafe food on the market, and Article 19 obliges the business operator to withdraw it and notify the competent authority; oversight sits with BABH. As waste: from the moment you decide to write it off, the batch is waste under § 1, item 17 of the Supplementary Provisions of the WMA and is managed under the WMA and Ordinance No. 2/2014. Transport is carried out by a party holding a registration document under Article 35(5) of the WMA. Green Shield Logistics operates under document No. 12-РД-2661-00, issued by RIOSV.
The two regimes meet at a single point: the proof that the product was destroyed is a document issued under waste law, but it is used before the food regulator and before the NRA.
Typical codes under Ordinance No. 2/2014
| Code | Description | Type |
|---|---|---|
| 16 03 06 | Organic waste other than that mentioned in 16 03 05 (group 16 03 covers discarded batches and unused materials) | Non-hazardous |
| 16 03 04 | Inorganic waste other than that mentioned in 16 03 03 (mineral and vitamin formulations on an inorganic base) | Non-hazardous |
| 02 03 04 | Materials unsuitable for consumption or processing (for manufacturers of plant-based supplements) | Non-hazardous |
| 02 06 01 | Materials unsuitable for consumption or processing (for manufacturers of bars, blocks and similar products) | Non-hazardous |
| 20 01 25 | Edible oils and fats (for liquid formulations on an oil base) | Non-hazardous |
| 15 01 01 / 15 01 02 / 15 01 07 | Paper and cardboard, plastic and glass packaging | Non-hazardous |
An expired supplement becomes hazardous waste only by exception, for example if it contains ethanol at a concentration that triggers property HP3 (flammability). In that case the code is 16 03 05* and the ADR regime applies. We establish this in advance, not at the loading bay.
Questions & Answers
The batch carries our brand. What happens to the packaging?
If the packaging carries your brand, we treat it as part of the problem rather than as a recyclable stream. On request we separate the product from its primary packaging and send the packaging for destruction instead of recycling. If the brand is not sensitive, the packaging goes to streams 15 01 01, 15 01 02 and 15 01 07, which is cheaper and gives a better environmental result.
Do we need a worksheet for a one-off write-off?
Yes. Ordinance No. 2/2014 draws no distinction between one-off and ongoing generation. The worksheet is prepared for a waste code, not for a collection. We prepare and file it on your behalf; the timescale depends on RIOSV.
Incineration or landfill?
It depends on the code and the facility, not on the type of product. Non-hazardous batches may go to landfill, but where the brand is sensitive we recommend incineration. It is irreversible and is documented with a protocol. We name the facility up front, in the quote.
What documents do we need for the accounting write-off?
Your write-off protocol is supported by our document set: the waste consignment document, the weighbridge ticket from the facility and the acceptance confirmation. Whether a correction of input VAT under Article 79 of the VAT Act is due in your case is for your accountant to judge. Article 80(2) provides exceptions, but they are evidenced precisely by documents proving destruction.
Do we need to notify BABH?
If you are writing off product purely because it expired in your own warehouse, notification is not usually required. If the product has already been placed on the market and is being withdrawn, the notification under Article 19 of Regulation (EC) No 178/2002 is your obligation and is separate from the write-off. We supply the documents with which you evidence completion.
Who is liable if the product reappears on the market?
The waste holder is liable up to the moment it is handed to a party holding the proper document. That is why we return a document set for every batch. They are the evidence that the chain was broken at your end.
Request a batch write-off
Send us a stock list and you will receive a quote naming the facility and the timescale. We work across the country.