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Discussion
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vvilla Apr 07, 2017 03:00 PM
Hi all. Animal by-products and derived products not intended for human consumption (Commission Regulation (EU) No 142/2011) should be reported to E-PRTR (Regulation (EC) No 166/2006) as off-site transfers of waste?
Replies (5)
EEA Apr 19, 2017 11:50 AM
Hello,
We need advice from the European Commission (DG Environment) to answer your question. We will come back to you as soon as we hear from them. Kind regards.
virginia Apr 20, 2017 10:44 AM
Thank you very much for the information given. I am looking forward to hearing from you as soon as possible
EEA Apr 25, 2017 02:51 PM
Transfers of waste are to be reported to the E-PRTR as soon as they fall, annually, above the relevant threshold:
- 2 tonnes per year when the waste is hazardous
- 2000 tonnes per year when it is non-hazardous

The E-PRTR Regulation refers to the EU law on waste to define what is to be considered as such. The current EU law on the matter is Directive 2008/98/EC. Waste is defined as follows:

- any substance or object which the holder discards or intends or is required to discard;

While the Directive refers to the specific regulation on animal by-products (currently Regulation (EU) No 142/2011) in those aspects covered by such legislation, reporting of transfers of these materials when becoming waste would not be amongst the aspects regulated by that piece of legislation.

This is why, our current understanding is that:
- When the holder of the animal by-product or derived product either discards it or intends to/is required to discard it, the material falls under the definition of waste. If it is transferred, when above the relevant threshold, the quantities are to be reported under the E-PRTR Regulation.

Please be aware that it is within the European Commission’s mandate to interpret EU law. For that reason, in case of any follow up questions we suggest you contact the Directorate General for the Environment, the service in charge of both the waste and the E-PRTR legislation. You can contact them here http://ec.europa.eu/environment/contact/form_en.htm
Kind regards.
virginia Apr 28, 2017 09:38 AM
Thank you very much for the information given. Kind regards
 
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