Which Subjects Are Not Required to Prepare a Registration Dossier to Be Issued a Register of Hazardous Waste Generator?

Our company generates approximately 400kg/year of hazardous waste, and we have registered as a hazardous waste generator. However, do we need to prepare a registration dossier to be issued a Hazardous Waste Generator Registration Book? Our company is located in Ha Dong, Ha Noi. Kindly ask the lawyer to respond.

Clause 3, Article 12 of Circular 36/2015/TT-BTNMT provides regulations on entities not required to perform the procedure for registering to obtain the Waste Generator Registration Certificate for Hazardous Waste (CTNH), but only need to register through periodic Hazardous Waste Management Reports, including:

- Facilities generating hazardous waste with an operation duration of no more than 01 (one) year;

- Facilities generating hazardous waste regularly or annually with a total amount not exceeding 600 (six hundred) kg/year, except in cases of hazardous waste listed among the persistent organic pollutants (POP) under the Stockholm Convention on Persistent Organic Pollutants (hereinafter referred to as the Stockholm Convention);

- Offshore oil facilities.

Due to the non-specific information provided, if your company falls into one of the following cases, it is not required to perform the procedure for registering to obtain the Waste Generator Registration Certificate for Hazardous Waste (CTNH):

- Your company operates for no more than 01 year;

- Your company generats hazardous waste regularly or periodically with a total amount of hazardous waste not exceeding 600 kg/year and that hazardous waste is not listed among the persistent organic pollutants (POP) under the Stockholm Convention.

=> In this case, your company only needs to register through periodic Hazardous Waste Management Reports.

If your company does not fall into the above two cases, it must proceed with the procedure for registering to obtain the Waste Generator Registration Certificate for Hazardous Waste (CTNH).

Respectfully!

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