Waste management records and annual SIM reporting: a guide for companies
Every company that generates waste — from a small workshop to a factory — has to keep records of it and report them every year. The obligation isn't new, but inspections have become more thorough, and the data in the Integrated Environmental System is increasingly cross-checked against what collectors report. Here is what records that pass an inspection without drama look like.
In short
- Records are kept monthly, for each waste code, in the format in annex 1 to HG 856/2002 — not rebuilt at year end.
- Quantities come from weighbridge tickets and transport forms; ask your collector for monthly totals by code.
- Annual reporting happens in SIM, by the deadline ANPM announces, and supporting documents are kept for at least three years.
Who has the obligation and what the waste record is
OUG 92/2021 on the waste regime requires waste producers and holders to keep records of how their waste is managed, in the format set out in annex 1 to HG 856/2002. It doesn't matter whether you hold an environmental permit or run an office-only business: if your economic activity generates waste, the obligation applies.
Records are kept monthly, separately for each type of waste, identified by its code from the European waste list. For each code you record the quantity generated, the quantity recovered, disposed of or temporarily stored, and the operator it was handed over to.
Where the numbers come from: weighbridge tickets and transport forms
The figures in the record aren't estimated, they're documented. They come from the loading-unloading forms issued for every shipment under HG 1061/2008, from weighbridge tickets and, for hazardous waste, from the shipment forms.
That's why it matters to work with a collector who weighs every handover and sends you the documents monthly, totalled by code. When the quantities in your record match the operator's, an inspection ends quickly; when they don't, the difference has to be explained.
Annual reporting in SIM
The monthly records are totalled once a year and reported in SIM — the Integrated Environmental System run by ANPM, Romania's National Environmental Protection Agency — through an account the company creates on the platform. ANPM announces the deadline for each reporting session; in recent years, reporting for the previous year has taken place in the first quarter.
If the records were kept monthly, reporting is a simple sum by code. If not, it means rebuilding a whole year from invoices and emails, with the risk that your figures won't match what collectors declared for the same handovers.
What to keep and for how long
Keep the records together with the supporting documents: transport forms, weighbridge tickets, contracts with operators and copies of their environmental permits. The legislation sets a minimum retention period of at least three years, and in practice it's worth keeping them longer.
Organise the file by year and by waste code. In an inspection, the first request is usually the record for the last year, followed by the documents behind a few randomly chosen quantities — and a tidy file shortens that conversation considerably.
Frequently asked questions
- Do I need to keep records if I run a small company with no production?
- Yes, if your activity generates waste — packaging, retired IT equipment, maintenance waste. Low volumes make the record simpler, but they don't remove the obligation.
- What happens if I don't report in SIM on time?
- Failing to report or reporting incorrectly is a contravention under OUG 92/2021. It's also easy to spot, because your collector reports the quantities it took from you as well.
- Can the collector help with the reporting data?
- Yes. We send clients the transport documents and a monthly summary of quantities by code, and an annual statement on request, so the figures in their records match what we actually collected.
This article is informational and reflects our practice at the date of publication. Romanian environmental legislation changes frequently — for your company's specific situation, check the texts in force and consult the environmental protection agency or a specialist adviser.