e-SIR (waste information system): how to process hazardous waste transfers

The electronic waste information system (e-SIR) is the Spanish state platform used to process waste transfers within Spain electronically. It allows the movement of hazardous waste, and certain non-hazardous waste, to be tracked in real time, guaranteeing traceability from origin to final treatment.

The electronic procedure has been available since March 2021 and has been mandatory since 1 September 2021 for transfers subject to prior notification. Below we explain what e-SIR is, which waste it covers, which documents are involved and how to process a transfer step by step.

What is the e-SIR system and why is it mandatory?

The e-SIR system centralises information on the generation, transfer and management of waste in Spain under the coordination of the Ministry for the Ecological Transition and the Demographic Challenge (MITECO). Its aim is to provide a consistent, real-time view of waste flows, accessible both to companies and to the autonomous communities, which are the authorities responsible for processing.

Before e-SIR, transfers were documented on paper or on separate regional platforms, which created duplication and errors. With e-SIR the data is recorded digitally and shared between the autonomous communities involved in each transfer.

The obligation rests on two regulatory pillars. First, Royal Decree 553/2020, which regulates waste transfers within Spanish territory and establishes the electronic procedure. Second, the Law 7/2022 on waste and contaminated soils, which reinforces traceability and digitalisation. In practice, any company generating hazardous waste, or non-hazardous waste subject to control, must use e-SIR: it is not an option but a legal obligation, and non-compliance is equivalent to an unauthorised transfer.

Which documents are involved in e-SIR?

The system revolves around two documents regulated by RD 553/2020:

• The prior notification (NT): the document with which the operator notifies a transfer before starting it, in the cases where the rules require prior notification (hazardous waste, waste destined for disposal and mixed household waste, among others). The competent authority can object within a set period.
• The identification document (DI): physically accompanies the waste during transport and identifies the waste, its LER code, the quantities and the operators (producer, carrier and destination manager).

In addition, the operator and the manager must add each transfer to their chronological record and keep a copy of the identification document for at least three years.

Which waste must be registered in e-SIR?

The e-SIR system does not apply to all waste equally, but to that which the rules consider most critical. It is mandatory, first, for hazardous waste: used oils, solvents, batteries, contaminated electrical equipment, chemicals or expired pharmaceuticals, among others. Their transfer must be documented from origin to final destination.

Second, the platform controls certain non-hazardous waste subject to prior notification, such as waste destined for disposal or mixed household waste (LER code 20 03 01). Any company, from a car repair shop to a large construction firm, may be required to use e-SIR if it generates waste in these categories.

Steps to process a hazardous waste transfer in e-SIR

The procedure follows a sequence that guarantees traceability at every stage:

1. Registration and linking. The company registers and links to its authorised waste manager, so that those responsible for production and management are identified in the system.
2. Prior notification (NT). When the transfer requires it, it is notified in advance, detailing the type of waste and LER code, estimated quantity, origin, destination and details of the carrier and manager. The competent authority can object within the legal period.
3. Acceptance by the manager. The destination manager validates that it can accept and treat the waste in line with the rules, preventing it from ending up in an unsuitable facility.
4. Transfer and identification document (DI). The waste travels accompanied by the DI generated in e-SIR, which guarantees its identification during transport.
5. Confirmation of receipt. The manager records the arrival of the waste and the treatment applied (recovery, recycling, landfill or incineration), closing the documentation cycle.

Main advantages of the e-SIR system

Using e-SIR brings clear benefits. The most obvious is traceability: you always know where each waste stream is and what treatment it receives, which builds confidence with the authorities and auditors. It also reduces the risk of penalties, by centralising and validating documentation in a single system and minimising the typical omissions of paper.

It also improves transparency during inspections, because having the digitised history speeds up checks, and it adds administrative efficiency by removing paper formalities and automating communication with the autonomous communities.

Common difficulties with the e-SIR system and how to solve them

The system is not without its challenges. Some companies report synchronisation problems with the regional systems, which delay document validation; in these cases it helps to rely on a manager with experience across several autonomous communities.

Another common error is incorrect LER code assignment: if the waste is not classified correctly from the start, the whole process is invalidated. The solution is to analyse waste periodically and train the staff responsible. Finally, unfamiliarity with the platform among administrative staff causes bottlenecks; appointing an e-SIR officer within the company helps reduce errors.

Frequently asked questions about e-SIR and hazardous waste transfers

What happens if I do not register a hazardous waste transfer in e-SIR?

It is treated as an unauthorised transfer, classified as a serious or very serious offence under Law 7/2022. Serious offences reach up to €100,000, and very serious offences, where they involve hazardous waste, start at €600,001.

Who has to do the registration?

The waste producer is legally responsible, although it can delegate the process to the authorised manager.

Is it necessary to keep the documentation?

Yes. Even though it remains in the system, the operator and the manager must keep a copy of the identification document and their chronological record for at least three years.

How does e-SIR relate to the annual hazardous waste report?

They are complementary obligations: e-SIR documents each transfer, while the annual hazardous waste report summarises the year's activity for the competent authority.

To centralise the traceability and reporting of your hazardous waste, you can rely on a waste management tool.