e-SIR (Waste Information System): How to Process Hazardous Waste Transfers

The Waste Information System (e-SIR) is the digital platform developed by the Ministry for the Ecological Transition and the Demographic Challenge to monitor waste transfers in Spain in real time. Since 2021, it has been mandatory to register the movements of hazardous waste and, in some cases, non-hazardous waste as well.

This system ensures traceability, transparency, and legal compliance. However, for many companies, its use represents both an administrative and technical challenge.

Below, we explain what the e-SIR system is, why it is mandatory, and how your company can process hazardous waste transfers to avoid penalties.

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

The Waste Information System (e-SIR) is a digital tool developed by the Ministry for the Ecological Transition and the Demographic Challenge (MITECO) that centralizes all information related to the generation, transfer, and management of waste in Spain. Its main goal is to guarantee traceability from the point of origin to final treatment, offering a complete, real-time overview of waste flows.

Before the implementation of e-SIR, companies managed this documentation on paper or through independent regional platforms, which led to duplications, registration errors, and a lack of coordination. With e-SIR, a standardized framework has been established nationwide, where data is digitally recorded and accessible to both companies and competent authorities.

The obligation to use this system is based on two key regulations: Law 7/2022 on Waste and Contaminated Soils for a Circular Economy, which requires strengthening traceability and digitizing processes to comply with EU directives, and Royal Decree 553/2020, which specifically regulates waste transfers within Spain and establishes the documentary procedures that must now be completed online.

In practice, this means that any company generating hazardous waste, or controlled non-hazardous waste, must use e-SIR to document its movements. It is not optional but a binding legal obligation. Failure to comply can result in fines of up to €100,000 for serious infringements.

Beyond compliance, e-SIR represents a cultural shift in environmental management: it helps companies move toward digitalization, improve transparency with auditors and investors, and strengthen their sustainability credentials.

Which waste must be registered in e-SIR?

The e-SIR system does not apply indiscriminately to all waste but to those considered most critical due to their potential environmental impact and the need to guarantee traceability.

• Hazardous waste: This category includes used oils, solvents, batteries, contaminated electrical equipment, chemicals, and expired pharmaceuticals, among others. These materials pose risks to health and the environment if not managed properly, so their transfer must be documented from origin to final destination.
• Certain non-hazardous waste: The platform also monitors some non-hazardous waste subject to special oversight, such as construction and demolition materials, sludge from wastewater treatment plants, or certain industrial by-products. Although not classified as hazardous, their volume and risk of illegal dumping make strict control necessary.

This means that any company, from a small auto repair shop to a large construction firm, may be required to use e-SIR if it generates waste in these categories. Failure to register transfers is treated as unauthorized movement and sanctioned as a serious offense under Law 7/2022.

Steps to process a hazardous waste transfer in e-SIR

The waste transfer procedure via e-SIR follows a clear sequence that guarantees traceability at every stage:

1. Registration in the platform: The company must register and link to its authorized waste manager. This ensures that the legal parties responsible for production and management are correctly identified in the system.
2. Prior notification: A document is submitted with all transfer details: type of waste and its EWC code, estimated quantity, origin, destination, and information on the transporter and final manager. Without this notification, the transfer cannot take place.
3. Acceptance by the manager: The authorized waste manager must validate that they can accept and treat the waste according to regulations. This prevents hazardous waste from ending up in inadequate facilities.
4. Physical transfer: The waste must always be accompanied by a transfer document generated by e-SIR, ensuring traceability and proper identification during transport.
5. Confirmation of receipt: Once received, the manager confirms reception in the platform and records the treatment applied (recovery, recycling, landfill disposal, or incineration). This closes the documentation cycle and ensures legal compliance.

Main advantages of the e-SIR system

Using e-SIR offers clear benefits for both companies and authorities:

• Total traceability: Real-time visibility of each waste stream and its treatment builds confidence for both public administration and private auditors.
• Reduced risk of sanctions: Centralized documentation minimizes errors and omissions that were common with paper-based processes.
• Greater transparency for audits: During environmental inspections, having a fully digital record speeds up verification and reduces audit times.
• Administrative efficiency: By eliminating paper procedures and automating communication with regional authorities, companies save management time and reduce associated costs. According to official data, organizations that fully migrated to e-SIR have cut their bureaucratic burden related to waste by about 30%.

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

Despite its advantages, e-SIR is not free of challenges. Companies most often report:

• Synchronization issues with regional systems, causing delays in document validation. Solution: work with waste managers experienced in integrating with multiple regions.
• Incorrect EWC code assignment, which invalidates the entire process. Solution: conduct regular waste analyses and train staff responsible for classification.
• Lack of staff knowledge of the platform, leading to errors and delays. Solution: invest in training and consider appointing an “e-SIR officer” within the organization to specialize in this area and reduce mistakes.

In short, while the system requires adaptation and technical know-how, the key lies in training, careful documentation review, and partnering with specialized waste managers to ensure compliance.

FAQs about e-SIR and hazardous waste transfers

What happens if I don’t register a hazardous waste transfer in e-SIR?

It is considered a serious or very serious infringement, with fines of up to €100,000.

Who is responsible for registering transfers?

The waste producer is legally responsible, although they may delegate the process to the waste manager.

Is it necessary to keep the documentation?

Yes. Even though it is stored in the system, the company must keep digital copies for at least 3 years.