Annual hazardous waste report

The annual hazardous waste report (in Spanish, "memoria anual de residuos peligrosos") is a mandatory summary that producers and managers of hazardous waste must submit to the competent regional authority in Spain. It is based on the chronological record that each operator must keep, and it sets out the type, quantity and final destination of each waste stream, ensuring traceability and compliance with the waste management hierarchy.

The obligation is established in Article 65 of Law 7/2022, of 8 April, on waste and contaminated soil for a circular economy. Producers of hazardous waste, professional carriers of hazardous waste and waste dealers and brokers must send the report before 1 March of the year following the one to which the data refer. In several regions, operators that have already documented their waste transfers electronically (through the national e-SIR register or the regional electronic system) may be exempt from submitting the report separately.

Minimum contents

The report typically includes identification data, a description of the processes that generate the waste, total quantities (usually in tonnes), the treatment applied and the corresponding recovery operations (coded R 1 to R 13) or disposal operations (coded D 1 to D 15), together with the corresponding LER codes.

How it is prepared

Data capture relies on daily records, acceptance documents and the identification documents that accompany each transfer. With the help of environmental-management software, the monthly information is consolidated, and a technical officer checks the consistency of LER codes, weights and transport routes before submission.

A common error: mismatch between transfer documents and the report

One frequent problem is a discrepancy between the figures declared in the report and those in the underlying transfer and identification documents. Such inconsistencies can trigger inspections and penalties under Spanish waste and environmental-liability legislation, so a good practice is to reconcile the data periodically (for example quarterly) and keep discrepancies to a minimum.

More than a bureaucratic requirement

The annual hazardous waste report turns operational data into environmental and economic intelligence. Companies that integrate its preparation into their management systems improve efficiency, strengthen waste traceability and reduce the risk of penalties. At Manglai we help companies manage and report their waste and prepare their sustainability reporting. Discover how Manglai can help you.