An authorised waste manager is the individual or legal entity, public or private, registered through an authorisation or a prior notification that carries out one of the waste management operations: collection, transport, storage, treatment, recovery or disposal. In Spain the figure is defined by Law 7/2022 on waste and contaminated soils, and working with a properly licensed manager is the legal route for any company to dispose of its waste.
Hiring a manager does not release the producer from liability: handing waste to an unauthorised entity or without traceability documentation can lead to penalties. It is therefore worth understanding which operations exist, how to check a manager's actual licence and what obligations fall on whoever produces or holds the waste.
What it is and the difference between authorisation and notification
The rules distinguish two regimes according to the risk of the activity. Waste treatment operations (recovery and disposal in facilities) and the facilities themselves require prior authorisation from the regional government. By contrast, professional collection and transport, as well as dealer or broker activity, are usually subject to prior notification. In both cases the activity is entered in the waste production and management register.
Each facility or activity receives a code in the register. In practice the operator and its sites are identified through the NIMA (Environmental Identification Number), which lets you check which wastes, by LER code, each site is licensed to manage and with which operation.
Types of operations a manager can carry out
Waste management covers several operations, which a single manager may or may not combine depending on its authorisation:
- Collection: removal of the waste, including its initial sorting and storage, for transfer to a treatment facility.
- Transport: moving the waste in line with freight transport rules and, where applicable, dangerous goods rules (ADR).
- Storage: temporary holding before treatment, with stricter time limits for hazardous waste.
- Treatment: recovery operations (recycling, material or energy recovery) or disposal (landfill, incineration without energy recovery).
The law prioritises these operations according to the waste hierarchy: prevention first, then preparing for reuse and recycling, then other forms of recovery and, as a last resort, disposal. A good manager should steer your waste towards the higher options of that hierarchy.
The following table summarises each operation and the administrative regime that usually applies:
| Operation | What it involves | Usual regime |
|---|---|---|
| Collection | Removal, sorting and initial storage | Notification (professional collection) |
| Transport | Transfer to the treatment facility | Notification |
| Storage | Temporary holding before treatment | Authorisation or notification depending on the case |
| Recovery | Recycling, material or energy recovery | Authorisation |
| Disposal | Landfill or incineration without recovery | Authorisation |
How to choose an authorised waste manager
It is not enough for a company to advertise itself as a manager. Before signing, check several points:
- Valid authorisation and NIMA: confirm the manager is registered for the specific operation and for the LER codes of your waste. Licensing is specific; being authorised for one waste does not mean being authorised for another.
- Capacity and territorial coverage: the authorisation has a scope. If you will move waste between regions or abroad, check the shipment is covered by the transfer rules.
- Documentary traceability: the manager must issue the documentation proving the waste's destination. For hazardous waste, that traceability is channelled through electronic systems such as e-SIR, which records transfer notifications and identification documents.
- Consistent final destination: ask which facility the waste ends up at and which operation is applied; you want it as high as possible in the hierarchy.
Documents you should keep
As a producer you must keep treatment contracts, the identification documents for each transfer and the receipts proving who, how and where the waste was managed. This documentation is what protects you during an inspection.
Producer or holder obligations when hiring a manager
Law 7/2022 keeps the principle that the producer is responsible for its waste until it is correctly treated. The main obligations when hiring a manager include:
- Handing the waste to a registered dealer or an authorised manager for treatment, or treating it yourself if you hold an authorisation.
- Storing, packaging and labelling the waste properly until handover, respecting storage time limits.
- Keeping waste separated by type and not mixing hazardous waste when that would hinder its treatment.
- Holding the transfer and traceability documentation and, for hazardous waste producers, filing the annual report and other information duties.
Liability is reinforced for products subject to extended producer responsibility, where the manufacturer or importer also finances end-of-life management.
Penalties for incorrect management
Law 7/2022 classifies infringements as minor, serious and very serious, with financial penalties that rise sharply in the upper bands and may be accompanied by measures such as closing facilities. Handing waste to an unauthorised party, abandonment or uncontrolled dumping, or failing to prove traceability are among the punishable conducts. Beyond the fine, the responsible party may be required to repair the environmental damage caused. Working only with licensed managers and keeping documentation is the best defence against this risk.
Frequently asked questions
How do I know if a waste manager is authorised?
By checking it is registered in the waste production and management register for the specific operation and LER codes, usually through its NIMA. Licensing is specific by waste and operation, so ask for it in writing and verify it before hiring.
Can a company manage its own waste?
Yes, but only if it holds the relevant authorisation for the treatment operation it wants to perform. In most cases it is more practical and safer to hire an authorised manager that handles collection, transport and treatment.
Am I still liable after handing over the waste?
The producer keeps liability until the waste receives correct treatment proven by documentation. That is why it is key to choose an authorised manager with demonstrable traceability and to keep all transfer documents.
Manage your waste with traceability and no mistakes
Tracking which waste you generate, which manager treats it and whether the documentation is complete is easier with a tool that centralises all your environmental data. Manglai helps companies record their waste streams, maintain traceability and comply with Law 7/2022 without wasting time on scattered spreadsheets.
