Extended Rental Registration with an amendment to the Milleproroghe decree

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Emma Potter

What changes for businesses and operators in the sector?

Despite the amendment approved by the Senate, the deadline of February 13, 2025 for registration in the Restri remains at the moment unchanged for operators of the first bracketincluding waste treatment plants, transporters, traders and intermediaries, recovery and recycling consortia, as well as companies and manufacturers of hazardous and non -dangerous waste from industrial and artisanal processes with more than 50 employees.

Until the implementing decree of the Ministry of the Environment is adopted, companies belonging to this category must Continue with the forecast records and the use of the Rental System according to the methods established by Ministerial Decree no. 59 of April 4, 2023.

As for the companies of the Second and third Scaglionewhich from 13 February use the new models of chronological and formulating identification of waste of waste (FIR) in paper format, the obligation to continue using these documents up to new provisions remains. The extension, therefore, does not automatically change the operating procedures For none of the categories concerned until the publication of the specific ministerial decree.

Confirmation of the obligation and possible regulatory developments

The amendment, as reported in the official text, establishes that “For the purposes of the operation of the National Electronic Register for the traceability of waste, referred to in article 188-bis of the legislative decree of 3 April 2006, n. 152, by decree of the Minister of the Environment and Energy Safety, to be adopted within 30 days from the date of entry into force of the conversion law of this decree, the terms of ‘sixty days’ referred to in the decree of the Minister of the Environment e of energy security April 4, 2023, n. 59, article 13, paragraph 1, letter a), are modified in ‘one hundred and twenty days’. “

In practice, this means that the extension is not yet effective and will become operational only with the entry into force of the conversion law of the Milleproroghe and subsequently with the adoption of the ministerial decree.

To avoid misunderstandings of a management and organizational nature, companies subject to registration in the Renters must continue to respect the previous deadlines, including the obligation to register by February 13, 2025.

Possible updates will come communicated by the Ministry of the Environment and by the bodies in charge the management of waste traceability. In the absence of contrary indications, the failure to comply with the current timing could lead to the application of sanctions for companies that are not in order.