The Single Environmental Declaration Model (MUD) is the communication that Bodies and Companies submit every year, indicating how much and what waste they have produced and/or managed and/or transported and/or brokered during the year preceding the declaration. The data for the declaration are those reported in the loading and unloading register.
When must the return be submitted?
The MUD must be submitted by 30 April of each year and, from that date, the 60 days provided for by the legislation for late submission with reduced penalties usually run. Amendments and additions to the MUD are generally ordered by decree of the President of the Council of Ministers which must be published in the Official Gazette by 1 March; in this case, the deadline for submitting the form is subsequently set at one hundred and twenty days from the date of publication of the aforementioned decree.
As for the MUD declaration to be submitted in the year 2023 with reference to the data for the year 2022, however, there are novelties. On 06/03/2023, in fact, the Ministry of the Environment and Energy Security (MASE) published on its website:
https://www.mase.gov.it/notizie/rifiuti-mase-mud-vigore-entro-il-10-marzo-obblighi-slittano-luglio
a note stating that by 10 March the Prime Ministerial Decree will be published in the Official Gazette which will update the forms of the MUD 2023 declaration data for the year 2022. The deadline for the submission of the 2023 MUD declaration by operators will thus be postponed to the first days of July, based on the actual date of publication.
For further information and subsequent updates, please refer to the website of the Ministry of the Environment and Energy Security (www.mase.gov.it).
Articulation of the MUD
The MUD must be submitted for each local unit that is obliged to submit a declaration, communication, denunciation, notification. The term local unit indicates the location where the Declarant has held the waste subject to the declaration, in relation to the activities carried out there (production, preliminary storage, storage, recovery/disposal, final storage).
The declaration is unique, in the sense that, to a registry sheet, all the communications that declaring Bodies and Companies are obliged to submit must be attached, and must be presented to the competent Chamber of Commerce for the territory, or where the local unit to which the declaration refers, or its headquarters, is located.
It should be noted that the local unit coincides with the registered office, if it is a subject that carries out transport-only activities or waste brokerage and trade activities without detention.
The current legislation provides for the following communications:
- Waste Communication:
- Anyone who carries out waste collection and transport activities on a professional basis;
- Waste traders and intermediaries without detention;
- Companies and entities that carry out waste recovery and/or disposal operations;
- Companies and entities that initially produce hazardous waste;
- Companies and entities that initially produce non-hazardous waste deriving from industrial processing, artisanal processing and waste recovery and disposal activities, sludge produced by drinking water and other water treatments and wastewater purification, fume abatement, septic tanks and sewerage networks (as provided for in Article 184, paragraph 3, letter c), d) and g)) of Legislative Decree 152/06 as amended) and who have more than ten employees.
- End-of-Life Vehicle Communication:
- Subjects who carry out the treatment of end-of-life vehicles and related components and materials.
- Packaging Communication:
- Consortia Section: CONAI or other entities referred to in art. 221, paragraph 3, letters s) and c) of Legislative Decree 152/2006;
- Packaging Waste Managers Section: plants authorised to carry out packaging waste management operations referred to in Annex B and C of Part IV of Legislative Decree 152/2006.
- Waste Electrical and Electronic Equipment (WEEE) Communication:
- Subjects involved in the WEEE management cycle falling within the scope of application of Legislative Decree 152/2006;
- Communication on Urban Waste and Collections in Convention:
- Institutional entities responsible for the integrated management of urban waste.
- Notice to Manufacturers of Electrical and Electronic Equipment (EEE):
- Manufacturers of electrical and electronic equipment registered in the national register and collective financing systems.
Subjects who are not obliged to submit the MUD
The following are excluded from the obligation to submit the MUD:
- Entities and companies that produce non-hazardous waste deriving from activities/processes other than industrial, artisanal and waste, water and fume treatment (letters c), d) and g) of Article 184, paragraph 3 of Legislative Decree 152/2006), regardless of the number of employees;
- Initial producers of up to 10 employees, only for special non-hazardous waste referred to in Legislative Decree 152/2006 art. 184, paragraph 3, letters c), d) and g). deriving from industrial and artisanal processes and from the treatment of waste, water and fumes.
In addition, the agricultural entrepreneurs referred to in Article 2135 of the Civil Code and the subjects carrying out activities falling within the scope of the ATECO codes 96 02 01, 96 02 02 and 96 09 02 who produce hazardous waste (including those with EER code 18 01 03*, relating to needles, syringes and used sharps) can fulfil the obligation to register on the waste loading and unloading register and to submit the MUD with progressive storage for three years. years of the identification form relating to the transport of waste or of the replacement documents provided for by Legislative Decree 152/2006 art. 193.
Simplified waste communication
The simplified waste communication reported in Annex 2 to the Prime Ministerial Decree can only be submitted by subjects who produce, in their Local Unit, no more than 7 wastes for which they are required to submit the declaration and, for each waste, use no more than 3 transporters and 3 final recipients. The simplified waste communication cannot be submitted by producers who deliver waste abroad.
Compilation and transmission of the MUD
The MUD must be transmitted electronically, using software specifically developed for the compilation of the MUD through the www.mudtelematico.it, mudsemplificato.ecocerved.it and www.mudcomuni.it sites.
Sanctions
In the event of omission, incomplete, inaccurate or subsequent submission, administrative fines are envisaged.
Service offered by Valli Gestioni Ambientali S.r.l.
Also this year, Valli Gestioni Ambientali will offer its customers the service of filling out the MUD for the waste delivered during 2022 to Valli Gestioni Ambientali.
All the information for booking the service will be contained in the MUD 2023 Information Circular (data for the year 2022) which will be sent to all our customers shortly.
