WHAT IS RENTRI? (link)
RENTRI (National Electronic Register for Waste Traceability) is the acronym that identifies the new information system for the traceability of waste provided for by art. 188-bis of Legislative Decree no. 152/2006, which introduces a digital management model for the fulfilment of the obligations already provided for by Legislative Decree no. 152/2006, such as the issuance of transport identification forms and the keeping of historical loading and unloading registers. This system is managed by the Ministry of the Environment and Energy Security (MASE) with the technical-operational support of the National Register of Environmental Managers and the Chambers of Commerce system.
The regulatory details of RENTRI are governed by Decree No. 59 of 4 April 2023 “Regulation of the waste traceability system and the national electronic register for waste traceability pursuant to Article 188-bis of Legislative Decree No. 152 of 3 April 2006″ published in the Official Gazette (Official Gazette) no. 126 of 31/05/2023 (link).
SUBJECTS OBLIGED TO REGISTER (link)
The subjects referred to in art. 188-bis of Legislative Decree no. 152/2006, as amended by Legislative Decree no. 213/2022, are required to register with RENTRI, through accreditation to the telematic platform for the provision of data, as follows:1. entities and companies that carry out waste treatment;2. producers of hazardous waste;3. entities and companies that collect or transport hazardous waste on a professional basis or that operate as traders and intermediaries of hazardous waste;4. consortia set up for the recovery and recycling of particular types of waste;
- the subjects referred to in art. 189, paragraph 3, of Legislative Decree 152/2006 as amended, with reference to non-hazardous waste. As regards the subjects referred to in point 5. The following are included:• transporters of non-hazardous waste;• intermediaries of non-hazardous waste;• producers of non-hazardous waste referred to in points c), d) and g) of art. 184 of Legislative Decree 152/2006 as amended, with more than 10 employees. The classification referred to in Article 184 is as follows:
“c) waste produced in the context of industrial processes other than urban waste; d) special waste produced in the context of artisanal processing other than urban waste; g) waste deriving from the recovery and disposal of waste, sludge produced by drinking water and other water treatments and wastewater purification, as well as waste from fume abatement, septic tanks and sewerage networks.”
TIMING FOR REGISTRATION TO THE RENTRI (link)
There are three different time slots for registration with RENTRI, depending on the type of activity carried out and the number of employees. Three registration brackets have been identified:
1) starting from 15 December 2024 and by 13 February 2025:
• the initial producing bodies or companies of hazardous and non-hazardous special waste*, with more than 50 employees;• all other entities other than producers (waste treatment plants, transporters, traders/intermediaries, consortia);• associations, delegates;
2) from 15 June 2025 and by 14 August 2025:
• entities or companies that initially produce hazardous and non-hazardous special waste*, with more than 10 and up to 50 employees included;
3) starting from 15 December 2025 and by 13 February 2026:
• entities or companies that initially produce only special hazardous waste, with a number of employees less than or equal to 10.
* For non-hazardous waste, reference is made to the subjects referred to in Article 189, paragraph 3, of Legislative Decree 152/2006 and subsequent amendments: this is waste produced in the context of industrial and artisanal processing, and the recovery and disposal of waste, sludge produced by drinking water and other water treatments and wastewater purification, waste from fume abatement, septic tanks and sewage networks.
Producers of special hazardous waste who are not part of organisations of bodies and companies are required to register with RENTRI as of 15 December 2025 and by 13 February 2026, regardless of the number of employees.
By connecting to the www.rentri.gov.it website you can check the timing of registration with RENTRI in relation to the activity of your company. The number of employees is calculated overall for all local units of the company, considering the number of people present in the company as of December 31 of the year preceding the reference year, as reported in paragraph 3 of Article 13 of Ministerial Decree 59/2023.
Anyone (even non-obliged subjects) will be able to register independently and on a voluntary basis for RENTRI starting from 15 December 2024, even in advance of the second or third bracket.
WHAT CHANGES: THE NEW FORMS AND REGISTER (link)
As a result of the RENTRI, from 13 February 2025 the obligation to use the new models of the chronological register of loading and unloading and identification form for the transport of waste (FIR) will come into force. Therefore, all companies, including companies not obliged to register with RENTRI and companies in the second or third bracket, from 13 February 2025 will have to use the new form and register models.
NEW WASTE IDENTIFICATION FORMS (FIR): they can be downloaded and endorsed through the use of the RENTRI platform starting from 23 January 2025, but can only be used starting from 13 February 2025.
From 13 February 2025, it will therefore be mandatory to use the new Form model, which can be downloaded through the management system or the RENTRI platform, to be digitally stamped; the Form can still be used in paper format until 13 February 2026, after which it will only be used in digital format. It should be noted that, starting from the introduction of the new model, the old forms of the form, although stamped, can no longer be used by companies.
NEW LOADING AND UNLOADING REGISTERS: starting from 4 November 2024, the new paper printing service of the chronological loading and unloading register format (link) will be made available, to be endorsed at the Chambers of Commerce (CCIAA). The service will be accessible through the RENTRI portal and will not require any registration or registration. We remind you that, from 13 February 2025, all companies, whether registered with RENTRI or not, will have to use the new forms. Three scenarios are therefore presented:A. companies that register with RENTRI by 13 February 2025 will use the new register model in digital format, either directly on the RENTRI platform or through appropriate interoperable company management systems;B. companies that register with RENTRI in the other brackets indicated, from 13 February 2025 until the date of registration, must still use the new register form in paper form, endorsed at the relevant Chamber of Commerce;C. companies that do not register with RENTRI, but that use a register for waste traceability, from 13 February 2025 will have to use the new paper waste register model, endorsed at the relevant Chamber of Commerce.
Until 12 February 2025, the old register models and forms with the related management methods will remain in force; from 13 February 2025 the old register models, although stamped, can no longer be used.
SUPPORT OFFERED BY VALLI ENVIRONMENTAL MANAGEMENT
VALLI GESTIONI AMBIENTALI, for customers required to register with RENTRI who do not have a specific management system for the management of RENTRI, through a web application, connected to its company management software interoperable with RENTRI, can support customers in fulfilling the obligations of data communication to the National Electronic Register for Waste Traceability.
We reiterate that, starting from 13 February 2025, all waste producers obliged to keep loading and unloading registers and to issue FIRs, even if not yet obliged to register with RENTRI, will have to use the new models of waste loading and unloading registers and FIRs and will have to access RENTRI services to fulfil the obligations of endorsement of the new FIR models and for printing loading registers and unloading of waste in paper format to be endorsed at the competent Chambers of Commerce.
Informativa RENTRI – VALLI GESTIONI AMBIENTALI
