Starting from 15 June 2025 and by 14 August 2025, subjects who fall under the second phase of RENTRI registration will have to comply with the regulations of Ministerial Decree no. 59 of 4 April 2023, concerning the National Electronic Register for Waste Traceability (RENTRI), the new IT traceability system made mandatory as of 13 February 2025.
From 15 June 2025, in fact, the time window will open for the registration of the following obliged entities in RETRI: entities or companies that initially produce hazardous and/or non-hazardous special waste as specified by Article 184, paragraph 3, letters c), d) and g) of Legislative Decree 152/06 as amended with more than 10 and up to 50 employees.
The classification referred to in Article 184, paragraph 3, of Legislative Decree 152/2006 is shown below:
The following are special waste:
[…]c) waste produced in the context of industrial processing if different from that referred to in paragraph 2; d) waste produced in the context of artisanal processing if different from that referred to in paragraph 2;
[…]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.
N.B. The number of employees is calculated at the overall level for all local units of the company, considering the number of people present in the company on 31 December of the year preceding the reference year, as reported in the following FAQ on the RENTRI website:
Number of employees: number of people who work, with subordinate ties, on behalf of the entity or company, under an employment contract, and who receive remuneration for the work performed. The number refers to all employees present in the company or entity as of 31 December of the year preceding the reference year. For the purposes of calculating the number of employees present on 31 December of the year preceding the reference year, it is specified that part-time and seasonal employees represent fractions of work units as indicated by the Ministerial Decree of 18 April 2005 of the Ministry of Productive Activities. As far as the owner and partners are concerned, it is believed that they should be counted only if they are also classified as employees of the company, i.e. on the payroll of the same.
We remind you that in order to register and subsequently access the portal, you must have a SPID / ELECTRONIC IDENTITY CARD / NATIONAL SERVICE CARD of a top figure of your company, as well as a credit card (or other methods provided by the chosen payment service provider) in order to proceed with the payment, through the PagoPA platform, of the annual contribution and secretarial fees.
The top management may subsequently appoint the appointees who will carry out all operations on RENTRI. They too will only be able to access the portal through digital identity authentication tools.
Once registered, it will be mandatory:
- open and keep the loading/unloading chronological register in digital format (new model) through the support services made available by RENTRI or through interoperable management software. It should be noted that the paper register (new model) that has been endorsed by the Chamber of Commerce and which has been adopted while waiting for registration, can no longer be used;
- transmit to RENTRI, on a monthly basis, the entries in the chronological loading/unloading register in digital format, by the end of the month following the month in which the entry was made.
For further information on the registration procedure, please refer to the instructions published by MASE.
To learn more about the terms and obligations in Ministerial Decree no. 59 of 4 April 2023, we direct you to the links below:
