Waste codes in the office: do waste toner cartridges and electronics need to be entered in the register?

In many offices, the subject of waste ends up with the assumption that, since the company pays for waste collection, everything can be treated as municipal waste. However, this simplification can sometimes be costly. Waste from the employees' social area can indeed be treated as municipal waste, but toners, cartridges, used printers, computers, monitors or fluorescent lamps no longer automatically fall into this category. Official BDO material emphasises that waste generated in the staff welfare area is treated as municipal and not subject to registration, but for other waste generated by the business the obligation to register with BDO may still exist. This is why a used toner cartridge or an old laptop is not a minor administrative detail, but a potential point of entry into a company's waste obligations. 

What waste codes apply to toner cartridges and office equipment?

The most common misclassification is to assign ink-related codes to toner cartridges, although these are usually not applicable in the office. BDO points out explicitly that waste arising from toner and cartridges for office printers and household printers is coded 16 02 13* or 16 02 14 respectively. In practice, this means that office toner should not be „lumped” into general categories just because it looks inconspicuous. Used office electronics should be looked at in a similar way. If a company disposes of a printer, computer, monitor or other electrical and electronic equipment, we are dealing with business-related waste and not typical employee household waste. It is the correct classification that is the first step to answering the question of whether a record-keeping and BDO obligation arises. 

Do toner cartridges and electronics always mean a BDO entry is required?

Not always, but very often they require checking. Biznes.gov.pl points out that if an entrepreneur exceeds the amount of waste for which he is not obliged to keep records, he must obtain an entry in the BDO Register and start recording. BDO, on the other hand, reminds that some entrepreneurs can benefit from exemptions if they produce only certain types of waste and only in the quantities indicated in the current regulation. This includes some waste typically occurring in offices, such as fluorescent lamps, batteries or some small equipment waste in small quantities. This means that the mere presence of toners and electronics does not yet give an automatic „yes” or „no” answer. The key factors are the type of waste, its quantity and whether the company benefits from a full exemption from record-keeping. If the exemption is full, there is no obligation to make an entry in this respect. If the company even enters a simplified record or exceeds the limits, an entry in BDO may already be necessary. 

How to reduce the risk of errors and when can an office avoid registration?

The safest approach is to separate social waste from business waste and to check whether the company itself becomes a generator of the waste in question. BDO gives a practical example with fluorescent lamps: if a company does not want to register itself in BDO as a generator of such waste, it can outsource the maintenance and repair of lighting to an external company, which in a certain model becomes a waste generator. The same way of thinking is worth applying more widely to the handling of some of the technical waste in the office. Additionally, it is important to remember that not every piece of cardboard, toner or equipment from the office is municipal waste simply because it originated in the office. In practice, it is best to quickly verify the codes, quantity and source of the waste before the company considers that the topic does not apply to it. A sub-link to a BDO outsourcing service or verification of waste obligations would also work well in this article, as it is with office „minutiae” that costly misinterpretations are most easily made.

If you want to check whether used toner cartridges, printers, computers or other waste from your office needs to be entered in BDO, it is worth verifying this before a problem arises at waste collection or during an inspection. Details can be found under Contact page there, you can describe your situation and match the scope of support to your company's real responsibilities.