Section XII of the BDO - what does it mean and who does it apply to?

Phrase „Division XII of the BDO” is sometimes confusing, as it appears in two different contexts in the official materials of the system. In reporting on waste generated and waste management Chapter XII means „Information on waste collected”, while in the registration module Chapter XII concerns a waste producer who is obliged to keep records of waste and who is not required to obtain a waste production permit or an integrated permit. From the perspective of SEO and real user queries, it is the latter meaning that is most often behind a question typed into Google, so the article refers to the Division XII in the BDO register.

Who should fill in Section XII in the BDO

Division XII is primarily concerned with entities that generate non-municipal waste and are required to keep waste records, but are not required to obtain a waste permit or an integrated permit. The official BDO survey directs businesses generating non-municipal waste without the required permit, those generating waste in quantities greater than the record-keeping exemption levels, construction, demolition, renovation, cleaning, maintenance and repair contractors, as well as surface farmers, among others, to this department 75 ha and over, if they generate non-municipal waste. In practice, this means that Division XII often applies to small and medium-sized service companies, workshops, some construction companies, factories and larger farms.

How to complete Section XII correctly and when an entry alone is not enough

One of the most common mistakes is to assume that only the company's registered office needs to be indicated in Division XII. Meanwhile, the official BDO knowledge base explains that the table in Division XII should be completed for all sites where waste will be generated. This is very important for companies operating in several locations or providing services in different locations, as incorrectly listing a location can cause problems in further recording and documenting waste activities. It is also worth noting that the Division XII qualification itself is not included in the list of groups covered by the registration and annual fee, which covers only selected categories of businesses introducing products, packaging, tyres, oils, batteries, equipment and vehicles. This means that an entry in Chapter XII only is not, in principle, included in the catalogue of entries covered by this fee. This is the conclusion of the official list of levied activities.

When Section XII in the BDO should not concern you

Not every company that generates waste has to remain in Division XII. If the activities generate municipal waste only, an entity that has been entered in the BDO Register under Division XII, in light of the applicable legislation does not keep records and does not generate documents in the BDO system, and the official BDO knowledge base indicates that in such a situation he should submit a request for removal from the register. This is very important information for offices, some service activities and entrepreneurs who, out of caution, have registered with BDO, even though they do not actually generate non-municipal waste or do not exceed the record-keeping thresholds. This is why, before registering or updating an entry, it is worth assessing not only the industry, but above all the real nature and scale of the waste generated.

Frequently asked questions

Does Section XII of the BDO apply to every company?

No. It only applies to those entities that generate non-municipal waste and are subject to a record-keeping obligation, but are not required to have a waste production permit or an integrated permit.

Is Section XII in the BDO the same as Section XII in the report?

No. In the register, it is the category of the waste generator included in the record, and in reporting, Section XII stands for „Information on waste collected”.

Is only the registered office of the company entered in Section XII?

No. BDO indicates that the table must be completed for all business sites where waste will be generated.

If I only have municipal waste, should I be in Division XII?

No. BDO's official knowledge base indicates that such an entity does not keep records and does not generate documents in the system, so it should apply for removal from the register.

Does a Division XII-only entry imply a registration fee?

As a rule, this is not apparent from the official catalogue of fees, which only covers specific groups of product and packaging introducers. This is a practical conclusion from the list of activities covered by the levy on the BDO website.

You have doubts as to whether Section XII BDO concerns your company, how to properly complete the application or whether registration, update or deletion is required in your case? Contact us Ekopro Group will help you analyse your responsibilities, sort out your paperwork and answer your questions about BDO. Go to „Contact” and make use of our support.