BDO waste toner cartridges - when does a company have an obligation?

Used toner cartridges do not always mean an entry in BDO is required. The key point is this, what kind of waste it is exactly, whether it contains hazardous components and whether it can be treated as municipal waste in your activity. Official BDO materials indicate that used toner cartridges that do not contain hazardous components may in certain cases be considered municipal waste, in which case, as a generator of municipal waste, the entrepreneur does not register in the BDO register for the generation of this waste. At the same time, waste with hazardous properties from sources other than households cannot be considered municipal waste, so its status must be assessed much more carefully.
What is the waste code for used toner cartridges

This is the most common source of errors. In practice, many companies automatically assign waste toner codes 08 03 17* or 08 03 18, but the official BDO survey clarifies that these codes apply only to waste arising from production, preparation, marketing and use of printing inks. Waste from toner cartridges for office and household printers is coded as follows 16 02 13* or 16 02 14. This distinction is very important, as the correct code later determines whether the waste is hazardous, whether records need to be kept and whether the company should be listed in BDO.
When used toner cartridges trigger an obligation to enter in BDO
The general rule is that the obligation of registration with BDO for a waste generator is linked to the obligation to keep waste records. Official information from the BDO indicates that entities that are completely exempted from waste records are not subject to registration, and that registration applies to waste generators that are obliged to keep records. In practice, this means that a small office or service point with only harmless used toners treated as municipal waste will not always have to register with BDO. The situation is different for hazardous waste: from 1 January 2025, records must be kept for all hazardous waste regardless of quantity, and BDO directly indicates here the code 16 02 13*. So if your company's used toner or cartridge is hazardous waste, the risk of an obligation to record and register with BDO increases regardless of the small mass of the waste.
How to handle toner cartridges in your business so you don't make a mistake
The safest sequence of action is as follows: first the waste code must be correctly established, then it is necessary to check whether the waste has hazardous properties and whether it is recordable at all, and only finally to assess the obligation to enter it in BDO. If a company transfers recordable waste, it must use the documents in the BDO system, and the BDO manual reminds that The Waste Transfer Note shall be created before the start of the transport and only for one code and type of waste.. In practice, this means that with toner cartridges it is not enough to make the general assumption „we have printer waste, so BDO probably applies to us” or, conversely, „it's just an office, so nothing applies to us”. It is the correct classification of the specific waste and the company's real business model that determines whether an entry, record and KPO is needed.
Frequently asked questions
Does every company with a printer have to have a BDO?
No. If a company produces only municipal waste or waste that does not need to be recorded, the mere fact of using a printer does not automatically imply an obligation to register in BDO.
What code do toners from office printers have?
Official BDO material indicates that waste from toner cartridges and toner cartridges for office and home printers is coded as follows. 16 02 13* or 16 02 14, and not automatically 08 03 17* or 08 03 18.
Does used hazardous toner always need to be recorded?
From 1 January 2025, records must be kept for all hazardous waste regardless of quantity, and BDO also indicates in this context the code 16 02 13*.
Is it necessary to issue a KPO when handing over used toner cartridges?
If the waste in question is recorded in BDO, its transfer is carried out using a Waste Transfer Sheet, which is created before the transport begins.
Are you in doubt as to whether your company's used toner cartridges need to be entered in BDO, how to assign them the correct waste code or whether records need to be kept? 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.

