§1.3.1 Packaging waste and contents

Separately collected packaging waste is to be allocated under sub-chapter 15 01. Such waste must not be classified under sub-chapter 20 01, as the heading of sub-chapter 20 01 explicitly excludes sub-chapter 15 01. Under sub-chapter 15 01 the following MNH entries are contained: 15 01 01 paper and cardboard packaging MNH 15 01 02 plastic packaging MNH 15 01 03 wooden packaging MNH 15 01 04 metallic packaging MNH 15 01 05 composite packaging MNH 15 01 06 mixed packaging MNH 15 01 07 glass packaging MNH 15 01 09 textile packaging MNH The following MH entries are provided: 15 01 10* packaging containing residues of or contaminated by hazardous substances MH 15 01 11* metallic packaging containing a dangerous solid porous matrix (for example asbestos), including empty pressure containers MH Before it is decided which entry for packaging waste is most suitable, one has to assess whether the waste actually should be classified as packaging waste at all, or rather be classified according to its content. Figure 2 of this Annex, which is based on the UK waste classification guidance (6) (hereinafter ‘the UK Guidance’) provides a flow chart supporting this decision. Please note that derogations from the flow chart presented in Figure 2 may be possible, e.g. for mixed packaging from households after considering Member State specific conventions and approaches. For example, the Flanders Waste Classification Guidance (7) (hereinafter ‘the OVAM Guidance’) states that mixed packaging waste which is cleaned at a licensed company and thus can be assumed that no hazardous residues are contained by the packaging waste, can be classified as non-hazardous. In order to allocate the sub-chapter 15 01 it is necessary to determine whether the packaging/container is nominally empty (cf. Step P1 and P2 in Figure 2). It is suggested to understand ‘nominally empty’ in the sense that the product's contents were effectively removed. This removal can be achieved by draining or scraping. The circumstance that minimal residues of the contents are present in the packaging waste does not preclude the packaging waste to qualify as ‘nominally empty’ and does not prohibit the packaging waste from falling under subchapter 15 01 packaging waste. To decide upon the question whether packaging is nominally empty, practical approaches applied in individual Member States can be used. For example in Austria related to packaging ‘completely emptying’ means proper emptying (‘free of trickles’ such as leftover powder, sludge and drops; brush clean, spatula clean) except for unavoidable residues, without applying additional measures (such as heating). The term does not include cleaning of containers. A container has been emptied completely, if in the case of a renewed attempt of emptying, such as inverting the container no longer drops or solid remains are released. When the packaging contains residual material that cannot be removed by normal standards (e.g. due to size of aperture or nature of material), then the waste should not be classified as packaging waste but as the residual material waste (e.g. half empty tin of solidified varnish might be classified as 08 01 11*). In the case that waste containers are washed to remove the contents, further considerations should be taken to ensure an environmentally sound method is used. If the packaging is nominally empty, it should be checked if it is metallic packaging which contains a dangerous solid porous matrix (e.g. asbestos in old fireproof packaging material), including empty pressure containers (Step P3 in Figure 2). Such metallic packaging needs to be assigned to code 15 01 11*. With respect to steps P4a and P4b in Figure 2 above, it has to be noted that packaging which is nominally empty but which still can contain small quantities of residues can be either hazardous because (1) it displays hazardous properties because of the remaining residues OR because (2) it displays hazardous properties because of the packaging material itself (of which the packaging is manufactured) because it is contaminated with hazardous substances from the manufacturing process (e.g. with impregnating agents, stabilisers, flame retardants, plasticisers, pigments) or during the use phase. Accordingly, it has to be assessed in Step P4a whether the waste displays hazardous properties due to the remaining residues and, in Step 4b, whether the packaging material itself displays hazardous properties. Calculations whether threshold limits defined in Annex III to the WFD, based on hazard statement codes, are exceeded, should be based on the weight of the waste as it is when the classification of the waste is undertaken (i.e. a comparison would be made between the amount of contained hazardous substances against the total weight of the nominally empty packaging plus the leftover residue). If hazardous properties can be related to the residue or to the packaging material itself, entry 15 01 10* will apply. Otherwise a non-hazardous entry according to the packaging's material needs to be assigned (codes 15 01 01 to 15 01 09) (8).

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07