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§3.2.1 Step 3: Is sufficient knowledge on the composition of the waste available to determine if it displays hazardous properties either by calculating or testing in line with Step 4?

Obtaining sufficient information about the presence and content of hazardous substances in the waste, in order to be able to determine if the waste might display any of the hazardous properties HP1 to HP15, is an important step in waste classification. Certain information on the composition of the waste is required, independent from the chosen method of assessing the hazardous properties (calculation or testing) as it is described in Step 4. There are several ways to gather information on the relevant composition of the waste, the hazardous substances present and potential hazardous properties displayed: — information on the ‘waste-generating’ manufacturing process/chemistry and its input substances and intermediates including expert judgments (useful sources may be BREF reports, industrial process handbooks, process descriptions and lists of input materials provided by the producer, etc.); — information from the original producer of the substance or object before it became waste, e.g. Safety Data Sheets (SDS), product label or product fiches (see in more detail Annex 2); — databases on waste analyses available on MS level; — sampling and chemical analysis of the waste (see Annex 4). Once information has been gathered on the composition of the waste, it becomes possible to assess if the identified substances are classified as hazardous, i.e. if they are assigned a hazard statement code (see Box 12). In order to determine if the contained substances are classified as hazardous and to learn more about the specific hazard classes and categories the substances may be attributed according the CLP Regulation, please refer to the guidance given in Annex 2. Hazard statement codes Whether substances identified as constituents of the relevant waste are considered hazardous substances, needs to be assessed in line with CLP criteria. For useful information tools in this context, consult Annex 2 of this document. Note that according to CLP Regulation, ‘hazard statements’ are introduced defined as follows: ‘hazard statement’ means a phrase assigned to a hazard class and category that describes the nature of the hazards of a hazardous substance or mixture, including, where appropriate, the degree of hazard; An example for a hazard statement code and assigned hazard class and category from Table 3.1 of Part 3 of Annex VI to the CLP Regulation is: Hazard statement: Description: Hazard class and category: H330 Fatal if inhaled Acute Tox. 2 Thereby the first digit after the ‘H’ represents the categorisation of the hazard (2 — physical hazards, 3 — health hazards, 4 — environmental hazards), the second and third digit are consecutive numbers clustering hazard codes. Information on hazard statement codes assigned to substances can be found in Annex 2. Box 12: Remark on CLP criteria: Hazard Statement Codes Please note that if direct testing of hazardous properties (as it is typically conducted for the physical hazardous properties, see Step 4) is considered, chemical analysis of the waste under consideration may not be necessary. Instead the other information sources as mentioned above may already indicate whether a targeted direct testing of certain hazardous properties could be reasonably performed. If sampling and chemical analysis of the waste under consideration are considered in order to determine its chemical composition (e.g. in order to carry out the calculation approach in the assessment of hazardous properties as described in Step 4), please refer to Annex 4. Those classifying the waste are expected to take all reasonable steps to determine the composition and hazardous properties of the waste before reaching this point. Finally, if the gathered information on the composition of the waste (taking into consideration all above displayed options) does not allow concluding on or assessing the hazardous properties displayed by the waste, neither by calculation nor by testing of the waste in line with the following step 4, then the operator should consider classifying the waste as hazardous (if necessary after consultation with the competent authority). It should be noted that although direct testing methods are available for some hazardous properties as described in Step 4, they are not available for all hazardous properties. As a consequence, direct testing cannot be used to fully classify a waste of unknown composition as non-hazardous.

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