UE 333 / 2011

Scrap metal ceases to be waste

The "criteria that determine when certain types of scrap metal cease to be considered waste pursuant to Directive 2008/98 / EC of the European Parliament and of the Council ".

Articles 3 and 4 provide for the criteria applicable respectively to scrap iron and steel (table in annex I) and for aluminum scrap (table in annex II).

Article 5 prescribes the DECLARATION of CONFORMITY' or:

1. The producer or importer shall draw up, for each consignment of scrap metal, a declaration of conformity on the basis of the model set out in Annex III.

2. The producer or importer shall forward the declaration of conformity to the subsequent holder of the scrap metal consignment. The manufacturer or importer keeps a copy of the declaration of conformity for at least one year from the date of issue, making it available to the competent authorities who request it.

3. The declaration of conformity can be drawn up in electronic format.

Article 6 is certainly of interest, which requires the manufacturer to apply a QUALITY MANAGEMENT SYSTEM capable of demonstrating compliance with the criteria indicated in articles 3 and 4, in particular the system must include:

  • control in acceptance of waste;
  • the monitoring of processes and waste treatment techniques;
  • monitoring the quality of the metal scrap obtained from the recovery operation;
  • effectiveness of radiation monitoring;
  • customer comments on the quality of scrap metal;
  • recording of the results of the checks carried out;
  • review and improvement of the quality management system;
  • staff training.

Advantages for the company that certifies itself

Certification Process

> Request for an offer from the customer interested in certification

> Acquisition of all the information necessary for the certification and issue of the offer by AX-REGISTER

> Acceptance of the offer by the customer


> Analysis of any gaps and assessment of the current compliance of the ISMS with the regulatory requirements

> Verification aimed at evaluating the implementation of the principles and structure of the Management System (applicable legislation and regulations, security policy, risk analysis, Statement of Applicability (SoA), clear and consistent definition of the purpose, risk treatment plan)

> Verification aimed at evaluating the adequate and effective implementation of the Management System, through techniques that involve the analysis of documents, observations, interviews with personnel.

> This verification is aimed at issuing the certificate

> Audit carried out annually after certification, to check continuous improvement

> The Renewal Audit is carried out after three years following a complete verification or continuous evaluation over time.

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