Waste accounting under the new law: PAEW reports a glaring problem in the EcoSystem

Waste accounting under the new law: PAEW reports a glaring problem in the EcoSystem Скриншот з сайту eco.gov.ua
Hanna Velyka

Due to the technical unpreparedness of the enterprise platform the risk of losing permits and licenses 

The Unified Environmental Platform “EcoSystem” currently lacks the functionality for electronic waste management and reporting required by the law on waste management.

This was reported by the PAEW Association of Environmental Professionals.

How it should be according to the law

According to Art. 47 of the Law of Ukraine “On Waste Management”, all waste generated, collected, transported and processed on the territory of Ukraine is subject to accounting. Business entities that are generators and/or owners of waste are required to keep records of waste by volume, code and name, sources of waste generation, and waste management operations.

Part 2 of Art. 48 of this Law also stipulates that enterprises submit reports to the waste management information system by filling out an electronic reporting form using an electronic digital signature.

The Procedure for State Waste Accounting and Reporting, approved by Order of the Ministry of Environmental Protection and Natural Resources of Ukraine No. 1357, stipulates that accounting for waste generation and waste management operations is conducted electronically. According to this document, waste accounting and reporting should be carried out through the e-Cabinet of the business entity created in the functional module of the EcoSystem Unified Environmental Platform.

What is the problem faced by enterprises?

The Association of Environmental Professionals sent a request to the Ministry of Ecology and received a response that currently “the functionality of the relevant module is absent.”

“That is, as of February 05, 2025, business entities are not able to fulfill the obligations stipulated by the Law of Ukraine “On Waste Management” and other permits (license conditions, conditions of the permit for waste treatment operations, environmental conditions of environmental impact assessment conclusions),” PAEW stated.

The Association reminded what consequences are provided for in the Law of Ukraine “On Waste Management” for business entities in case of violations:

  • violation of the rules for keeping records of waste generation and waste management operations, late submission of reports provides for disciplinary, administrative, administrative and economic, civil and criminal liability;
  • failure to comply with the terms of the permit (including waste accounting and reporting) is grounds for its termination;
  • failure to submit hazardous waste management reports for 2 or more quarters is a ground for a decision to terminate the license.

Pursuant to Article 16 of the Law of Ukraine “On Environmental Impact Assessment”, failure to comply with the conditions stipulated in the environmental impact assessment conclusion is grounds for a temporary ban (suspension) of the operation of the enterprise or its individual workshops (sections) and equipment units.

Given the paradoxical situation, the PAEW Association of Environmental Professionals sent an official request to the Ministry of Ecology to consider suspending the Procedure for State Waste Accounting and Reporting and the Model Waste Accounting Form until the EcoSystem is properly functioning.

Last year in September, EcoPolitic reported that the new service for issuing permits for pollutant emissions was practically devoid of functionality.

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