The Human Environment and Transport Inspectorate (ILT) has conducted inspections in the last months of 2024 and the first months of 2025 at 31 municipal depots for the collection of small hazardous waste (KGA depots). Violations were found at 22 of the inspected depots. Overall, there is still insufficient supervision by depot staff on the intake of hazardous waste from citizens.
The inspections specifically focused on the collection and packaging of hazardous (waste) materials at the depots prior to transport to processing locations. This falls under the Hazardous Materials Transport Act (Wvgs), which the ILT oversees in the Netherlands. The overall storage and processing of industrial and household waste at municipal depots is also monitored by Environmental Services.
Batteries
The ILT found, among other things, that mistakes are made in packaging and labeling the small hazardous waste collected at the depots. For example, inspectors found poorly packaged batteries releasing hazardous substances such as lead or acid, which can lead to water and soil pollution. Lack of labeling increases the risk of exposure to toxic substances, as those involved are unaware of the contents and hazardous properties of the hazardous waste.
To safely package and label, it is important that staff at the depots and at waste collectors and processors have sufficient knowledge of the regulations. This ensures that people and the environment can be protected against the release of toxic and harmful substances.
Findings
The inspected municipal depots and waste processors have been informed of the ILTs findings. (Re)inspections will continue in the coming period to implement improvements. The ILT is also in contact with the Association of Dutch Municipalities (VNG) and the Royal Dutch Association for Waste and Cleaning Services (NVRD) to explore how more and better information can increase knowledge of the KGA depots and their staff. Additionally, the Association of Waste Companies has been informed of the ILTs findings, and discussions are underway about what is needed to implement improvements.
Background
Municipalities are required to collect small hazardous waste. Each municipality may decide how to do this. Some municipalities have a municipal or KGA depot, while others have a chemical collection vehicle. The municipal collection must prevent small hazardous waste from individuals from ending up among household waste or being dumped and disappearing into the soil or water.
It is important that the municipal collection and treatment of small hazardous waste is done correctly: according to the international agreement for the transport of hazardous materials by road (ADR). With small hazardous waste, it is often difficult to fully comply with the ADR, for example, because it is unclear which specific substances are involved and which packaging or transport regulations apply. Therefore, in 2015, the Ministry of Infrastructure and Water Management established the “Regulation for the Transport of Household Hazardous Waste 2015,” commonly referred to as the “Chemical Collection Vehicle Regulation.”
Chemical Collection Vehicle Regulation
The Chemical Collection Vehicle Regulation allows for the safe, accessible collection of small hazardous waste using a specially designed vehicle or at special collection points. When collecting, less strict requirements apply for, among other things, the classification of hazardous substances. The regulation pertains to the initial transport to the locations where the small hazardous waste is processed by professional collectors. At those locations, the ADR regulations must still be adhered to, but they also have the knowledge, facilities, and means to do so.