Waste holder – prepare a transfer document for the transport of these wastes

In the law, waste holder refers to a waste producer, property holder or other party that has control over the waste before it is transported. The definition is case-specific.

For example, on construction or demolition sites, either the main contractor or the orderer of a construction or demolition project is usually regarded as the holder. In most cases, the main contractor is responsible for the transfer document obligation. The contract between the contractor and the main contractor or the general terms and conditions of the construction contract (YSE 1998) usually lays down provisions on the responsibility for arranging waste management.

If household waste is picked up by a transport company, the driver is responsible for the transfer document the same way as the holder of the waste. If the household transports the waste to the reception point itself, the transfer of the waste is not subject to the transfer document obligation.

• YSE 1998 (rakennustieto.fi) (in Finnish)

The waste holder must draw up a transfer document or ensure that the transfer document is drawn up.

Many companies provide waste producers with a transfer document service. The holder may agree, for example, that the transport company or consultant prepares the transfer document and handles the transfer document process on its behalf. Archiving of the transfer document may also be agreed upon.

Even if the transfer document were to be prepared by the carrier, the responsibility for ensuring that the information in the transfer document is correct and that it has been correctly submitted to the register remains with the waste holder. The same applies regarding the responsibility for archiving transfer documents. The details of the original waste holder are also always entered in the transfer document.

The law allows the use of a paper transfer document if there are no conditions for drawing up an electronic document. Such situations may include non-functional electronic systems and emergency or exceptional situations.

In addition, small-scale activities where waste transported away is rarely generated can be an exception. It is therefore possible to use a paper transfer document if the procurement of an electronic transfer document service would result in unreasonable costs in relation to the transport volume.

Data on these transfer documents must also be entered in the SIIRTO register (siirtorekisteri.fi).

The parties to the waste transfer (holder, carrier, transferee) must sign the electronic transfer document by electronic signature, electronic stamp or other reliable electronic authentication method.

The transfer document must include as detailed information as possible on the amount of waste before the transfer begins. The information can be specified further after weighing at the reception of waste.

Data submitted to the SIIRTO register shall always be based on measuring. The amount of waste must be marked primarily in tonnes (t), but kilograms (kg) can also be used for a small lot. If the weight is not known, the quantity can be marked as volume (m3).

The property or building identifier can be determined using the National Land Survey’s map interface, for example:

• National Land Survey of Finland: How to find out the property identifier

There are also affordable mobile map applications that can be used to search for a property ID.

The waste treatment method is entered in the transfer document using the codes “Recovery measures” and “Final treatment measures” contained in appendices 1 and 2 of the Waste Decree (978/2021) and by describing the treatment in free form.

If necessary, you can ask the recipient of the waste about the treatment method. The transfer document must include the best information on the treatment method before the start of transport. The information can be updated when the final treatment method is confirmed.

• Government Decree on Waste (978/2021) (Finlex.fi)

Saving the data in the SIIRTO register is only possible if all the information marked as mandatory has been provided, so the data cannot be submitted to the register as incomplete. The information in the transfer document can be updated after the completion of the transport once the transferee has indicated the amount of waste and the treatment method.

The data of the electronic transfer documents must be sent to the SIIRTO register without delay after the transport has ended. A delay of a few days in completing the necessary information is acceptable.

The information in the paper transfer document must be submitted to the SIIRTO register within three months of the end of the transfer.

The data entered in the SIIRTO register can be edited through the user interface of the register (siirtorekisteri.fi) for three months after the transfer has ended.

The waste holder is obliged to keep the transfer document or a copy of it for three years from the end of the shipment. The SIIRTO register is not enough to be a document repository because the register does not contain all the information in the transfer document, such as signatures.

The holder or transferee of the waste may also agree on the storage of the transfer documents, for example with the transport company.

If the company’s records referred to in section 118 of the Waste Act are based on transfer documents, the transfer documents must be kept for at least 6 years. 

The data of the electronic transfer documents must be sent to the SIIRTO register without delay after the transport has ended. A delay of a few days is acceptable if the delay is due to supplementing the data or, for example, a technical failure in the information systems.

If a paper transfer document is used, the data must be entered in the register via the user interface as soon as possible and no later than within three months of the end of the transfer.

The data entered in the SIIRTO register can be edited through the user interface of the register (siirtorekisteri.fi) for three months after the transfer has ended.

For more information about the SIIRTO register and how to use it, see:

• Transfer document – report the information to the SIIRTO register

If the recipient is a private person, check the box “The recipient of the waste is a private person” in the SIIRTO register, in which case no business ID needs to be entered.

If the waste is transported to a private person who has an authority’s approval to use the waste in earthworks (registration in accordance with the MARA decree 843/2017), the target ID in the MARA notification is marked in the SIIRTO register in the field reserved for it.

For more information about the SIIRTO register and how to use it, see:

• Transfer document – report the information to the SIIRTO register