Waste carrier – take care of the information and acknowledgements 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.

• 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). 

In principle, the data can be collected in a single transfer document. However, the transfer document must contain information on all collection points and an acknowledgement from each waste holder. All pick-up point data must also be submitted to the SIIRTO register.

Most transfer document applications make it possible to copy the previous transfer document as a new template, in which case, for example, the information of the waste carrier river and recipient will be included in the new document. In the SIIRTO register, it is also possible to copy a previously completed transfer document as a basis for a new document.

• SIIRTO register (siirtorekisteri.fi)

Where a transport company drives several loads from the same departure point of the same type of waste (e.g. crushed concrete) to one reception point during the same day, the loads can be collected on a single transfer document.

If the waste is transported by several vehicles, the registration numbers of all vehicles involved in the transport may be entered in the SIIRTO register.

Loads run by different transport companies cannot be combined on the same transfer document.

If the waste shipments continue for several days, a separate transfer document must be drawn up for each day. An exception is a situation where an individual transfer extends to another day.

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)

If a transport company authorises a subcontractor to transport the waste, the details of the subcontractor are entered in the transfer document.

The original transport company is granted the right to view transport data entered in the SIIRTO register by requesting the authorisation “Suomen sisäisten jäte-erien tietojen katselu (Viewing information on domestic waste lots)” from the subcontractor in the suomi.fi service.

When you transport any waste from Finland to another country, from another country to Finland or through the Finnish territory, you need a movement document in accordance with Annex IB or Annex VII to Regulation (EC) No 1013/2006 of the European Parliament and of the Council. It replaces the transfer document referred to in section 121 of the Waste Act.

Information on transfrontier shipments i of waste is not submitted to the SIIRTO register. 

• Read more about transfrontier shipments of waste

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 is acceptable for completing the necessary information and facilitating the transport.

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 law requires the carrier to keep the transfer documents for waste collected from households for three years from the end of the shipment. The SIIRTO register is not enough to be a repository because the register does not contain all the information in the transfer document, such as signatures. The recipient is also responsible for keeping the transfer document.

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 holder and the transferee are responsible for keeping transfer documents for waste other than that collected from a household.

The waste holder (and, in the case of household pick-ups, the waste carrier) must send the data of the electronic transfer documents 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 data completion.

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