Transfer document – report the information to the SIIRTO register

The use of a transfer document is the responsibility of all parties involved in the transfer.

Obligation of the holder (producer)

According to law, the waste holder, i.e., the waste producer or the party in possession of the waste before the transfer, is responsible for preparing the transfer document. Only households do not have a transfer document obligation, but the waste carrier has the transfer document obligation for waste collected from households.

Read more about the waste holder’s legal obligation:

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

Obligation of the carrier

When a transport company accepts waste requiring a transfer document, the driver is obliged to acknowledge the transfer document and carry it during the transfer. When the waste is collected from a household, it is the responsibility of the carrier to draw up the transfer document. In this case, the carrier is also legally responsible for other transfer document obligations concerning the holder of the waste.

Read more about the waste driver’s legal obligation: 

• Waste driver – take care of the information and acknowledgements in the transfer document

Obligation of the transferee

The waste transferee is obliged to acknowledge the waste as received in the transfer document.

Read more about the waste transferee’s legal obligation:

• The waste transferee acknowledges the transfer document

The transfer document must be drawn up for the transport of the following waste:

• Hazardous waste
  • These waste types are marked with an asterisk in annex 3 to the Waste Decree (978/2021).
  • See the Classification of waste as hazardous waste – updated guide (in Finnish) (Institutional Repository for the Government Valto)
• POP waste containing persistent organic compounds
  • POP is waste containing persistent organic pollutants (POP) above the permitted limit. 
  • POPs can be found in flame retardants, plastic and rubber softeners, insulators, coolants, hydraulic oils, lubricants and certain textiles, parts of end-of-life vehicles and electrical and electronic equipment, and demolition waste (e.g. concrete elements, insulation and coatings containing PCB, SCCP or HBCDD).
  • See the Guide for the identification of POPs waste (in Finnish) (Institutional Repository for the Government Valto)
• Septic tank and cesspool sludge
  • Sludge from domestic waste water formed in a septic tank, cesspool, small-scale treatment plant or other similar treatment system
  • list-of-waste entry 200304.
• Sludge from sand and grease interceptors
  • Sludge from sand and grease interceptors is produced, for example, in the cleaning of street drains and rainwater wells, in restaurants, and the manufacture of food, and list-of-waste entries 020204, 020502, 020603, 190802, 200125, 200303, 200306 are used for it.
• Construction and demolition waste, except uncontaminated soil
  • Waste from the construction, renovation, and demolition of buildings or other fixed structures, civil engineering and other construction and demolition activities. The obligation has been specified further in the Ministry of the Environment’s memorandum on the obligation on transfer documents (15 September 2023, chapter 2) (In Finnish) (ym.fi)
• Contaminated soil
  • Contaminated soil contains harmful substances in concentrations exceeding the lower guideline value of the PIMA Regulation (214/2007).
  • E.g. list-of-waste entries 170503* (hazardous waste) and 170504 (non-hazardous waste).

In matters related to the classification of waste, you can ask your municipality’s environmental protection or waste management authority or the centre for economic development, transport and the environment that supervises your company’s environmental permit.

The responsibility area table of the SIIRTO register shows which municipal environmental protection authority and waste management authority are responsible for your municipality’s waste management matters.

The law determines what information the transfer document must contain. No specific format is required for the transfer document.

As a rule, the transfer document must be in electronic format. If the transfer document is in electronic format, it must also be in machine-readable format. The transfer document must be presentable to the supervisory authority in a readable format during the transport of waste.

The information contained in the transfer document must be submitted to the SIIRTO register in electronic format. The authorities recommend the use of market-based transfer document applications, consignment note applications or ERP systems in which the transfer document data is integrated. The data in the transfer document are usually transferred from the applications to the SIIRTO register directly via the interface.

The electronic transfer document must include the possibility to: 

• enter the required information
• update data 
• confirm the information with a signature
• track data changes (change log) 
• access to the data to all parties involved in the transfer.

The data in the transfer document created in the transfer document application are archived in PDF, for example. The archived PDF transfer document is accessible to all parties involved in the transport.

See also Can I use a paper transfer document?

According to the Waste Decree (978/2021), the following information is entered in the transfer document:

• Identifying data of the waste producer or other waste holder, carrier and transferee: name, business ID or the corresponding foreign identifier and contact details. Contact details include the mailing address, the contact person’s name, telephone number and, if necessary, the e-mail address. When collecting waste from a household, the name and mailing address of the waste holder are sufficient as identification.
• Date and start and end location of the transfer of waste. Visiting address or coordinates and, where possible, building or property identifier.
• List-of-waste entry. The entry set in appendix 3 of the Waste Decree (Waste catalogue, e.g., 130206*) is used and a free-form verbal description of the type of waste is given, e.g., a description of the composition, condition and other essential characteristics.
• Waste amount. Mass or, where information is not available, volume of waste.
• Type of waste. Use the code set in appendix 5 of the Waste Decree, e.g., hazardous waste and POP waste.
• The activity in which the waste was generated. Use the code set in appendix 5 of the Waste Decree, e.g., construction.
• Vehicle registration number, if possible. If the transfer has been carried out using several vehicles, enter the registration numbers of all vehicles used.
• Waste treatment method at the place of delivery. Use the codes “Recovery measures” and “Final disposal measures” in appendices 1 and 2 to the Waste Decree, for example: R 12.2. Describe the treatment in free form, e.g., storage of waste oil before recovery.
• Confirmation by the waste holder that the information provided is correct.
• Confirmation by the waste driver that the waste has been accepted for transport.
• Confirmation by the waste transferee of the receipt of the waste and information on the amount of waste received at the end of the transfer.
• For hazardous waste, the following is reported:
  • Composition of waste: free-form description.
  • Form: use the code sets in appendix 5 of the Waste Decree, e.g., solid.
  • Hazardous properties: use the code set in Annex 4 item III of the Waste Directive, e.g., HP 1 Explosive. For example, the code set can be found on the page Vaaraominaisuudet (koodistot.suomi.fi).
  • Method of packaging and transport of waste. Use the code set in appendix 5 of the Waste Decree, e.g., barrel, surface road.
• For POP waste, the following is reported:
  • Persistent organic compounds in the waste. Use the compounds listed in Annex IV of the POPs Regulation, e.g. endosulfan. The compounds listed in the POPs Regulation and their numerical codes can be found, for example, on the page Pysyvät orgaaniset yhdisteet (koodistot.suomi.fi).
  • Method of packaging and transport of waste.
• For waste oil, the type of waste oil is indicated. Use the code set in appendix 5 of the Waste Decree, e.g., engine and gear box oil waste.
• In addition, for septic tank and cesspool sludge, information of the property holder is provided if the holder is different from the waste producer: name, mailing address, property or building ID and information on the type of sludge tank as described in appendix 5 to the Waste Decree:
  • septic tank or small treatment plant containing washing water only
  • septic tank or small treatment plant containing sewage and washing water
  • cesspool containing sewage and washing water
  • cesspool containing sewage
  • other, please specify

More detailed provisions on the information and its format are laid down in appendix 5 to the Waste Decree: the Waste Decree with up-to-date amendments (978/2021) ) (In Finnish) (Finlex.fi).

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 transfers must also be entered in the SIIRTO register (siirtorekisteri.fi).

The use of the transfer document is supervised by the municipal environmental protection authority and the centre for economic development, transport and the environment. The police also supervise the use of the transfer document in road traffic. The transfer document must be presentable to the supervisory authority in a readable format during the transport of waste.

The waste management authority monitors the fulfilment of waste management obligations, such as drainage and transport of sewage sludge from residential and other properties that are part of municipal waste management.

A negligence fee may be imposed on the waste holder, the carrier or the transferee for neglecting the obligation to provide information in the transfer document or the SIIRTO register.

The waste holder, i.e., the waste producer or the party in possession of the waste before the transfer, provides the information to the SIIRTO register. The information contained in the transfer document for waste collected from households is handled by the carrier.

The waste holder is responsible for ensuring that the transfer document is drawn up for all waste required by law and that the information submitted to the SIIRTO register is correct. The waste holder can purchase the transfer document service from a transport company, for example. Even if the transfer document is prepared by the carrier, the responsibility for ensuring that the information in the transfer document is correct and that it has also been correctly submitted to the register remains with the waste holder.

When collecting waste from households, the waste carrier is responsible for the transfer document and submitting the data to the SIIRTO register. In this case, the carrier is also responsible for ensuring that the information is correct and that all parties have access to the transfer document.

Note! The waste transferee can also get the information to the SIIRTO register, but in this case the matter must be agreed separately with the waste holder or the carrier so that the information does not end up in the register twice.

All information required in section 40 of the Waste Decree (978/2021) for the transfer document is submitted to the SIIRTO register, with the exception of signatures and electronic confirmations.

See above: What information is entered in the transfer document?

Information can be submitted to the SIIRTO register from electronic transfer documents, different applications and ERP systems via an interface. There are several transfer document and consignment note applications on the market, from which the data can be transferred directly to the SIIRTO register.

The electronic transfer document service can often be purchased as part of a waste management service.

If a paper transfer document is used, its 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.

Go to the user interface of the SIIRTO register: siirtorekisteri.fi.

The data of the electronic transfer documents must be sent to the SIIRTO register without delay after the transfer 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 waste holder or carrier must enter the data 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.

Modifying the data in the SIIRTO register requires the mandate “Suomen sisäisten jäte-erien tietojen ilmoittaminen (Reporting information on domestic waste lots)”. 

Copying an old template

In the SIIRTO register, it is possible to copy a previously saved transfer document as a basis for a new document. To copy a document, click the document copy icon at the end of the selected transfer document row.

Data editing

Editing the data requires a mandate to edit the data. Read more under What type of a mandate do I need for the SIIRTO register?

The data stored in the register can be edited for three months after the transfer. The data is edited in the SIIRTO register (siirtorekisteri.fi).

When you click the pen icon at the end of the document row, the document opens for editing.

If corrections are needed to the data of a waste transfer that is more than three months old, or if there is a large amount of data or documents to be corrected, contact SIIRTO register support (siirtorekisteri-tuki@syke.fi).

A company can develop its own interface application using the test version of the SIIRTO register’s electronic interface. Test credentials for the interface can be obtained by contacting siirtorekisteri-tuki@syke.fi.

• The test version of the SIIRTO register’s electronic interface (testbed.ymparisto.fi)

Once the application made by the company is finished, the keys to the actual interface can be obtained by signing an agreement with Syke on the use of the interface.

There are four types of mandates. The mandate names, target groups and descriptions can be checked in the table below.

1. Authorisation: Seeing information on waste shipments within Finland (Suomen sisäisten jäte-erien tietojen katselu)

Target group: The parties to the waste shipment and the persons and operators authorised by them.

With this mandate, the user of the SIIRTO register can see only details of the waste transfers
in which the assignor is involved with their business ID (waste producer, carrier or transferee).

2. Authorisation: Submitting information on waste shipments within Finland (Suomen sisäisten jäte-erien tietojen ilmoittaminen) 

A party to a waste transfer or a person/actor authorised by a party who is responsible for entering the data of a transfer document to the SIIRTO register.

This mandate allows the user of the SIIRTO register to report, edit and view the details of all waste transfers in which the assignor is involved with their business ID (waste producer, carrier or transferee). 

3. Authorisation: Authority supervision of waste shipments within Finland (Suomen sisäisten jäte-erien viranomaisvalvonta) 

Target group: Environmental protection authority

With this mandate, the user of the SIIRTO register, who carries out the tasks of the environmental protection authority, can see the information on waste transfers’ transfer documents throughout the municipalities in their control area. The authorisation is granted by the municipality in charge in the supervision area.

4. Authorisation: Viewing information on internal sedimentation and closed tank sludge batches (Suomen sisäisten saostus- ja umpisäiliöliete-erien katselu)

Target group: Waste management authority    

With this mandate, the user of the SIIRTO register, who carries out the tasks of the waste management authority, can see the details of the transfer documents for septic tank and cesspool sludge transports throughout the municipalities in their control area. The authorisation is granted by the municipality in charge in the supervision area.

The responsibility of environmental protection and waste management authorities can be checked using the “Tarkista vastuukunta (Check responsible municipality)” button on the front page of the SIIRTO register user interface (siirtorekisteri.fi).

5. Authorisation: Powers of a centre for economic development, transport and the environment authority (ELY-keskuksen viranomaisen valtuudet) 

Target group: Centre for economic development, transport and the environment controllers of plants subject to environmental permits

With these mandates, the centre for economic development, transport and the environment’s environmental permit authority can see the information on waste transfers’ transfer documents either in the area of its own centre for economic development, transport and the environment or in the entire Finland. A mandate covering the entire Finland must be granted to a supervisor only if they need such extensive information in their work. With a mandate covering the area of one centre for economic development, transport and the environment, one can see the details of waste transfer documents starting and ending in the supervision area.

In order to be granted a mandate, the supervisor must be associated with the reader access group of the SIIRTO register. Valtori will do the assignment at the request of the centre for economic development, transport and the environment’s environmental protection supervisor. The mandate names are:

• Area of one centre for economic development, transport and the environment: SIIRTOASIAKIRJA_ELY_READER 
• Entire Finland: SIIRTOASIAKIRJA_ELY_WHOLE_FINLAND_READER 

Authorising another person

A person with the authority to sign for a company or organisation may authorise other persons to act on behalf of the organisation. The authorisation is done via suomi.fi authentication. To add a mandate, you need the name and personal identity code of the person to whom the mandate is being granted.

In order for a person to be able to submit information to the SIIRTO register, they need the mandate “Suomen sisäisten jäte-erien tietojen ilmoittaminen (Reporting information on domestic waste lots)”. For viewing information, the mandate “Suomen sisäisten jäte-erien tietojen katselu (Viewing information on domestic waste lots)” is sufficient.

1. Authenticate yourself on the suomi.fi website
2. Select e-Authorizations from the top menu
3. Select Company’s Mandates
4. From the list, select the organisation whose mandates you want to grant to the person
5. Select Grant mandates (top of the list on the left)
6. Mandate type (1/7): Select Mandate for transaction 
    
7. Parties (2/7): Click Add a person to authorise someone from within your organisation
8. Mandate matters (3/7): In the search box, enter Submitting information on waste shipments within Finland or Seeing information on waste shipments within Finland
9. Selected mandate matters (4/7): Select Next
10. Mandate confirmers (5/7): Select Next
11. Validity (6/7): Select the desired period of validity
12. Summary and validation (7/7): Review the details and select Validate

• More information and instructions on granting mandates can be found in the suomi.fi service

Transfer of mandate

A person with the right to grant mandates on behalf of an organisation may grant an employee a mandate and also a right to grant a mandate. An employee with authorisation to grant a mandate may grant mandates to other employees and request mandates for transactions from other organisations or persons.

• For more information on different authorisation types, see the suomi.fi service

Requesting an authorisation

A person or another organisation may also request an e-authorisation from a company, association or organisation, in which case the mandate is issued by accepting the mandate request.

• Making a mandate request as an organisation (suomi.fi)
• Making a mandate request as a person (suomi.fi)

You can check the mandates you have received by logging in to the suomi.fi service.

Select “Personal mandates” as the service role. On the “Received mandates” page, you can see all parties you have received mandates from. When you click an assignor’s name, you can see all the mandates received from the assignor.

If you have the right to authorise others in suomi.fi e-Authorizations based on register data, select “Company's Mandates” as the service role. This allows you to also see the mandates granted to your organisation.

• Instructions for Suomi.fi e-Authorizations – Where can I see received mandates?
• Instructions for Suomi.fi e-Authorizations – Where can I see mandates received by an organisation?

The person managing the tasks of the environmental protection authority does not need mandates to be entered in the SIIRTO register separately from each municipality in their supervision area. Instead, the authorisation granted by the responsible municipality, “Suomen sisäisten jäte-erien viranomaisvalvonta (Supervision of domestic waste lots by the authorities)” is sufficient for viewing the transfer document data of the entire supervision area.

The environmental protection authority does not see the details of the transfer documents in the SIIRTO register if the mandate has been granted by a party other than the responsible municipality.

Authorisation is done on the suomi.fi website, where a person with the right to sign for a municipality can authorise themselves or other persons or organisations to act in the SIIRTO register on behalf of their municipality (so-called mandate for transactions). To add a mandate, you need the name and personal identity code of the person to whom the mandate is being granted.

1. Authenticate yourself on the suomi.fi website
2. Select e-Authorizations from the top menu
3. Select Company’s Mandates
4. From the list, select the organisation (municipality) whose mandates you want to grant to the person
5. Select Grant mandates (top of the list on the left)
6. Mandate type (1/7): Select Mandate for transaction 
7. Parties (2/7): Click Add a person 
8. Mandate matters (3/7): In the search box, enter Authority supervision of waste shipments within Finland and click Seuraava (Next).
9. Selected mandate matters (4/7): Select Next
10. Mandate confirmers (5/7): Select Next
11. Validity (6/7): Select the desired period of validity
12. Summary and validation (7/7): Review the details and select Validate

• More information and instructions on granting mandates can be found in the suomi.fi service

Requesting an authorisation

A person or another organisation may also request an e-authorisation from a company, association or organisation, in which case the mandate is issued by accepting the mandate request.

• Making a mandate request as an organisation (suomi.fi)
• Making a mandate request as a person (suomi.fi)

Delegating an authorisation

A person who has the right to grant mandates on behalf of an organisation may also grant an employee an authorisation to grant a mandate. An employee with authorisation to grant a mandate may grant client representation mandates to other employees and request mandates for transactions from other organisations or persons.

• For more information on different authorisation types, see the suomi.fi service

The person managing the tasks of the waste management authority does not need mandates to be entered in the SIIRTO register separately from each municipality in their supervision area. Instead, the authorisation granted by the responsible municipality, “Suomen sisäisten saostus- ja umpisäiliöliete-erien tietojen katselu (Viewing domestic septic tank and cesspool sludge lots)” is sufficient for viewing the transfer document data of the entire supervision area.

The waste management authority does not see the details of the transfer documents in the SIIRTO register if the mandate has been granted by a party other than the responsible municipality.

Authorisation is done on the suomi.fi website, where a person with the right to sign for a municipality can authorise themselves or other persons or organisations to act in the SIIRTO register on behalf of their municipality (so-called mandate for transactions). To add a mandate, you need the name and personal identity code of the person to whom the mandate is being granted.

1. Authenticate yourself on the suomi.fi website
2. Select e-Authorizations from the top menu
3. Select Company’s Mandates
4. From the list, select the organisation (municipality) whose mandates you want to grant to the person
5. Select Grant mandates (top of the list on the left)
6. Mandate type (1/7): Select Mandate for transaction 
7. Parties (2/7): Click Add a person 
8. Mandate matters (3/7): In the search box, enter Viewing information on internal sedimentation and closed tank sludge batches and click Seuraava (Next).
   9.    Selected mandate matters (4/7): Select Next
   10.    Mandate confirmers (5/7): Select Next
   11.    Validity (6/7): Select the desired period of validity
   12.    Summary and validation (7/7): Review the details and select Validate

• More information and instructions on granting mandates can be found in the suomi.fi service

Requesting an authorisation

A person or another organisation may also request an e-authorisation from a company, association or organisation, in which case the mandate is issued by accepting the mandate request.

• Making a mandate request as an organisation (suomi.fi)
• Making a mandate request as a person (suomi.fi)

Delegating an authorisation

A person who has the right to grant mandates on behalf of an organisation may also grant an employee an authorisation to grant a mandate. An employee with authorisation to grant a mandate may grant client representation mandates to other employees and request mandates for transactions from other organisations or persons.

• For more information on different authorisation types, see the suomi.fi service

A centre for economic development, transport and the environment’s supervisors of plants subject to environmental permits have the right to view the data on waste transfers in the SIIRTO register maintained by the Finnish Environment Institute. In order to use the register, the supervisors of the institutions must be granted the reader access right in the SIIRTO register. Valtori will assign the role if approved by the head of supervision of environmental protection.

1. Supervisors of establishments subject to environment permit will send a message to the head of supervision if they need access to the SIIRTO register in their work.
2. The head of supervision asks Valtori to grant persons who need a mandate to view waste shipments the mandate SIIRTOASIAKIRJA_ELY_READER (if the supervised institutions are located in the area of one centre for economic development, transport and the environment) or the mandate SIIRTOASIAKIRJA_ELY_WHOLE_FINLAND_READER (if the supervision area is all of Finland).

Once the right has been granted, login is done using VIRTU at siirtorekisteri.fi.

If a person’s duties change so that they no longer supervise the above-mentioned institutions, Valtori must be asked to remove the membership of the read access role in the SIIRTO register as a matter of priority.