Reporting obligation – Which facilities submit data according to the obligations of E-PRTR Regulation

In accordance with the E-PRTR Regulation, a facility has to submit data if it fulfills the following two criteria:

  1. 1. the facility undertakes one or more economic activities listed in Annex I of the E-PRTR Regulation.
  2. 2. the capacity of the facility exceeds the applicable E-PRTR capacity threshold set out in Annex I of the E-PRTR Regulation.

Based on the above two criteria, it is determined whether a facility falls under the provisions of the E-PRTR Regulation or not. Given that the above criteria 1 and 2 are fulfilled, the operator of a facility is obliged to submit to the Competent Authorities the pollutant releases to air, water and land as well as off-site transfers of waste and of pollutants in waste water for verification and validation purposes. The obligation of the operator of a facility to submit relevant annual data is included in the Terms and Conditions set out in the Air Emission Permits and Waste Discharge Permits.

The Competent Authorities report the above data of a specific facility to the European Commission and the European Environment Agency, if the following conditions are fulfilled:

  1. 1. Releases to air, water and land as well as off-site transfers of pollutants in waste water of any of the 91 pollutants for which the applicable threshold value specified in Annex II of the E-PRTR Regulation is exceeded.
  2. 2. Off-site transfers of hazardous waste exceed 2 tonnes per year or of non hazardous waste exceed 2.000 tonnes per year