regulatory services page<\/a>.<\/p>\r\nWaste dealer and waste broker: the difference<\/h2>\r\n
The law distinguishes two activities. A waste dealer is \"a company responsible for buying and selling waste, including companies that do not take physical possession of the waste\" (Article 2(56) of the Law on Waste Management of the Republic of Lithuania (AT\u012e)). A broker is \"a company arranging the recovery or disposal of waste on behalf of others, including companies that do not take physical possession of the waste\" (Article 2(63) AT\u012e).<\/p>\r\n
In practice the difference is this. If you buy and sell waste in your own name, you are a dealer. If you only connect the waste holder with a recovery or disposal operator and arrange the treatment on the holder's behalf, you are a broker. What a company calls itself does not decide its status. What matters is whether you buy and sell waste in your own name (a dealer, Article 2(56) AT\u012e) or arrange its recovery or disposal on someone else's behalf (a broker, Article 2(63) AT\u012e).<\/p>\r\n
In both cases physical possession of the waste is not required. Both are classed as waste managers: \"Waste managers include waste dealers or brokers carrying out the activity referred to\" (Article 2(20) AT\u012e). The definition of waste management also covers cases where the actions are carried out by a waste dealer or broker (Article 2(18) AT\u012e).<\/p>\r\n
The main duties described below \u2014 registration, records and supervision \u2014 are set by the law in the same way for both.<\/p>\r\n
Registration in the Register of Waste Managers<\/h2>\r\n
This is the first and most important duty. Companies \"intending to carry out waste collection, transport, waste treatment, waste dealing, brokering\" must register in the Register of Waste Managers information system (Atliek\u0173 tvarkytoj\u0173 registro informacin\u0117 sistema<\/em>) (Article 4(10) AT\u012e). The law speaks of companies that \"intend\" to carry out the activity, so you need to register before you start.<\/p>\r\nThe exception in the same provision applies only to companies for which waste collection and\/or transport is not a professional activity and which provide a non-hazardous waste collection and\/or transport service to other companies in Lithuania no more than three times per calendar year (Article 4(10) AT\u012e). No such exception is set for dealing or brokering.<\/p>\r\n
Companies carrying out \"waste dealing and\/or brokering\" are also objects of the register (Article 6\u00b9(1)(3) AT\u012e). The controller of the register and its data is the Ministry of Environment (Aplinkos ministerija<\/em>) (Article 6\u00b9(4) AT\u012e). Registration is carried out by the Environmental Protection Agency (Aplinkos apsaugos agent\u016bra<\/em>). The Waste Management Rules (Atliek\u0173 tvarkymo taisykl\u0117s<\/em>), approved by Order No. 217 of the Minister of Environment of 14 July 1999, provide that the activity of a waste dealer and broker may be carried out by a company that meets the requirements of the law and that the Agency has entered in the Register (point 68 of the Waste Management Rules; the Agency is named in point 22). The same Rules confirm that waste dealers and brokers may be companies that do not take physical possession of the waste (point 67 of the Waste Management Rules). Register data are public, except for the personal data specified in the register regulations (Article 6\u00b9(3) AT\u012e). So your partners will be able to check whether you are registered, and you can check them.<\/p>\r\nWhen a pollution permit is needed<\/h2>\r\n
Under the law, a \"permit\" means \"an integrated pollution prevention and control permit or a pollution permit\" (Article 2(46) AT\u012e). Permits must be obtained by companies intending to carry out waste treatment, companies recycling ships, and companies that keep hazardous waste at the place where it was produced for longer than six months, or non-hazardous waste for longer than one year (Article 6(1) AT\u012e).<\/p>\r\n
Waste treatment means \"recovery or disposal operations, including preparation prior to recovery or disposal\" (Article 2(7) AT\u012e). Dealing and brokering without treatment are not on the list in Article 6(1). So a company that does not sort, shred or keep waste at its own yard, and does not otherwise treat it, does not need a permit under this provision.<\/p>\r\n
The position changes when the trading model includes your own yard or warehouse. Storage of waste pending treatment has its own definition and limits (Article 2(10) AT\u012e), and waste must be stored so that it has no negative impact on human health or the environment (Article 8(1) AT\u012e). In our practice, we first look at the site, its designated use, the planned quantities and the types of waste. These decide what level of permit and which other environmental assessments will be needed.<\/p>\r\n
For specific economic activities, the Minister of Environment sets the types and quantities of waste that a company may treat without a permit. Such a right may be set only for the treatment activities listed in the law, for example preliminary treatment of waste (Article 6(2) AT\u012e). This is an exception for treatment, not for trading, and it has to be checked against the specific activity.<\/p>\r\n
Records, documents and checking your partners<\/h2>\r\n
Registration is not the only duty. Waste records are kept, and reports are filed through the Unified Products, Packaging and Waste Accounting Information System (Vieninga gamini\u0173, pakuo\u010di\u0173 ir atliek\u0173 apskaitos informacin\u0117 sistema<\/em>, GPAIS), by, among others, \"waste dealers and brokers\" (Article 7(1)(1) AT\u012e).<\/p>\r\nEvery transfer must be documented. A waste holder that has handed waste over to a waste dealer, broker, recovery or disposal operator must hold a document confirming the transfer (Article 4(9) AT\u012e). The Rules require a written document and give examples: an invoice, a waste handover-acceptance certificate or a waste consignment note, stating the name of the waste, its code under the list of waste, its weight and the date of transfer. This requirement does not apply where the waste holder keeps its records in GPAIS in the cases set in the Rules (point 9 of the Waste Management Rules). When waste is transported within Lithuania, the waste producer or waste manager prepares a waste consignment note (Article 4(8) AT\u012e). A waste holder hands waste over to waste managers that have the right to manage it, under a written contract for its recovery and\/or disposal. Having handed it over, the holder must hold a document confirming the final treatment of the waste. An exception applies to the handover of municipal and other household waste under Article 30\u00b9 AT\u012e (Article 4(1) AT\u012e).<\/p>\r\n
Documents must be kept. Hazardous waste management documents are kept for at least five years, non-hazardous waste management documents for at least three years (Article 9 AT\u012e).<\/p>\r\n
The biggest risk is a partner without the right to manage waste. A contract for the recovery and\/or disposal of waste concluded with persons who do not have the right to manage that waste is void (Article 4(14) AT\u012e). In addition, a person who has no right to treat waste itself and who hands waste over to a dealer, broker, recovery or disposal operator without a lawful document confirming the transfer is deemed to have treated waste without the right to do so (Article 4(13) AT\u012e). So before a deal it is worth checking that the seller, the carrier and the buyer are registered and hold the permits they need.<\/p>\r\n
Waste dealers and brokers are supervised and inspected by state environmental protection control officers (aplinkos apsaugos valstybin\u0117 kontrol\u0117<\/em>) and officers of other authorised institutions (Article 11\u00b9(1) AT\u012e). Persons who breach the requirements of the law are liable as provided by law (Article 35(1) AT\u012e).<\/p>\r\nHazardous waste<\/h2>\r\n
Non-hazardous waste is \"any waste not classified as hazardous waste\" (Article 2(49) AT\u012e). Hazardous waste is waste with one or more hazardous properties listed in EU legislation (Article 2(54) AT\u012e). So it is worth establishing the type of waste under the list of waste before the deal, not after it. When identifying waste, the waste holder must follow the list of waste (Article 7\u00b9(1) AT\u012e). Waste marked with an asterisk (*) in the list is classed as hazardous (point 73 of the Waste Management Rules).<\/p>\r\n
With hazardous waste the requirements grow:<\/p>\r\n
- companies intending to collect and transport hazardous waste must obtain a hazardous waste management licence (Article 12(1) AT\u012e). The licence is issued if the competence of the responsible staff meets the requirements of the law and the company's civil liability is insured (Article 12(4) AT\u012e);<\/li>
- companies collecting, transporting or treating hazardous and\/or tyre waste must insure their civil liability (Article 4\u00b2(1) AT\u012e);<\/li>
- staff responsible for the collection, transport, storage and treatment of hazardous waste must hold a certificate confirming their competence (Article 11\u00b2(2)(2) AT\u012e);<\/li>
- the holder of hazardous waste must identify and declare it (Article 13 AT\u012e);<\/li>
- hazardous waste may not be mixed with other waste or substances, except in the cases set by law, where the mixing is done by a company holding a permit and other conditions are met (Article 14(1) and (2) AT\u012e);<\/li>
- it must be packaged and labelled (Article 15 AT\u012e) and transported under the rules for the carriage of dangerous goods (Article 17 AT\u012e).<\/li><\/ul>\r\n
The licence duty in Article 12 is tied to collection and transport. If the waste is collected and transported by the carrier you engage, the carrier must hold the licence. A waste holder is the waste producer or a person who has the waste (Article 2(17) AT\u012e). If you buy hazardous waste in your own name, assess whether you become its holder; if so, the duty to identify and declare it (Article 13 AT\u012e) applies to you as well. In our practice we assess this against the specific deal structure.<\/p>\r\n
Bio-waste and animal by-products<\/h2>\r\n
Bio-waste has its own definition in the law: biodegradable garden and park waste, food and kitchen waste from households, offices, restaurants, trade and catering premises, and comparable waste from food processing plants. Forestry or agricultural waste, sewage sludge, natural textiles, paper and cardboard, and wood waste are not included (Article 2(24\u00b3) AT\u012e). The handling of bio-waste (other than biodegradable garden and park waste) generated at food business operators, at the place where it arises, is supervised by the State Food and Veterinary Service (Valstybin\u0117 maisto ir veterinarijos tarnyba<\/em>) (Article 24(2) AT\u012e).<\/p>\r\nFor animal by-products covered by the EU Animal By-products Regulation, the Law on Waste Management does not apply to the extent that other legislation implementing EU law, or directly applicable EU law, applies to them (Article 1(3) AT\u012e). The exception is such by-products intended for incineration, landfilling or use in a biogas or composting plant: the law does apply to those (Article 1(3)(2) AT\u012e). So trading in animal by-products has to be assessed separately, by their intended use.<\/p>\r\n
Does it matter who you buy from: businesses or individuals?<\/h2>\r\n
The Law on Waste Management does not link the registration, record-keeping or permit duties to whether you buy waste from companies or from individuals. The duties arise from the activity: dealing, brokering, collection, transport or treatment (Article 4(10) AT\u012e). When scrap metal is bought from individuals, additional payment and reporting requirements under other legislation may apply. This article does not cover them.<\/p>\r\n
When waste crosses a border or the activity takes place in another country<\/h2>\r\n
Transit of waste, its shipment out of Lithuania and its shipment into Lithuania are governed by Lithuanian and EU legislation and international treaties, and compliance is controlled by the institution authorised by the Minister of Environment (Article 4(5) AT\u012e). Since 21 May 2026, Regulation (EU) 2024\/1157 on shipments of waste has applied (Article 86(2) of Regulation (EU) 2024\/1157); some of its provisions have other dates of application (Article 86(3)). It is directly applicable in all EU Member States. From 1 October 2026, Article 4(5) AT\u012e will be aligned with it. It will refer expressly to that Regulation and to the issue of pre-consents (Article 4(5) AT\u012e, as in force from 1 October 2026).<\/p>\r\n
In our practice, if you buy and sell waste in another EU Member State, we recommend checking that country's requirements for dealers and brokers separately. The EU rules are common, but their implementation and local procedures differ between Member States. Registration in Lithuania may not replace registration where the activity actually takes place.<\/p>\r\n
When scrap metal ceases to be waste<\/h2>\r\n
Some scrap metal may cease to be waste if, after recycling or other recovery, the conditions set by law are met: it is to be used for a specific purpose, a market or demand exists for it, it meets the requirements applicable to products, and its use will not harm the environment or health (Article 3\u00b2(1) AT\u012e). Where criteria for particular waste streams are not set in EU legislation, the Minister of Environment may set them (Article 3\u00b2(2) AT\u012e). So for scrap metal, first check whether criteria for that stream are already set in EU legislation, for example in a directly applicable EU regulation. The criteria must also cover the requirements for evidence of compliance and for issuing, keeping and storing the documents that confirm compliance (Article 3\u00b2(3)(4) and (5) AT\u012e). A person who first uses, or first places on the market, a material or object that has ceased to be waste must ensure that it meets the requirements for chemicals and products (Article 3\u00b2(5) AT\u012e).<\/p>\r\n
How to start<\/h2>\r\n
Send us a short description: which waste you plan to buy (waste codes, if you know them), whether you buy in your own name or only broker, who will transport the waste, whether you will have your own yard, and in which countries the deals will take place. We will tell you which registration and permits you need, and prepare the documents.<\/p>\r\n
Phone +370 5 212 1506, email info@linden.lt<\/p>\r\n
More about this service: regulatory services<\/a>.<\/p>"}]},"_links":{"self":[{"href":"https:\/\/linden.lt\/en\/wp-json\/wp\/v2\/irasas\/2269","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/linden.lt\/en\/wp-json\/wp\/v2\/irasas"}],"about":[{"href":"https:\/\/linden.lt\/en\/wp-json\/wp\/v2\/types\/irasas"}],"version-history":[{"count":0,"href":"https:\/\/linden.lt\/en\/wp-json\/wp\/v2\/irasas\/2269\/revisions"}],"wp:attachment":[{"href":"https:\/\/linden.lt\/en\/wp-json\/wp\/v2\/media?parent=2269"}],"wp:term":[{"taxonomy":"kategorija","embeddable":true,"href":"https:\/\/linden.lt\/en\/wp-json\/wp\/v2\/kategorija?post=2269"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}