The situation
The waste streams of two metalworking plants
A metalworking group machines gear housings in Steyr and at a newer plant in Žilina. Between them they produce steel swarf, used cutting emulsion, oily rags, paint-shop sludge and wooden pallets. An inspection in Žilina asked for waste records the plant could not fully produce, and the group EHS lead now wants one memo covering both sites.
The EU framework is shared, but the duties that matter on site are national: how each stream is classified, which are hazardous, what records are kept, who may collect them and what goes to the authority. The hours go on mapping five streams against two national waste acts.
What the research has to settle
The rules behind the answer
- The holder stays responsible
- Under the Waste Framework Directive, a waste producer or holder must treat its waste itself or hand it to an authorised collector or treatment operator. National law decides how far responsibility passes on handover, so the collector’s authorisation is checked before anything leaves the site.
- Hazardous waste is classified and kept apart
- Waste is classified using the European List of Waste, and some entries are hazardous depending on what the waste contains. Hazardous waste may not be mixed with other waste, must be packaged and labelled, and its movements are recorded.
- Scrap can stop being waste
- Iron, steel and aluminium scrap can cease to be waste once it meets the EU end-of-waste criteria, and some materials can qualify as by-products from the start. Both depend on conditions that someone has to evidence.
- Records and reports are national
- Both countries require records of waste produced and handed over, and reports or notifications to the authorities. Austrian law also ties a waste-management concept and a waste officer to the size of the establishment. The research confirms the thresholds and formats.
How it runs in azta
From the question to the document
The question, as you would type it
Metalworking plants in Austria and Slovakia. Waste streams: steel swarf, used water-mixed cutting emulsion, oily rags, paint sludge, wooden pallets. For each stream, how is it classified, is it hazardous, and what storage, handover, record and reporting duties apply in each country? When does swarf stop being waste?
You start with
The waste streams of two metalworking plants
- 01
Upload the waste register and contracts
Add the current register and the collectors’ contracts. azta reads them and points to the entries it relies on.
File upload· Pro - 02
Research each stream
Ask about classification, storage, handover and records for each stream. azta cites the Waste Framework Directive and the Austrian and Slovak waste acts.
Cited research· Free - 03
Read the provisions
Open each cited provision in the reader, in German or Slovak, and check the version in force for the period the inspection covered.
Atlas statute reader - 04
Draft the memo
Ask for a memo with a table per plant: stream, classification, duties and owner. Edit it in Canvas.
Canvas · Ask azta· Pro You send
A memo on the waste holder’s duties for each stream and each plant
What you get
A memo on the waste holder’s duties for each stream and each plant
Waste memo · draft
Waste-holder duties, Steyr and Žilina
Used cutting emulsion and oily rags. Both fall under hazardous entries of the European List of Waste. They are stored separately in labelled containers and handed only to collectors authorised for hazardous waste. Each handover is documented, and the documents are kept with the waste records.
Steel swarf. Sold to a scrap processor, the swarf remains waste until it meets the end-of-waste criteria at the processor. Our records therefore treat it as waste when it leaves the site, and the processor’s authorisation is kept on file.
Žilina. The records must show each stream, quantity and recipient for the period, and any reports to the authority are prepared from them. The gaps found at the inspection concern the months before the current collector contract; the EHS lead will reconstruct them from the collector’s handover documents.
Outcomes on your numbers
What azta is worth on this task
Pro pays for itself after
20 minutes a month
At €85 an hour, that is all the time Pro (€27 a month) has to take off your desk to cover its price.
Example figures. Replace them with your own.
- Hours back a year
- 22
- Capacity at your rate
- €1,836
- More waste-duty memos a quarter
- 0.8
- Return on Pro
- 5.7×
- Research
- Drafting
- Your review
A scenario you set, not a promise. The hours that come back go to another client, or deeper into this one.
Want these numbers on your team’s real workload?
Book a demoWhat stays with you
- The sampling and analysis that decide whether a waste is hazardous.
- Permits and environmental-authority guidance, which azta does not hold for most countries.
- Choosing and auditing the collectors.
Frequently asked questions
- Does azta classify our waste?
- It sets out the classification rules and the candidate entries with the reasons. Where the entry depends on what the waste contains, the analysis and the decision stay with you.
- Does it cover shipping waste to another country?
- Yes. Describe the shipment and azta researches the EU waste shipment rules and the national provisions.
- Does it hold environmental-authority guidance?
- For most countries it holds the legislation and EU law, not authority guidance. The answer shows what it cites, so you can see what still needs checking.



