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"Please send us the disposal certificate": IT departments hear this sentence from purchasing, data protection or the ESG team. But different documents are often meant. This entry explains what a disposal certificate is in waste law, when it is needed for old IT devices and which documents you receive instead.
In brief
In waste law, a disposal certificate is a document prepared in advance showing that hazardous waste is to be properly disposed of in a facility approved for the purpose. The basis is § 50 of the Circular Economy Act (KrWG) and the Verification Ordinance; the certificate is kept electronically via the eANV. In everyday language, any confirmation of completed disposal is also called that; for old IT devices, this confirmation is usually what is meant.
The disposal certificate in waste law
For hazardous waste, § 50 KrWG requires seamless verification. It has two parts:
- Advance control with the disposal certificate: Before disposal begins, waste producer and disposer declare what waste is involved and that the facility may accept it. Depending on the procedure, the authority confirms the certificate, or it is deemed confirmed for certain certified waste management companies.
- Whereabouts control with accompanying documents: Every single removal is documented with an accompanying document that runs from the producer via the carrier to the facility.
Since 2010, this evidence has in principle been kept electronically via the eANV with a qualified electronic signature. For smaller quantities there are simplified procedures such as collective disposal with an acceptance document.
Does this also apply to old IT devices?
Used electrical devices with hazardous components are hazardous waste, for example under the waste code 16 02 13*. The Electrical and Electronic Equipment Act (ElektroG), however, contains an exception: the verification obligations under § 50 (1) KrWG do not apply to the handover of old devices to facilities for collection and initial treatment. The carrier must nevertheless carry certain accompanying documents. If hazardous components such as batteries are removed from old devices, the full verification obligation applies again to them.
The details depend on the disposal route and the federal state. This entry gives an overview and does not replace legal advice.
Which documents you receive for IT disposal
| Document | What it proves | Legal character |
|---|---|---|
| Disposal certificate | Permissibility of the planned disposal of hazardous waste | Obligation under the KrWG and Verification Ordinance, unless an exception applies |
| Accompanying document / acceptance document | Whereabouts of a specific quantity of waste | Obligation in the verification procedure |
| Disposal confirmation or recycling certificate | That certain devices or quantities have been properly recovered | Agreed by contract, important for audit and ESG reporting |
| Erasure or destruction certificate | That the data was erased or destroyed per data carrier | Evidence for data protection, not a waste-law document |
The separation is important: a waste-law certificate says nothing about data, and an erasure certificate says nothing about recovery. What details should appear in erasure and destruction certificates is explained in our guide Certificate of destruction and erasure report.
Rule of thumb: For IT retirement you need two chains of evidence, one for the data and one for the waste.
Disposal certificates at Second IT
Second IT is a certified waste management company under § 56 KrWG and documents disposal in accordance with the Circular Economy Act. Customers receive recycling and disposal certificates for their CSR and ESG reporting, plus erasure certificates per device and certificates of destruction. Audit reports are available in the customer portal. What the certificate of a certified waste management company means is explained in the article Certified waste management company and IT disposal. More on the IT disposal with certification.
Frequently asked questions about the disposal certificate
Do I need a disposal certificate for old laptops?
A disposal certificate within the meaning of the Verification Ordinance is generally not required when handing over to facilities for the collection and initial treatment of waste electrical equipment. For your records, you should nevertheless request a confirmation of proper recovery.
What is the difference between a disposal certificate and a disposal confirmation?
The disposal certificate is a legally regulated document for hazardous waste that is prepared before disposal. The disposal confirmation confirms afterwards that devices or quantities were properly disposed of. It is agreed by contract.
How long do I have to keep disposal documents?
Evidence and registers under the Verification Ordinance generally have to be kept for at least three years. For documents that are also accounting records, the commercial and tax law retention periods additionally apply.
What is an accompanying document in disposal?
An accompanying document records every single removal of hazardous waste. It runs from the waste producer via the carrier to the disposal facility and thus proves the whereabouts. It belongs to the whereabouts control and is in principle kept electronically via the eANV.
Does an erasure certificate replace the disposal certificate?
No. The erasure certificate proves that data was erased or destroyed per data carrier. It is a data protection document and not a waste-law document. For IT retirement you therefore need two chains of evidence, one for the data and one for the waste.
IT disposal with certification, for data protection and ESG reporting.
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