An entire sector against eSIR

After just one month in operation, the eSIR telematic waste shipment notification system has achieved the dubious honour of uniting the main recycling industry associations against it, due to its lack of processing capacity, its innumerable errors and difficulty of use.


 Ion Olaeta, President of FER, member of the Board of Directors of EuRIC and Vice-president of the European Plastics Recycling Board (EPRB).

Since September 1, operators have been obliged to use the eSIR or the telematic systems of those Autonomous Communities with proprietary systems for shipments of waste subject to the prior notification procedure.

After just a single month in operation, and as we at FER unfortunately predicted some time ago, the recovery sector fears an unprecedented paralysis in activity due to the poor functioning of the mandatory electronic procedures system.

The sector has made this known in a letter to the Ministry for Ecological Transition signed by no less than 20 organisations representing different waste production and management activities. The letter calls on the Secretary of State for the Environment, Hugo Morán, to suspend the eSIR telematic platform temporarily until its operation can be guaranteed.

At FER we receive a multitude of daily complaints from our member companies, pointing out that the platform is not sufficiently operational due to lack of processing capacity, continuous errors and difficulty of use.

All of this makes it impossible to carry out the electronic procedures set out in the legislation, resulting in legal uncertainty and failure to meet the objectives of this legislation.

The concern of waste producers and managers about the current situation is such that we feel that the implementation of eSIR may lead to the paralysis of waste collection, a very serious issue that would have health, environmental and employment consequences.

The letter to the Secretary of State for the Environment also calls for the establishment of an alternative procedure that provides legal certainty when electronic procedures are not possible for reasons beyond the control of users.

The aim of these electronic procedure is to make it possible to trace waste from the point of generation to the point of treatment in order to ensure the most appropriate treatment in accordance with waste type. This is something that the organisations concerned have been supporting and promoting for years, because the digitisation of this process is the cornerstone for achieving a more circular economy. However, the fact is that it is currently not possible to carry out these procedures electronically.

Firstly, because the times needed to complete procedures are excessive. Despite estimates made when this new system was announced that it would take less than five minutes for each document to be processed, it can currently take up to an hour per document. These times are totally unfeasible if we bear in mind that some companies have to process a thousand documents per day. Currently, well under 10% of the required documents are being processed.

Secondly, updating of the database used by the application, the Register of Waste Managers and Producers (RGPR), is currently inefficient and the updating process is the subject of faults and errors. This updating process, which is the responsibility of the Autonomous Communities, should be constant so that all companies in the sector are included in the Register, something that is not happening at present.

Finally, the platform does not currently allow the processing of waste electrical and electronic equipment (WEEE). All of this is generating legal uncertainty because of the failure of the ministry to provide a provisional alternative until problems that are the sole responsibility of the public authorities have been solved.

Waste management moves at the pace of waste production and if storage capacity is exceeded, the situation can result in health and environmental risks. Due to the current electronic procedures scenario, infectious waste could accumulate in healthcare activities and there are also difficulties associated with the storage of fluorescent bulbs, batteries and WEEE due to lack of space in electrical appliance retail outlets. These problems are also occurring in industrial and waste management activities, and at household waste collection centres. This scenario of paralysis could also result in an increase in applications for the implementation of Temporary Job Retention Schemes (furlough schemes).

Faced with this uncertain situation, waste managers are calling for the temporary suspension of the eSIR platform so that the errors identified can be reported in detail, thus enabling the system to become operational again once they have been dealt with. In other words, waste managers are calling for a return to the path of consensus between legislators and operators in the sector.