Waste tracking notes: what documents to hand over business WEEE?
To hand over business WEEE in France in compliance with the rules, you must be able to prove who you gave it to, when, in what quantity and for what treatment. In practice: a waste tracking note (BSD) on Trackdéchets when the equipment contains hazardous components, an entry in your chronological waste register, the treatment facility's proof of handover and, for storage media, a data erasure certificate. Here is how to gather these documents without fuss.
Why does WEEE traceability concern you?
Because your responsibility does not end at the loading bay. Under Article L541-2 of the French Environmental Code, every producer or holder of waste remains responsible for its management until its final disposal or recovery, even when it is handed to a third party. The same article requires them to make sure that the person receiving the waste is authorised to take charge of it.
In practice, traceability documents serve three purposes:
- proving that your equipment went to an authorised outlet, in the event of an inspection by the classified installations authority;
- feeding your CSR reporting (tonnages, share of reuse) and internal audits;
- protecting the company on personal data, when hard drives or SSDs are part of the batch.
Do you need a BSD to hand over WEEE?
It all depends on how your equipment is classified. The French waste list (Annex II to Article R541-8 of the Environmental Code, which mirrors the European List of Waste) distinguishes:
| Waste code | Description | Hazardous? | BSD required? |
|---|---|---|---|
| 16 02 13* | Discarded equipment containing hazardous components | Yes | Yes, on Trackdéchets |
| 16 02 14 | Other discarded equipment | No | No |
| 16 02 15* | Hazardous components removed from discarded equipment | Yes | Yes, on Trackdéchets |
| 16 02 16 | Other components removed from discarded equipment | No | No |
| 20 01 35* | Discarded EEE containing hazardous components (municipal-type waste) | Yes | Yes, on Trackdéchets |
| 20 01 36 | Other discarded EEE (municipal-type waste) | No | No |
The asterisk marks hazardous waste. Since 1 January 2022, tracking notes for hazardous waste must be issued electronically on the public Trackdéchets platform, according to the French Ministry for the Ecological Transition.
How a batch is classified depends on the components it contains. Annex VII of Directive 2012/19/EU lists, among the components to be removed from WEEE, capacitors containing PCBs, components containing mercury and cathode ray tubes. A fleet of PCs, servers and circuit boards is therefore not classified in the same way as a batch that includes old CRT monitors. If in doubt, describe your batch precisely in your request: the applicable code is determined with the treatment facility.
What must your waste register contain?
The BSD does not replace the register. Article R541-43 of the Environmental Code requires producers and shippers of waste, as well as collectors, carriers and treatment facilities, to keep a chronological register. Its content is set by the Order of 31 May 2021, in force since 1 January 2022. For outgoing WEEE, each entry records in particular:
- the date of removal or shipment;
- the name and nature of the waste;
- the quantity;
- the origin of the waste;
- the destination and intended treatment (preparation for reuse, recycling, recovery);
- the type of transport.
The facility's purchase note gives you the weight, date and recipient to record. For hazardous waste, the Trackdéchets BSD complements the register. Also recording the waste code (for example 16 02 14) makes inspections easier and helps match your register to the facility's documents.
What documents should you ask the facility that takes your WEEE for?
| Document | What it proves | At RECYNEW |
|---|---|---|
| Detailed purchase note | Weight, categories and price of each line; serves as proof of the transaction | Always, approved online |
| Proof of handover (BSD) | Delivery of the WEEE to an authorised treatment facility | On request, to be stated in your request |
| Data erasure certificate | Secure treatment of hard drives and SSDs | On request |
| Invoice | The sale, for your accounts | Optional: you invoice RECYNEW or the purchase note is enough |
| Proof of the facility's certification | Treatment to a recognised standard | RECYNEW is WEEELABEX-certified (R2 v3 in progress) |
An often-overlooked point: a buyback changes nothing about your traceability obligations. Whether your WEEE is paid for (as at 15/11/2026, for example, €0.70/kg for a complete server and €0.50/kg for a complete computer) or you are charged for its collection, it remains waste until it is treated.
What about hard drives and GDPR?
Waste traceability does not cover data. If your batch contains hard drives, SSDs or servers, you must also be able to show that the data was erased or the media destroyed. At RECYNEW, reusable media are securely wiped and the rest are physically destroyed; a data erasure certificate can be provided to businesses on request. Details are in our article on data security and computer recycling.
How do you prepare a well-documented WEEE handover?
- Inventory the batch: types of equipment, number, estimated weight, presence of screens, batteries or storage media.
- Identify the likely waste code and, if it is hazardous, check that your site is registered on Trackdéchets.
- State your needs in your buyback request: BSD, data erasure certificate, invoice.
- File the purchase note, proofs and certificate with the matching entry in your register.
For the general legal framework, see also our article on companies' legal obligations for their WEEE, and the FAQ for how a buyback works.
In short
- You remain responsible for your WEEE until its final treatment (Article L541-2 of the French Environmental Code).
- A BSD on Trackdéchets has been mandatory since 1 January 2022 for hazardous WEEE (codes 16 02 13*, 16 02 15*, 20 01 35*).
- A chronological waste register in all cases, with content set by the Order of 31 May 2021.
- Ask the facility for: purchase note, proof of handover, data erasure certificate.
- A buyback does not exempt you from traceability: your WEEE remains waste until it is treated.