Environmental Services

Your environmental obligations. Our permanent support.

ANPM ReportingAFM ReportingDRS Reporting - RetuRO Environmental PermitsWaste AuditEnvironmental OfficerLegislation
01 · ANPM REPORTING

Waste management records

Every company that generates waste is responsible for the entire flow - hazardous or non-hazardous - from generation until the waste ceases to be waste. Records are kept monthly, for each type of waste, and waste is handed over only to authorised operators.

Who it applies toAny company that generates waste, regardless of size or sector.
What the law requiresIdentifying waste streams, classifying them under Decision 2014/955/EU, keeping monthly records for each type and reporting annually in the Integrated Environmental System (SIM) of the National Environmental Protection Agency (ANPM). Records are kept for at least 3 years (12 months for carriers).
Deadline15 March of the year following the reporting year.
Penalties5,000 - 15,000 lei (RON) (individuals) · 40,000 - 60,000 lei (legal entities)

Legal basis: Government Emergency Ordinance (GEO) 92/2021 on the waste regime, as subsequently amended and supplemented, Government Decision 1061/2008 and Government Decision 856/2002, all as subsequently amended and supplemented · Commission Decision 2014/955/EU

What Circulad'OR does
  • We identify and classify the waste streams from your activity
  • We keep the monthly records for each type of waste
  • We file the annual report in SIM, on time
  • We prepare the file for any inspection by the Environmental Guard (Romania's environmental inspectorate)
Talk to a consultant
02 · AFM REPORTING

Declarations to the Environmental Fund

The Environmental Fund is financed from the contributions and taxes paid by economic operators. Anyone who produces or places packaging, batteries or electrical equipment (EEE) on the Romanian market declares to the Environmental Fund Administration (AFM) - monthly, quarterly or annually, depending on the type of obligation.

Who it applies toProducers and anyone placing packaging, batteries or EEE on the market - including importers and online retail.
What the law requiresDeclarations by material category, reconciled with the actual quantities placed on the market; payment of contributions for unmet recovery targets; display of the eco-tax at the point of sale.
DeadlineThe 25th of the month, for the previous month.
Penalties1,000 - 5,000 lei (RON) for late filing · 2,000 - 2,500 lei for not displaying the eco-tax

Legal basis: Government Emergency Ordinance (GEO) 196/2005 on the Environmental Fund, as subsequently amended and supplemented, and the implementing orders in force

What Circulad'OR does
  • We prepare and file the monthly AFM declarations
  • We reconcile the declarations with your actual packaging portfolio - this is where most money is lost
  • We track recovery targets and the contributions due
  • We represent you during AFM inspections
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03 · DRS REPORTING - RETURO

The Deposit Return System (DRS)

Through the DRS, operators who place products in DRS packaging (beverages, 0.1-3 L) on the market fulfil their responsibility for the take-back, transport and recycling of that packaging. The system is run by RetuRO Sistem Garanție Returnare S.A. across the whole of Romania.

Who it applies toProducers who place products in DRS-marked packaging on the market, and retailers who sell them to end consumers.
What the law requiresRegistration in the system, monthly reporting on the RetuRO portal (portal.returosgr.ro), payment of the administration and handling fees, reconciliation with your packaging portfolio.
DeadlineMonthly reporting, on the RetuRO platform.
Penalties20,000 - 40,000 lei (RON) for legal entities

Legal basis: Government Decision 1074/2021, as subsequently amended and supplemented (including Government Decision 1075/2023) · Law 249/2015, Art. 16 para. (1), as subsequently amended and supplemented

What Circulad'OR does
  • Monthly DRS consultancy: the reports on the RetuRO portal, on time
  • A strategy for managing the DRS packaging in your portfolio
  • Implementation training for your team
  • Support for purchasing and maintaining reverse vending machines (RVM)
  • We clarify the administration and handling fees - where the calculation most often goes wrong
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04 · ENVIRONMENTAL PERMITS

The permit that allows you to operate

The administrative act issued by the environmental authority that sets the operating conditions and parameters for activities with a significant environmental impact - mandatory BEFORE the activity starts, then to be maintained and revised.

Who it applies toExisting or new activities with a potentially significant environmental impact (the list set out in the legislation).
What the law requiresA complete file: application, presentation sheet and declaration, proof of the public notice, site plan and zoning plan, inspection report, registration sheet - then the on-site check by the county environmental agency (APM), which compares the file with reality.
DeadlineIssue: 90 working days, if the file matches reality and no objections are raised.
Penalties30,000 - 60,000 lei (RON) for operating without an environmental permit

Legal basis: Government Emergency Ordinance (GEO) 195/2005 on environmental protection, as subsequently amended and supplemented, and the permitting procedures in force

What Circulad'OR does
  • We prepare the complete file, in the form the APM accepts
  • We accompany you during the on-site check - the file and reality must tell the same story
  • We track the issue deadline and respond to requests for additional information
  • We maintain and revise the permit when your activity changes
Talk to a consultant
05 · WASTE AUDIT

The waste audit and the prevention programme

A systematic, documented, periodic and objective assessment of how the organisation manages its waste. It is not optional: on the basis of it, the law requires a prevention and reduction programme - with objectives, deadlines and indicators, not just findings.

Who it applies toAny legal entity carrying out commercial or industrial activities.
What the law requiresAn audit in 5 stages (planning and scoping, information gathering, analysis of waste in its operational context, site assessment, data analysis) + the resulting prevention programme: types of waste, reduction strategies, reuse/recovery targets, timeline and monitoring indicators.
DeadlinePeriodic - the audit is repeated and the programme is updated.
Penalties40,000 - 60,000 lei (RON) for the absence of the audit / programme

Legal basis: Government Emergency Ordinance (GEO) 92/2021 on the waste regime, as subsequently amended and supplemented

What Circulad'OR does
  • We carry out the complete audit, across all 5 stages
  • We write the prevention and reduction programme - with targets and a timeline, ready to present to the authority
  • We find the savings in the audit too: disposal costs that can become recovery revenue
  • We monitor the indicators and update the programme periodically
Talk to a consultant
06 · ENVIRONMENTAL OFFICER

Environmental officer - Outsourced

The specialist who knows the environmental legislation in force and keeps the organisation compliant - before the Environmental Guard, the AFM or the local police find otherwise. With us, the role is outsourced: the expertise of a whole team, at a fraction of the cost of a dedicated employee.

What the role coversCompliance with environmental legislation · management of regulatory acts · records, reports and declarations · monitoring programmes · waste documentation · staff training · prevention plans · internal audits and non-conformities · representation before the authorities.
Who inspectsThe Environmental Guard (Romania's environmental inspectorate), the Environmental Fund Administration, the environmental departments of the local police.
Why outsourcedLegislation changes often; one person alone cannot keep up with everything. Our team does it every day, for dozens of clients.
What Circulad'OR does
  • We take over the company's environmental officer role in full
  • We keep the calendar of obligations - nothing expires unnoticed
  • We train staff and prepare the organisation for inspections
  • We represent you before the environmental authorities
Talk to a consultant
07 · NATIONAL ENVIRONMENTAL LEGISLATION

The legislation guide, written for the people who apply it

We maintain an up-to-date guide to the environmental obligations in national legislation - what has changed, who it concerns and from when it applies. No official-gazette language: explained for the people who have to comply, not for lawyers.

Legislative news appears on the Blog →

Not sure which obligations apply to you?

The first conversation is free and ends with a concrete answer: which of the above applies to you, by when, and who does it - you, us, or the application.

Call 031 9303 office@circulador.ro