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Merck Retrologistik® - Merck-Disposal-Service

Merck Retrologistik®

FAQs – Chemical waste disposal

Frequently Asked Questions

  1. I have chemical waste but no information about legal EU requirements.
  2. I have chemical waste and I need information about disposal possibilities.
  3. I have waste packages and need information about disposal possibilities.
  4. Is it possible that Merck takes back used products or collected waste?

1. I have chemical waste but no information about legal EU requirements.

The basic definitions of wastes have been published by the EU in guidelines No. 75/442/EEC (waste in general), and 91/689/EEC (hazardous waste), of which the complete texts can be found on the following web sites: 75/442/EEC and 91/689/EEC

Key contents of these regulations are:

  • All types of waste (not only chemical ones) have been compiled and classified in the European Waste Catalogue. This catalogue is valid and compulsory in all EU member states. Without this classification (expressed by 6-digit numbers), no waste disposal or recovery procedure is possible within the EU.
  • Waste should preferably be reused I recycled I recovered instead of being disposed. 
  • Disposal procedures should be applied only when the recycling / recovery processes are technically not practicable or unsafe or more expensive than a legally correct disposal.  
  • All procedures with waste (reclamation as well as disposal) have to be performed in a manner which is safe for mankind and environment. This is not described in detail, so realisation underlies national laws, which may lead to individual variations within the EU.
  • Each treatment of a waste stream in a recovery I disposal facility has to be permitted by the authorities beforehand. This also applies for the transport of this waste from the waste producer to the recovery I disposal facility.
  • Any waste transport has to be documented. The extent of documentation depends on the waste classification (hazardous or not; defined in the catalogue mentioned above). Details of this administrative procedure vary from state to state.

Please check also your domestic regulations!


2. I have chemical waste and I need information about disposal possibilities.

If some of your wastes are originally packed perhaps you can find another lab that needs the chemicals. Possibly some chemicals can be recycled by an industrial company (e. g. metals,) or the energy of burning the chemicals can be used. To dispose of your chemical waste you can turn to a local disposal company that has an incineration kiln. The second possibility is to give the chemical waste, that isn't soluble in water,  to a special landfill. Please ask if the disposal company is allowed to take your wastes back.

Recommendations for starting a disposal procedure (based on German requirements):

In order to obtain a permit for the disposal procedure of a certain waste stream, which includes waste recovery as well as the final disposal.

  1. Please determines which procedure to apply, and with which partner(s) to cooperate (this considers both  type of waste and the handling procedure).
  2. Please then contact the authorities for permission to apply this procedure. This permission is necessary for any transportation of waste.
  3. In any application (form), please determines (among other items)
    • the origin and composition of the waste (in detail)
    • the name of the intended disposal company
    • the estimated amount of waste per year. This limit must not be exceeded). The maximum expiry time of such a permit is 5 years, the planned amount for each year must be listed.  
    • the exact disposal procedure.
  4. Please integrate the disposal company into the process: permission for treatment, logistic conditions etc.
  5. It is only after you have received the authorities' consent that the waste can be transported to the disposal company.
  6. Further legal requirements linked with the safety of waste transportation (e.g. ADR) include classification, accompanying documents, and suitable containers as well as vans and drivers (regardless who transports) etc.

3. I have waste packages and need information about disposal possibilities.

Merck KGaA and VWR International GmbH (Deutschland) are classified as self-disposal companies and with the Retrologistik® system give their customers the opportunity to return product-packaging materials from Merck or VWR for recycling.

The person or company removing products from packaging materials is under no obligation to return the packaging materials, i.e. the return of such materials is entirely voluntary for our customers.

If you wish to return reusable containers for which you have paid a deposit, please contact your sales partner.

Please also see EU guideline: Directive on packaging 94/62/EEC

Within the European Union (EU), Merck or the manufacturer takes back empty vessels and packaging. Furthermore empty vessels and packaging can be disposed via a special collection system (Retrologistik). Please check  your domestic regulations and contact your nearest Merck agency.

Please send back returnable drums (e.g. cans and vessels) to the manufacturer.

Before returning them, cans and vessels have to be completely empty and closed tightly.

As cans and drums normally cannot be emptied drip-free, please declare the transport as shipment for dangerous goods. Make sure the drums are marked with the appropriate labels for product and dangerous goods!


4. Is it possible that Merck takes back used products or collected waste?

  • Waste recovery and/or disposal should be executed – wherever possible – within the individual producing state ("environmental autarky"), unless another EU member state can provide better handling conditions.
  • In cases where the waste will be transported cross borders to another state, a very detailed procedure of permission and surveillance is required (see EU regulation  EC/1013/06). A regulation is a legal device which must be  adopted in all member states without any adaptation or modification. This procedure is also valid for the importation of waste into and for the exportation out of the EU.

This regulation prescribes in detail all things we have to do and not to do. It is also valid for countries which are not EU-members.

The system of transfrontier shipment of waste looks complicated at a first glance but is not if you are a bit familiar with it.

The export licences are regulated and covered by the EU regulation. We have to use a so-called notification procedure. Here, all authorities are involved which are touched by the transport: in the exporter's country, in the importer's country (Germany) and in all transit countries. All these authorities have to be contacted and have to agree.

The agreed notification is valid for 1 year and must then be renewed with the full procedure.

If you decide to do the notification yourself we will send you informations and copies how to do  the notification.

The transport costs depend on the weight and the distance, the fees mainly on the weight (the order of magnitude is about 400€  for the fees).

© Merck KGaA, Darmstadt, Germany, 2014


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