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Permitra • Germany • hazardous waste
Hazardous waste transport in Germany – the §54 KrWG permit
Have you been offered a load of waste with an asterisked code going to, from or through Germany? We explain when a carrier needs a permit under §54 KrWG, what the German authority assesses, which exceptions exist and how the permit differs from ADR and from notification of the shipment.
- Kreislaufwirtschaftsgesetz (KrWG)
- Anzeige- und Erlaubnisverordnung (AbfAEV)
The short answer
Hazardous waste in Germany means a permit, not a notification
Anyone who transports hazardous waste commercially in Germany needs a permit under §54 KrWG. A notification under §53 KrWG covers only non-hazardous waste. The requirement also applies to companies based outside Germany and to activities carried out in Germany as part of a cross-border shipment, including transit.
A waste carrier registration or permit from your home country, for example in Ireland or the UK, is not a German §54 permit.
Before you accept the job
Three separate questions
- Carrier: a §54 permit or an exception.
- Load: whether the waste is dangerous goods within the meaning of ADR.
- Shipment: notification and consents for the transboundary movement.
When a §54 KrWG permit is required
A permit is required for businesses that collect, transport, deal in or broker hazardous waste (§54(1) KrWG). Whether waste is hazardous is determined by the German waste list ordinance (AVV): a code marked with an asterisk generally denotes hazardous waste.
| Aspect | §53 KrWG – notification | §54 KrWG – permit |
|---|---|---|
| Waste | Non-hazardous | Hazardous |
| Nature | Notification of the activity; the authority confirms receipt | Decision by the authority before the activity starts |
| Relationship | Not required if the company holds a §54 permit (§53(1)) | Also covers transport of non-hazardous waste |
| Authority for a foreign company | The authority of the federal state (Land) in which the activity is first carried out in Germany (§7(2) and §9(2) AbfAEV) | |
| Territorial scope | The whole of Germany (§54(1) KrWG) | |
The rules on notifications and permits also cover activities carried out on German territory as part of a cross-border shipment of waste (§1(2) AbfAEV). The absence of loading or unloading in Germany therefore does not remove the requirement. The authority may attach conditions to the permit (§54(2) KrWG), so what matters is not only the document itself but also its scope.
What the German authority assesses
A §54 permit is not a formality. The authority grants it if the company demonstrates two things: the reliability and the professional competence of the persons who manage and supervise the activity (§54(1) KrWG). The details are set out in the AbfAEV.
Reliability
The owner and the persons in charge are assessed. As a rule, reliability is lacking if, in the five years before the application, any of them received a fine of more than €2,500 or was convicted of, among other things, an infringement of waste, environmental protection, transport or dangerous goods law.
Competence of managers
The person responsible for management and supervision must have practical experience in the activity concerned and must have completed a course recognised by the authority. They refresh their knowledge on recognised courses at least once every three years and provide proof of this on their own initiative.
Staff knowledge
Other staff, including drivers, must be trained within the company according to an induction plan and know the current rules for their work. The authority may request a written plan.
The application is made on the official form to the competent authority of the federal state (§9 AbfAEV). For companies from Ireland, the UK and other countries, this means proceedings conducted in German, with documents from the home country and from Germany.
Exceptions to the permit requirement
Not everyone carrying hazardous waste in a vehicle needs a §54 permit. The exceptions are narrow, however, and must be demonstrated.
Entsorgungsfachbetrieb
A certified “specialist waste management company” (§56 KrWG) is exempt only for its certified activities. It must still notify its activity under §53 and enclose the certificate (§7(1) AbfAEV).
Incidental activity
The exemption covers businesses that transport waste in the course of a different, main business activity. A transport company providing waste transport services to customers does not fall within this exception.
Other cases
Take-back of waste by producers and distributors, handover of end-of-life vehicles, EMAS-registered organisations in certain classes of activity, maritime transport, and parcel and courier services that comply with the rules on dangerous goods.
Despite an exception under §12, the authority may order that a permit procedure be carried out if the public interest so requires (§12(2) AbfAEV).
§54, ADR and notification are three different matters
ADR
“Hazardous waste” is a concept of waste law. ADR classifies dangerous goods according to its own criteria. An asterisked code does not automatically mean a UN number or ADR obligations. A §54 permit does not replace ADR, and a driver’s ADR certificate does not replace the permit.
Notification and DIWASS
The §54 permit concerns the carrier. Shipping hazardous waste between countries generally requires prior written notification and consent (Regulation (EU) 2024/1157). Since 21 May 2026 this procedure has been handled in the DIWASS system.
A vehicle carrying waste in Germany must also display “A” plates (§55 KrWG), and a copy of the permit must be carried in the cab (§13(2) AbfAEV), even if the waste on a given journey is non-hazardous.
Inspections and penalties
Hazardous waste without §54
The company has only a §53 notification or no German authorisation at all, and the load has a hazardous waste code.
Consequence: a fine of up to €100,000 (§69(1) no. 7 and §69(3) KrWG).
Who imposes the fine
For companies without a registered office or branch in Germany, in road transport, proceedings are conducted by the Federal Office for Logistics and Mobility (BALM).
Legal basis: §69(4) KrWG.
The amount stated is an upper limit; the authority sets the actual fine. A fine of more than €2,500 may also call into question the reliability of the company and its managers in a later application (§3(2) AbfAEV).
Open questions to be resolved for each company
- Which authority for transit only? The competent authority is that of the federal state in which the activity is carried out “for the first time”. Where the route crosses several federal states, this has to be determined case by case.
- The limit of the “incidental” exception. The rules set no thresholds for the permit. Whether transport is incidental to the company’s main business is assessed in each individual case.
- Mixed loads. A single asterisked code in the load is enough for the transport to require a §54 permit, even if the rest is non-hazardous waste.
- Scope of the permit. The permit relates to the type of activity (collection, transport, dealing, brokering) and may carry conditions. A new type of activity or different waste requires checking whether it falls within the permit issued.
Requirements in other countries on the route are covered in our overview Waste transport across Europe.
Frequently asked questions
Is a registration from my home country or a §53 notification enough?
No. A registration or permit from Ireland, the UK or another home country is not a German permit, and a §53 notification covers only non-hazardous waste. Commercial transport of hazardous waste in Germany requires a permit under §54 KrWG, unless the company falls within a statutory exception.
Is a §54 permit needed for transit through Germany alone?
As a rule, yes. The AbfAEV covers activities carried out on German territory as part of a cross-border shipment of waste, and the rules do not exempt transit.
Is a §54 permit valid only in the federal state that issued it?
No. A §54 permit is valid throughout Germany. Its scope and any conditions must still be checked.
If I have a §54 permit, do I also need a §53 notification?
No. A company with a §54 permit does not additionally notify under §53 and may also transport non-hazardous waste on the basis of the permit.
Is all hazardous waste subject to ADR?
No. Classifying waste as hazardous and classifying goods under ADR are separate matters. Whether ADR applies depends on the properties of the material carried.
With a §54 permit, can I transport hazardous waste without notification?
No. The permit concerns the carrier. Consents for shipping a particular consignment derive from Regulation (EU) 2024/1157 and are a separate procedure.
What is the penalty for transporting without a permit?
Up to €100,000 (§69 KrWG). For foreign companies in road transport, proceedings are conducted by BALM.