Create a waste balance in accordance with Section 55 of the KrWG: template, mandatory content and deadlines

According to Section 55 of the Circular Economy Act (KrWG) in conjunction with the Evidence Ordinance (NachwV), operators of certain systems are obliged to keep a waste balance annually and to present it to the responsible authority upon request. According to Section 25 NachwV, the retention period is at least three years, often five years for systems requiring approval under the BImSchG, and even ten years for evidence of hazardous waste. Anyone who does not keep the balance sheet or keeps it incomplete runs the risk of a fine of up to 100,000 euros per violation according to Section 69 KrWG and, in the event of a repeat offense, the withdrawal of the plant permit as well as an entry in the central commercial register with consequences for future tenders.

This article explains which companies are required to keep a balance sheet, what content a waste balance must necessarily cover according to Section 55 KrWG and how you can structure the documentation so that it is one withstands official scrutiny. You will receive a verifiable template structure, information on the allocation of waste codes according to AVV, an overview of the most common deficiencies and a procedure with which the annual balance sheet becomes a routine instead of an annual crisis in March. You will learn how the balance sheet is combined with accompanying notes, eANV takeover notes and the internal register to form a closed chain of documents that can withstand any request from the authorities. CIVAC is a German compliance platform and officer-as-a-service with workspace, 490 audit templates, ISO/IEC 27001:2022 ISMS and EU data residency according to standard.

The obligation to produce a waste balance does not apply to every company, but to a clearly defined group. Section 55 KrWG refers to the Evidence Ordinance, which specifies the obligation to keep registers and balance sheets in Sections 23 ff. As a rule, operators of systems requiring approval in accordance with Section 4 BImSchG, specialist waste disposal companies in accordance with Section 56 KrWG, commercial collectors as well as producers and owners of hazardous waste above certain quantity thresholds are required to carry out the balance sheet. Transporters and dealers of hazardous waste also keep registers that are included in the balance sheet.

It is important to differentiate from the obligation to register. Every producer of hazardous waste keeps a register in accordance with Section 49 KrWG. The waste balance goes beyond this: it condenses the register data into an annual overview, organises them according to waste codes of the Waste Catalog Ordinance (AVV) and compares recycling and disposal. Authorities use the balance sheet to check compliance with the waste hierarchy according to § 6 KrWG: prevention before preparation for reuse before recycling before other utilization before disposal.

Anyone who cannot clearly assign their own balance sheet obligation should systematically check the plant permit, the decision according to BImSchG and the AVV code of the waste generated. CIVAC bundles this check in the workspace of the environmental officer and links each system with the associated list of duties. This way you can see at a glance whether a waste balance is due for your location, which quantity thresholds apply and which additional evidence applies according to the BImSchG or the Commercial Waste Ordinance. The appointment certificate, signed, filed, verifiable. This clear assignment of duties is the basis of every reliable balance sheet and prevents an authority from encountering previously unrecognized balance sheet obligations during the audit process and making additional demands with tight deadlines that are difficult to meet operationally and trigger internal escalations.

The waste balance according to Section 55 KrWG in conjunction with Section 24 NachwV is not a free document, but follows a fixed structure. It must reflect all waste generated, accepted, handed in and stored for the calendar year. The mandatory content is divided into five areas: master data of the facility, waste types according to the AVV code, quantities in tons, origin and whereabouts as well as recovery and disposal processes according to appendix 1 and 2 KrWG. If one of these areas is missing, the balance sheet is considered incomplete and will be rejected for correction.

The master data includes the operator name, system location, system number, BImSchG file number and reference year in the header of the balance sheet. The types of waste are each identified with a six-digit AVV code, supplemented by the designation according to AVV and the labelling as hazardous or non-hazardous. Quantities are to be stated in tonnes with two decimal places, broken down into delivered, produced in the company, recycled, disposed of and left in storage. The total must add up, otherwise the balance sheet is not closed.

For each item, at least the industry or group of producers must be named for each item, as well as the waste disposal company or the downstream facility with the facility number and address. Recycling processes are identified with R codes (R1 to R13), disposal processes with D codes (D1 to D15). Anyone who works with abbreviations or incomplete codes risks a complaint in the test report. The balance sheet must be so legible that an external auditor can understand the waste flows without further questions. The auditor calls, the evidence is ready. This readability is not just a question of form, but also decides whether the balance sheet is accepted as plausible or whether an in-depth on-site inspection follows.

A waste balance in accordance with Section 55 of the KrWG can be drawn up in seven sections, which cover every authority audit. Section 1 contains the master data of the operator and the system, including BImSchG file number, industry code, NACE code and reporting period from January 1st to December 31st. Section 2 documents the balance sheet basics: quantity determination using calibrated scales, volume measurement or documented flat-rate approach, data sources from accompanying notes, acceptance notes, internal weighing cards and eANV extracts as well as the description of the measuring devices used with the calibration date.

Section 3 lists all types of waste in a table according to the AVV code, each with a name, physical state and labelling as dangerous or non-hazardous. Section 4 presents the quantity balance: initial inventory plus delivery and in-house production minus recycling, disposal and in-house consumption results in the final inventory. Differences of more than 5 percent are explained in the next section, for example due to shrinkage, evaporation, incoming inspections with quantity correction or stock transfers between locations. Section 5 documents recycling and disposal with R and D codes, disposal address, facility number and proof number for electronic verification (eANV).

Section 6 explains special features: extraordinary deviations in quantity, newly added types of waste, stocks over twelve months, accidents and official orders in the reporting year. Section 7 contains the date, signature of the responsible operations manager and, if applicable, the waste officer as well as a co-signature from the management, if internal rules stipulate this. Anyone who maintains the template in a spreadsheet program should adapt the data structure to the authority's XML schemas in order to avoid media disruptions. CIVAC provides a waste balance template in the workspace that maps these seven sections and is automatically filled from the current register, so that on April 1st there is no longer any manual transfer work and the balance sheet is exported as PDF/A with one click. Audit-proof, documented, § 55-proof.

The Waste List Ordinance (AVV) forms the basis for every waste balance. It contains around 840 waste codes, divided into 20 chapters according to the industry of origin. Each key consists of six digits: the first two identify the chapter, the next two the subgroup title, the last two the specific waste. Star-marked keys (e.g. 13 02 05*) mean hazardous waste with special monitoring requirements according to Sections 49 and 50 KrWG.

The most common errors in practice: firstly, the allocation of a collection key that is too unspecific, such as 19 12 12 instead of a specific material key from Chapter 17 or 20. Secondly, the confusion of mirror entries where a dangerous and a non-dangerous key exist in parallel (e.g. 17 05 03* and 17 05 04). Thirdly, the lack of classification according to the HP criteria (HP1 to HP15) for mirror entries. Fourthly, the omission of the quantity information for so-called small quantities, which according to NachwV can still be subject to accounting if they accumulate over the calendar year.

Those who work properly here document the derivation of the key for each type of waste: material description, origin process, analysis results for mirror entries, reference to safety data sheets and, if necessary, reports from external laboratories. This derivation becomes part of the balance sheet documentation and is available in the workspace together with the accompanying note, the weighing receipt and the disposal contract. In this way, a list becomes comprehensible evidence. The workspace links each AVV key with the associated legal basis and with the chain of responsibility in the company. Who issued the key, when and on what basis can be found at any time. This traceability is crucial if, years later, an authority inquires or a change of ownership triggers a due diligence that examines contaminated sites and historical waste streams.

The waste balance is prepared every calendar year. Section 24 Paragraph 3 NachwV requires completion by April 1st of the following year. The deadline may vary for systems with reporting obligations in accordance with the 11th BImSchV or the Industrial Emissions Directive (IED). The balance sheet will be presented to the responsible authority upon request; Automatic transmission is only intended for certain types of systems. In the case of specialist waste disposal companies, the recognised monitoring association checks the balance sheet as part of the annual monitoring in accordance with Section 56 KrWG and establishes compliance in writing.

Retention periods result from Section 25 NachwV: three years for the waste balance itself, five years for the underlying registers in accordance with Section 24 NachwV and ten years for evidence of hazardous waste in accordance with Section 25 Paragraph 2 NachwV. Tax and commercial law retention periods according to § 257 HGB and § 147 AO can be longer and must be checked separately. The deadline begins at the end of the calendar year in which the balance sheet was prepared, not the reporting year.

Submission requirements take effect as soon as the authority requests them. Experience shows that there are typically two to four weeks between request and submission, sometimes only 72 hours if there is a justified reason such as a resident complaint, fire or accident. Anyone who only creates the balance sheet then is too late and produces visible defects. Deadline begins as soon as we become aware of it. CIVAC bundles balance sheets, registers and accompanying notes in the same workspace and reminds you of the April 1st deadline 90, 30 and 7 days before with a documented escalation level. This means that the balance sheet does not remain idle, but is updated with every disposal movement. An external environmental officer also takes over this care via officer-as-a-service without tying up internal personnel capacity.

The evaluation of official audits in North Rhine-Westphalia, Bavaria and Lower Saxony shows recurring deficiencies in practical accounting. First and foremost are missing or incomplete quantity balances: although initial inventory, arrivals and departures are documented individually, they are not condensed into a closed overall balance. In second place are incorrect AVV keys without documented derivation. Thirdly, missing R or D codes in the disposal routes, for example if only the name of the disposal company is entered but the procedure remains open.

Flaws four to seven relate to the document chain. Consignment notes are filed separately from the register, meaning an auditor cannot carry out cross-comparisons in a reasonable amount of time. Transfer notes from the eANV are not included in the balance sheet because the responsible employee does not systematically review the quarterly statements. In the case of mirror entries, the reason why a position was classified as not dangerous is missing, even though the parallel dangerous variant exists. In the case of collective batches, there is no breakdown into individual batches with date and origin.

Flaw number eight is the incomplete signature: no name of the responsible operations manager, no date, no stamp, no co-signature of the waste officer. Defect number nine: the balance sheet is kept electronically, but when requested is not presented in a verifiable format (PDF/A), but as an Excel file with unclear versions. Anyone who checks these nine defects preventively will survive most official inspections without additional demands. A structured template that lists each mandatory content as a separate field prevents the most common omissions. CIVAC provides this template as part of the 490 ready-to-use audit templates and links it to the ISO/IEC 27001:2022 ISMS if the facility is part of a certified area. Others run compliance like a filing cabinet. We run it like software.

Many companies keep the waste balance in an Excel file, maintained by the plant manager or a working student. This method works with few types of waste and stable staffing. As soon as the plant generates more than 30 types of waste or the responsible person changes, problems arise: formula errors in the quantity balance, incorrect references between spreadsheets, lack of version control, no audit trail, parallel file versions on different drives and therefore no clear source of truth. When there are inquiries from the authorities, there is no overview of which file is the final balance sheet.

A linked workspace solves these problems structurally. The balance sheet is no longer created anew, but rather generated from the current data. Every accompanying note that is signed in the eANV automatically flows into the register. The register condenses into a balance sheet as soon as the calendar year is completed. Corrections are versioned: who changed what and when can be traced at any time. This audit trail capability is also required by ISO/IEC 27001:2022 Annex A 8.15 (Logging) if the system is part of an ISMS, and corresponds to the 93 controls of the current version of the standard as well as the requirements for unchangeable logging in certified areas.

The changeover can be done in three steps. Step 1: Migration of the existing balance sheets from the last three years into the new structure, retaining the original documents as a PDF archive and a mapping table for the AVV keys. Step 2: Connection of the eANV interface so that accompanying notes arrive automatically and acceptance notes are compared quarterly. Step 3: Define roles and approval channels, such as balance sheet creator, technical review by the waste officer, management approval and archiving in the audit-proof data room. CIVAC offers this migration as a standard process with handover in 2 working days instead of the classic 2-6 weeks and includes everyone involved in the workflow without internal IT resources being required for the connection. Licence the workspace for your internal representatives or have our representatives order it.

The waste balance according to § 55 KrWG does not stand alone, but is interlinked with other obligations. Systems in accordance with the 4th BImSchV also create emission declarations in accordance with the 11th BImSchV, in which waste streams appear as secondary data. Operators who fall under the Commercial Waste Ordinance (GewAbfV) document the separation of paper, plastic, metal, glass and biodegradable waste as well as the pretreatment of mixed commercial waste in accordance with Section 4 GewAbfV. Anyone who produces construction waste must also provide evidence in accordance with the Substitute Building Materials Ordinance and the Shell Ordinance with proof of suitability for recycling materials.

Material flow verifications in accordance with Sections 17b and 17c of the BImSchG concern systems that use sustainable biomass, biogenic fuels or renewable fuels. This evidence runs via the Nabisy database of the Federal Office for Agriculture and Food (BLE). The quantities stored in Nabisy must be consistent with the balance information in the waste balance, otherwise the differences will be noticed during the next official audit and lead to questions about the overall data quality. The EU emissions trading system (ETS) also requires consistent quantity and energy data for certain systems.

An integrated workspace addresses these interfaces. Data from the eANV, from Nabisy, from the emissions register and from the internal material flow calculation flow into a common data room. The waste balance becomes a view of this data room, not a separate file with its own data maintenance. In the case of inquiries from authorities, each item can be traced back to the original document: balance sheet item, register entry, accompanying note, weighing receipt, safety data sheet, disposal contract, calibration certificate for the scale. CIVAC connects these data sources in the environmental officer's workspace and offers the reporting line to management as regular, documented reporting with clearly defined escalation levels for excess quantities or new hazardous waste. EU data residency is standard, so that no waste data is stored outside the European Union and sensitive material flow information does not leave the region.

A waste balance is not a compulsory exercise, but rather part of environmental governance. It shows how a company handles resources, where waste avoidance potential lies and what recycling rate is achieved. Banks and ESG rating agencies read the balance sheet as soon as a company falls under the CSRD reporting requirement and is required to report in accordance with ESRS E5 (Resource Use and Circular Economy). Even according to the LkSG, the waste balance can be part of the risk analysis if downstream waste disposal companies in third countries are commissioned and this creates human rights or environmental risks in the supply chain, which are included in the annual LkSG report to the BAFA.

Those who bring the waste balance out of the shadow of pure legal obligation and place it in the strategic reporting line win several times over: less risk in audits, better ratings, clearer material flows and thus leverage for cost reduction through targeted avoidance or higher Recycling rates. This interlinking can only be achieved if you keep the balance sheet, register and strategy on one platform and think about the officer roles for waste, environment and sustainability together instead of separating them into silos.

CIVAC is the compliance platform and officer-as-a-service that makes this interlinking possible. 25 representative roles are live, 490 audit templates are ready for use, the workspace links waste balance with ISO/IEC 27001:2022 ISMS and ESG reports. The appointment certificate, signed, filed, verifiable. Licence the workspace for your internal representatives or have our representatives order it. If you do not want to create the waste balance for 2026 until March 2027, but would like to keep it on an ongoing basis, write to info@civac.de or use the contact form. Handover in 2 working days instead of the traditional 2-6 weeks, including the representative's appointment certificate and connection to the reporting line. Turn reading into an assignment.