Deadlines for the entry into force of RENTRI have been published
With the directive decree no. 97 of September 22, 2023, the timelines related to the following have been defined:
- deadlines for registration with RENTRI
- entry into force of the new c/s register and FIR models
- obligation to keep the c/s register in digital format
- obligation to keep the FIR in digital format
This decree has been published on the website of the Ministry of the Environment and Energy Security and on the RENTRI website.
What are the deadlines set by the decree?
The "RENTRI Deadline Table" adopted with directive decree no. 97 of September 22, 2023, provides for:
Deadlines for RENTRI registration:
Registration with RENTRI must be carried out within the following timeframes (Art. 13, paragraph 1)
| Letter a): starting from the eighteenth month and within the following sixty days (Art. 13, paragraph 1, letter a) | starting from December 15, 2024, and by February 13, 2025 |
| Letter b): starting from the twenty-fourth month and within the following sixty days (Art. 13, paragraph 1, letter b) | starting from June 15, 2025, and by August 14, 2025 |
| Letter c): starting from the thirtieth month and within the following sixty days (Art. 13, paragraph 1, letter c) | starting from December 15, 2025, and by February 13, 2026 |
Date of entry into force of the new models:
Deadline for the adoption of the new Loading and Unloading Register and Waste Identification Form (FIR) models (Art. 9, paragraph 1)
| The Register and FIR models, as per Articles 4 and 5, are applicable regardless of the obligation to register with RENTRI, starting from the date indicated in Article 13, paragraph 1, letter a) | starting from February 13, 2025 |
Obligation to keep the loading and unloading register in digital format:
Deadlines for keeping the loading and unloading register in digital format (Art. 4, paragraph 3, letter b)
| For operators required to register with RENTRI between December 15, 2024, and February 13, 2025 | starting from February 13, 2025 |
| For operators required to register with RENTRI between June 15, 2025, and August 14, 2025 | from the date of registration with RENTRI |
| For operators required to register with RENTRI between December 15, 2025, and February 13, 2026 | from the date of registration with RENTRI |
Obligation to issue the FIR in digital format:
Deadline for issuing the FIR in digital format (Art. 7, paragraph 8)
| For operators required to register with RENTRI, the waste identification form is issued and managed digitally starting from the date indicated in Article 13, paragraph 1, letter c) | starting from February 13, 2026 |
The first deadline is therefore for entities or companies that are initial producers of hazardous and non-hazardous special waste with more than 50 employees, as well as for all other entities different from the initial producers, including those referred to in Article 18: these entities must register between 12/15/2024 and 02/13/2025. From 02/13/2025, these same entities must keep the loading and unloading register in digital format.