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Biogas and Biomethane: Other Environmental Permits - Waste Production Permit ♻️

An investor planning to build a biogas plant - if not obligated to obtain an integrated permit - should apply for the following permits related to waste management:


  • 📝Permit for Waste Production (if producing waste exceeding 5000 tons annually - for non-hazardous waste);


  • ♻️ Permit for Waste Processing, which includes recovery processes, including preparation preceding recovery and disposal processes, including preparation preceding disposal; for biogas plants, the most appropriate type of energy recovery is type R10, i.e., "treatment on land bringing benefits to agriculture or improving environmental conditions", and R3, i.e., "recycling or recovery of organic substances not used as solvents (including composting and other biological transformation processes)".


The principle is that separate permits are issued for waste collection and separate permits for their processing, although it is possible to combine both permits into one collective permit if the applicant makes such a request.


It should be noted that under current legal regulations, before using waste for processing, the producer is obliged, in accordance with Article 11 of the Environmental Protection Act, to submit a notification of recognizing the object or substance as a by-product to the voivode responsible for the place of their production. This means that the substrate used in the biogas plant must be reported to the voivode, who, after assessment, issues a relevant decision allowing its processing. Such a decision is valid for a maximum of 10 years.


Competent authority for issuing decisions:

  1. Marshal of the Voivodeship:


  • For issuing permits for waste collection, in case the total combined mass of all types of stored waste in a year exceeds 3000 tons;

  • For facilities capable of accepting waste in quantities not less than 10 tons per day or with a total capacity not less than 25,000 tons, excluding facilities for agricultural biogas production.


2. County Mayor:


  • In all other cases.


Duration of the proceedings:

  • 1 month.

  • Particularly complex cases: 2 months from the date of initiation of the proceedings.


Fee for issuing the decision:

  • The treasury fee for issuing a permit for waste collection and/or processing is 616 PLN.

  • The treasury fee for authorization is 17 PLN.


How to appeal:

  • Appeal against the decision issued by the Marshal of the Voivodeship must be submitted within 2 weeks from the receipt of the decision to the Ministry of Climate and Environment.

  • Appeal against the decision issued by the County Mayor must be submitted within 2 weeks from the receipt of the decision to the relevant Local Appeals Board.

  • Further appeal can be made to the Voivodeship Administrative Court and the Supreme Administrative Court.


Can I submit the application electronically?

As of now, the authorities do not provide the option to submit electronic applications for obtaining a waste production permit.


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Summary ♻️

In the context of building a biogas plant, investors should consider obtaining permits for waste production and processing if they are not required to obtain integrated permits. The process of obtaining a permit depends on local and national regulations and may require notification to the voivode before processing waste. Permit fees amount to 616 PLN, and the duration of procedures may vary depending on the complexity of the matter. Currently, applications for waste production permits cannot be submitted electronically.



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