With Article 184-bis of Legislative Decree 152/2006 (Environmental Consolidation Act), the national legislator alongside the definition of waste identified the criteria according to which a substance or object can be defined as a sub-product.

With Ministerial Decree 264/2016, a regulation was subsequently published in the Official Gazette with the aim of standardising the interpretation of the criteria according to which a substance or object can be qualified as a sub-product.

If a production residue is to be classified as a sub-product and not as waste, the producer is required to prove that it meets the requirements identified by law. The management of a sub-product as opposed to a waste can be advantageous for companies

  • from an economic point of view, as the sub-product can be immediately placed on the market, generating profitability. In addition, costs in terms of transport may be reduced: waste is subject to dedicated transport with obvious management costs.
  • from an organisational point of view since all the bureaucratic and organisational procedures for waste management are not in place (such as, for example, the correct drafting of forms and the filling in of loading and unloading registers).

How can we help you?


Normachem offers an extensive training programme for companies.

See all the courses


Complete assistance with risk assessment and security maximisation.

Find out more

Contact us

Contact us for more information about our consultancy services and courses.

Write to us