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Sub-Product

With article 184-bis of Legislative Decree 152/2006 (Consolidated Environmental Law), in addition to the definition of waste, the Italian lawmaker has identified the criteria according to which a substance or object may be defined as a sub-product.

With Ministerial Decree 264/2016, a regulation has been subsequently published in the Official Journal intended for the consistent interpretation of the criteria according to which a substance or object may be qualified as a sub-product. Should one wish to qualify a production residue as sub-product and not as waste, the producer is obliged to prove that it possesses the requirements set by the law.

Compared to waste, the management of a sub-product may be advantageous for companies:

  • from the economic point of view, because the sub-product may be immediately placed in marketing channels generating profit. In addition, transport costs might be lower: in fact, waste is subject to designated transport with due management costs.
  • from an organisational point of view, as all the bureaucratic fulfilments and organisational requirements connected to waste management are not required (such as correctly filling in forms and in and out registers).

Meet the expert

Carla Repice

Carla Repice

Regulatory Affairs Consultant

Marco Vitulo

Marco Vitulo

Regulatory Affairs Consultant

Monica Stefani

Monica Stefani

Regulatory Affairs Consultant

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