Lesson 1.3 · 7 min
Who is who: the roles in a shipment
Open in the coursewith narrated slides, a checklist to tick off and a quiz
At a glance
- Two names for the person in charge. For a notification it is the notifier; for the Green List, the person who arranges the shipment.
- In this order. The original waste producer, a new producer, a collector, or a dealer or broker acting for them. Only if all are unknown or insolvent, the waste holder.
- In the country of dispatch. The person in charge must be under the jurisdiction of the country of dispatch. Austria reads that as having a seat or an establishment here.
- Consignee and facility. The consignee is whoever receives the waste for recovery or disposal. If it isn't the facility's operator, the operator signs the contract too.
- Carriers. A carrier is whoever actually drives, a subcontracted haulier included. A forwarder that doesn't transport anything itself is not.
- Dispatch, destination, transit. Every country concerned has its competent authority. In Austria it is the BMLUK.
In detail
The person in charge: notifier or arranger
The regulation distinguishes by procedure. Whoever carries out a shipment that needs a notification, or has one carried out, is the notifier Art. 3(6). For Green List waste and laboratory samples, it is the person who arranges the shipment Art. 3(7). In both cases, these qualify, in this order:
- the original waste producer,
- the new waste producer, who treats the waste before shipment so that its nature or composition changes,
- a collector who has gathered small quantities of the same type of waste from various sources and ships them from a single location,
- a dealer or broker acting on behalf of one of these,
- only if all of these are unknown or insolvent: the waste holder.
A dealer or broker needs a written authorisation from the person it acts for; for a notification, it is included Art. 5(2). New producers, collectors, dealers and brokers may only notify or arrange if they hold a permit or are registered under waste law Art. 5(1) Art. 18(2). If the person in charge is not the original producer, it makes sure that, where practicable, the producer signs as well Art. 5(2) Art. 18(4).
A seat in the country of dispatch
Both definitions require the person to be under the jurisdiction of the country of dispatch. Austria and most Member States read that as requiring a seat or an establishment there (BMLUK). So only a company with a seat or establishment in Austria can notify or arrange a shipment from Austria; a shipment that starts in Germany follows the German rules. Nor can a company in Austria file the transport report in EDM for a notifier or arranger from another Member State: reports are made in the country of dispatch (BMLUK).
At the destination and on the road
- The consignee is whoever is under the jurisdiction of the country of destination and receives the waste for recovery or disposal Art. 3(5). If it isn't the facility's operator, the operator signs the contract too Art. 6(1) Art. 18(10).
- Carriers are all who actually carry out the transport, subcontracted hauliers included. Pure forwarders that don't transport anything themselves are not carriers (BMLUK).
- Competent authorities exist at dispatch, at destination and for every country of transit Art. 3(10)–(12). In Austria it is the BMLUK (USP).
Checklist
- For every shipment we know who the notifier or arranger is.
- Where we act as dealer or broker, we hold the producer's written authorisation.
- We hold the permit or registration our role requires.
- We know which carriers actually drive, subcontractors included.
- Consignee and facility operator are known by name.
Quiz
Who is a carrier, in the regulation's sense, in a Green List shipment?
- Only the haulier the arranger hired
- Also the forwarder that only organises the transport
- Everyone who actually carries out the transport, a subcontracted haulier included
- Only those who already have an EU Login
Show the answer
The answer is C: Everyone who actually carries out the transport, a subcontracted haulier included. According to the BMLUK, everyone who actually carries out the transport is a carrier, subcontractors included. Pure forwarders that don't drive are not. Carriers need an EU Login, but having one doesn't make anyone a carrier.
Sources
This lesson's statements rest on:
Not legal advice. What counts is Regulation (EU) 2024/1157 and Implementing Regulation (EU) 2025/1290 in the Official Journal, Austrian law and the BMLUK's guidance (read on 4 October 2026). DIWASS is a system of the European Commission. Not an offer of the European Commission, the BMLUK or the Environment Agency Austria.