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Lesson 4.3 · 5 min

Counting working days correctly

Open in the coursewith narrated slides, a checklist to tick off and a quiz

At a glance

In detail

What a working day is

Implementing Regulation (EU) 2025/1290 on DIWASS lays down that a working day is any day from Monday to Friday except 1 January, 1 May, 15 August, 1 November, 25 December and 26 December Implementing Reg. 2025/1290, Art. 2(2), point 16. The BMLUK applies this definition to the regulation's deadlines and stresses that national public holidays are not taken into account.

So Austrian public holidays not on that list count as working days, such as 6 January, Easter Monday, Ascension Day, Whit Monday, Corpus Christi, 26 October and 8 December.

Examples

CaseDeadlineAt the latest
Green List transport on a Tuesday (BMLUK example)report 2 working days beforethe Friday before
Green List transport on a Thursday (BMLUK example)report 2 working days beforeTuesday
Receipt of a notified delivery on a Tuesday (BMLUK example)confirmation within 2 working daysThursday
Transport on Monday, 28 December 2026report 2 working days before; 25 December doesn't countWednesday, 23 December
Receipt on Monday, 7 December 2026confirmation within 2 working days; 8 December counts as a working dayWednesday, 9 December

The deadlines at a glance

WhatDeadlineBasis
Green List: Annex VII formno later than 2 working days before the startArt. 18(5)
Green List: confirmation of receiptwithin 2 working days of receiptArt. 18(8)
Green List: recovery certificateno later than 30 days after completion, at most 1 year after receiptArt. 18(9)
Notification: movement documentat least 2 working days before the startArt. 16(2)
Notification: confirmation of receiptwithin 2 working days; 3 for exportsArt. 16(5) Art. 44(2)(i)
Notification: certificateno later than 30 days after completion, at most 1 year after receiptArt. 16(6)
Authorities' requests and the answers10 working days eachArt. 8(2), (3)
The authorities' decision30 days from completionArt. 9(1)
Answer to an essential change5 working daysArt. 17(2)
Decision for pre-consented facilities7 working daysArt. 14(14)

Checklist

Quiz

Waste arrives at the facility on Monday, 7 December 2026. By when must it confirm receipt of a notified delivery?

  1. By Friday, 11 December
  2. By Tuesday, 8 December
  3. By Thursday, 10 December, because 8 December is a public holiday
  4. By Wednesday, 9 December
Show the answer

The answer is D: By Wednesday, 9 December. Within two working days (Art. 16(5)). 8 December is a public holiday in Austria but is not on the list in Implementing Regulation (EU) 2025/1290, so it counts as a working day: Tuesday is the first, Wednesday the second.

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.