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
- Monday to Friday. A working day is any day from Monday to Friday, except 1 January, 1 May, 15 August, 1 November, 25 and 26 December.
- Other holidays count. National public holidays are not taken into account. Easter Monday, 26 October or 8 December count as working days.
- Transport on a Tuesday. Two working days before means: report by the Friday before at the latest.
- Receipt on a Tuesday. The facility must confirm receipt by Thursday at the latest.
- Read closely. Some deadlines run in calendar days, such as the 30 days for the authorities' decision or for the certificate after treatment.
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
| Case | Deadline | At the latest |
|---|---|---|
| Green List transport on a Tuesday (BMLUK example) | report 2 working days before | the Friday before |
| Green List transport on a Thursday (BMLUK example) | report 2 working days before | Tuesday |
| Receipt of a notified delivery on a Tuesday (BMLUK example) | confirmation within 2 working days | Thursday |
| Transport on Monday, 28 December 2026 | report 2 working days before; 25 December doesn't count | Wednesday, 23 December |
| Receipt on Monday, 7 December 2026 | confirmation within 2 working days; 8 December counts as a working day | Wednesday, 9 December |
The deadlines at a glance
| What | Deadline | Basis |
|---|---|---|
| Green List: Annex VII form | no later than 2 working days before the start | Art. 18(5) |
| Green List: confirmation of receipt | within 2 working days of receipt | Art. 18(8) |
| Green List: recovery certificate | no later than 30 days after completion, at most 1 year after receipt | Art. 18(9) |
| Notification: movement document | at least 2 working days before the start | Art. 16(2) |
| Notification: confirmation of receipt | within 2 working days; 3 for exports | Art. 16(5) Art. 44(2)(i) |
| Notification: certificate | no later than 30 days after completion, at most 1 year after receipt | Art. 16(6) |
| Authorities' requests and the answers | 10 working days each | Art. 8(2), (3) |
| The authorities' decision | 30 days from completion | Art. 9(1) |
| Answer to an essential change | 5 working days | Art. 17(2) |
| Decision for pre-consented facilities | 7 working days | Art. 14(14) |
Checklist
- Our deadline calculation knows only the six holidays in the definition.
- Holidays like 8 December count as working days for these deadlines.
- We tell deadlines in working days apart from deadlines in days.
- The facility confirms receipts on time around holidays too.
Quiz
Waste arrives at the facility on Monday, 7 December 2026. By when must it confirm receipt of a notified delivery?
- By Friday, 11 December
- By Tuesday, 8 December
- By Thursday, 10 December, because 8 December is a public holiday
- 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.