Waste management companies not to have their decisions terminated on December 31, 2025
The approaching end of 2025 has sparked concerns among waste management companies. According to existing regulations, duly filed applications for new decisions may not protect them from being unable to operate after January 1, 2026. However, the Ministry of Climate and Environment has announced that legislative work is underway to extend administrative decisions beyond this date. This is in response to the backlog in government agencies and the flood of applications that could paralyze the waste management sector.
A flood of applications leading to paralysis of authorities
An amendment to the Waste Law in 2018 (also known as the Firesafety Law), required all entrepreneurs engaged in waste management activities to align their decisions with the new fire protection requirements. Accordingly, by March 5, 2020 at the latest, entrepreneurs engaged in waste management activities were required to file applications to have their decisions aligned with the new regulations. This process involved preparing fire prevention reports and installing video surveillance, which caused most entrepreneurs to submit their applications just before the deadline. The surge in applications nearly overwhelmed state offices, paralyzing the operation of these institutions.
Meanwhile, 2024 and 2025 mark the expiration of the ten-year validity period of waste management decisions issued in 2014 and 2015. Consequently, offices were flooded with an additional wave of applications for new decisions.
A remedy not entirely effective
The situation was to have been remedied by introducing Article 226a to the Waste Law and Article 193(1c) to the Environmental Law in 2022. According to these articles, in the period until 31 December 2025, a permit for waste collection, processing, or production shall not expire due to the lapse of the time for which it was issued if the waste holder applies for a new permit no later than three months before this deadline.
The long wait time for a new or amended administrative decision on waste management poses a risk of many entrepreneurs having to close their businesses due to the approaching effective date of the aforementioned regulations and the administrative authorities’ failure to issue new permits/licenses in a timely manner.
The Ministry’s Response
In response to Parliamentary Inquiry No. 9775, the Ministry of Climate and Environment analyzed the situation with regard to the overall waste management system and the country’s economy. The ministry concluded that legislative changes are needed to eliminate the aforementioned risks and allow administrative decisions on waste management to be extended beyond January 1, 2026.
Regarding the possible deadline for the extension, the Ministry of Economy and Labor received a letter from the Ombudsman for Small and Medium-Sized Enterprises on April 22, 2025. In the letter, the Ombudsman proposes extending the deadline by 3 years, until December 31, 2028.
Entrepreneurs concerned about what steps to take and what deadlines to meet to extend their ability to conduct waste management activities are welcome to contact us.
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