Knowledge base
Hazardous waste or not: how the assessment works
The answer drives cost, transport requirements and liability. Yet it is often confused with the KM and MKM assessment. Here is the difference and the method.
Two different questions, two different rulebooks
The KM and MKM guideline values answer whether the land is suitable for a given use. The hazardous waste question answers how the waste must be managed under the Swedish Waste Ordinance. Soil can exceed MKM without being hazardous waste, and the two assessments use different values and different methods. Comparing the analysis report against the wrong table is the most common mistake in the industry. Read our guide to KM and MKM for the other rulebook.
How the assessment is done
Classification starts from the waste's hazardous properties, HP1 through HP15, where individual substance concentrations are assessed against limits derived from EU chemicals legislation. In practice the industry standard is Avfall Sverige's guidance with concentration limits for contaminated soil. The report is under revision to reflect updated legislation and a new version has been announced. Multiple substances with the same hazardous property may have to be summed, it is not enough that each single substance stays below its own limit.
POP substances: the stop many miss
For persistent organic pollutants, including certain PFAS, the EU POP Regulation sets its own limit values. Above the limits the waste must be treated so that the POP content is destroyed or irreversibly transformed, regardless of what the other assessments say. The POP stop overrides everything else. See our guide to PFAS in soil for the current limit values.
Who carries the liability?
The waste producer is responsible for correct classification. A wrong classification can stop deliveries at the gate and lead to claims after the fact, and incomplete documentation of transport and reporting can trigger an administrative fine of 5,000 SEK per breach. Document the assessment: which analyses, which values, which methodology and which version of the underlying guidance.
Frequently asked questions
Is soil above MKM automatically hazardous waste?
Not necessarily. MKM is a guideline value for land use, hazardous waste is assessed against other limit values under the Swedish Waste Ordinance. Soil can exceed MKM and still be non-hazardous waste.
What concentration limits apply for hazardous waste?
The limits are derived from the waste's hazardous properties under EU chemicals legislation. Avfall Sverige's guidance with concentration limits for contaminated soil is the most widely used application in the industry, and an updated version of the guidance has been announced.
What applies to PFAS-containing soil?
In addition to the ordinary assessment, the EU POP Regulation sets limit values for certain PFAS. Above those limits the waste must be treated so that the POP content is destroyed or irreversibly transformed.
Who decides if my soil is hazardous waste?
You as the waste producer are responsible for the classification, supported by analyses and established methodology. Tools and consultants are decision support, the liability stays with you.
Classify against the right rulebook, keep the evidence
Pinpointer's classification module is decision support with version-controlled rules for both KM/MKM and hazardous waste concentration limits. Every assessment is stored with the rule version that applied. You always make the final call.