Canadian businesses that import hazardous waste into Canada must follow specific regulatory requirements for permits, documentation, and confirmations.
While the regulations are straightforward, there may be misunderstandings about delivery dates, required submissions, and documentation deadlines.
In this article, we explain what hazardous waste is and outline the key requirements for importing it, including the documentation required and the timelines to consider.
Hazardous waste is defined as anything to be disposed of using one of the disposal operations listed in Schedule 1, Part 1 (column 2), and that meets one or more of the following criteria:
Cross-border movements of hazardous waste are administered by Environment and Climate Change Canada (ECCC) and are regulated under the Cross-border Movement of Hazardous Waste and Hazardous Recyclable Material Regulations (XBR).
Even if a material meets the above criteria, they are not considered hazardous waste if it is:
When you import hazardous waste into Canada, you must comply with applicable regulations.
Compliance comes down to these responsibilities:
Additionally, you will need to confirm whether Transport Canada ERAP requirements apply to your shipment, and that the carrier and receiving facility meet any applicable transportation and environmental authorization requirements.
At the border, permits and movement documents for hazardous waste shipments must be available and produced upon request (note that rail shipments follow a different process).
Persons moving hazardous waste across the Canadian border must notify ECCC in advance of the intended shipment. This notification process serves as the application for an import permit.
The permit must specify:
The permit is normally valid for up to one year and is site-to-site specific.
Movement documents are used to track the waste, the parties involved, and the intended handling at the destination.
A movement document tracks the shipment in three parts:
Hazardous waste import requirements include strict timelines.
To ensure compliance, make sure you meet and track the following deadlines:
Submit Part C (and the carriers’ Part B) of the movement document in CNMTS within three (3) working days after the shipment is delivered to the receiving facility.
Submit the Confirmation of Disposal or Recycling (CDR) in CNMTS within 30 days after the disposal or recycling operation is completed. Your CDR submission must be based on the authorized facility’s written notice.
Interim disposal or recycling operations must be completed within 180 days after delivery (or shorter, if required by local authorities or permit conditions).
Final disposal or recycling operations must be completed within one (1) year of shipment delivery (or shorter, if required by local authorities or permit conditions).
However, if the shipment is forwarded to another authorized facility for final disposal or recycling, the final operation must be completed within 18 months of delivery to the receiving facility (or sooner, if required).
All compliance documents (including the original written notices/confirmations from the facility) must be kept at your principal place of business in Canada for five (5) years after the latest day on which any of the permits expires.
At Cole International, we offer trade consulting and customs brokerage services to help Canadian importers reduce compliance risks and stay ahead of requirements and deadlines.
Our team works with importers every day to:
We don’t believe in guesswork. We get it right the first time.
If you import hazardous waste into Canada, reach out to one of our trade professionals for help reviewing the process, timelines, and required documentation.