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The end of the production chain: Portuguese approach to Cannabis waste management

The Portuguese National Authority for Medicines and Health Products (“INFARMED”) and the Portuguese Environment Agency (“APA”) issued a joint technical informative document on cannabis waste management, especially in respect of activities that use cannabis for medicinal purposes.

The Portuguese authorities acted to clarify the waste management procedures applicable to cannabis, emphasising classification, transportation, and treatment, to assure cannabis plant waste is traceable throughout the waste management chain in compliance with regulatory demands for controlled substances.

Main aspects of the published information are:

  • Waste classification shall be based on the activity that led to waste production and referring to the European Waste Catalogue (EWC), as published on Commission Decision 2014/955/EU amending Decision 2000/532/EC on the list of waste, pursuant to Directive 2008/98/EC of the European Parliament and of the Council.

INFARMED and APA pointed out examples of specific EWC Codes that should be used for each activity and type of waste. While comprehensive, the presented list is not exhaustive, with room for other possible classifications.

  • Cannabis waste may have five possible destinations: composting, anaerobic digestion, direct agricultural recovery, land-filling or incineration.

  • Composting, anaerobic digestion, and direct agricultural recovery are privileged, as land-filling and incineration should only occur in exceptional circumstances.

  • Further down the production chain, waste resulting from cannabis extracts, formulations and medicines must be forwarded for incineration. In these situations, waste should be contained in closed and sealed packages that can only be opened on the moment of incineration.

  • Incineration should be done in the presence of a witness that must testify under an honour commitment that all forwarded waste was destroyed.

  • Data related to managed waste should be submitted to the Integrated System of Electronic Waste Registration (“Sistema Integrado de Registo Eletrónico de Resíduos”, SIRER); Stakeholders on the waste management chain must store data for three years and be able to provide it to competent authorities.

As determined within the waste management general framework, waste treatment must be assured by the respective producers, that shall forward it to waste treatment operators dully licensed for that effect. 

The list of licensed waste treatment operators is available on the Information System for Licensing of Waste Management Operations (SILOGR) – waste producers can filter the operators on SILOGR per EWC code.

It is important to frame the management of the waste produced within the scope of these activities in taking into consideration their specificities and the need to control their destination.

Tags

cannabis, regulation, portugal

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