Industrial Waste Management System 2026 | Tracking Waste to Final Disposal

For most factories, the industrial waste management system conversation starts from an unexpected direction. An email arrives on a Monday morning saying the licensed processor you have been using has been suspended and can no longer accept deliveries. Your on-site storage bay has about ten days of room left. You start looking for an alternative processor and realise nobody in the plant can state, accurately, which waste codes you generate and how many tonnes of each. Someone begins pulling old removal permits out of a filing cabinet to count them, and only then does the real problem surface. The problem is not the processor. The problem is that there is no record. This article sets out how to design a system that fixes that, using the actual clauses of Thai regulation and a costed model.

An industrial waste system tracks what happens after the gate, not up to shipment

When a factory talks about traceability, the subject is normally the product. Which material lot went into which machine, became which part number, and shipped to which customer. That is lot traceability, and responsibility ends at shipment, or at the latest when the customer accepts the goods.

Industrial waste traceability puts that end point somewhere else. Passing the factory gate does not discharge your responsibility. A transporter carries the waste, a processor receives it, and only when treatment or disposal is complete does it leave your hands. The leg of the journey that happens outside your own site is inside the scope of the obligation, and that single fact separates waste traceability from production traceability.

That difference changes almost every design requirement. Nothing about it is contained inside your own manufacturing system. Part of the record sits with the transporter, part with the processor, and part exists only inside a government platform. However clean your own database is, records that never come back from the other party stay empty.

The idea that the identifier is set by the regulator rather than by you is not new. Medical devices got there first, and Medical Device UDI Compliance 2026, designing identifiers all the way to SaMD works through the same structure on the product side. If you have to explain regulatory traceability internally, reading both together makes the shape clearer.

Thailand already changed the rules in November 2023

Before going further, one common misconception needs removing. Some Japanese-owned plants still operate on the assumption that Thai waste regulation is loose, or that the legal framework has not been built yet. The opposite is true. The operating rules were rewritten in 2023.

The instrument is the Notification of the Ministry of Industry on the Management of Waste or Unused Materials, B.E. 2566. It was announced on 16 March 2023 and published in the Government Gazette, Volume 140, Special Part 126 Ngor, dated 31 May 2023. It has been in force since 1 November 2023, with Articles 13 and 22 among the provisions taking effect from the day after publication. Note also that the notification was amended by Notification No. 2 dated 8 August 2023, so deadlines such as the annual report have to be read against the amended text. Most translations in circulation reproduce the original wording, which is why it pays to check whether an amendment applies before relying on a date.

That notification repealed, in one move, the disposal notification of B.E. 2548 that had been the operating backbone, the notification of B.E. 2547 on reporting through electronic media, the second amendment of B.E. 2560, and the third amendment of B.E. 2566. Any plant still working from an old internal procedure manual is following a repealed instrument.

The heart of it is that the generator’s responsibility now runs through to completion of treatment. The law firm Tilleke and Gibbins describes the change as extending accountability until waste is properly and completely disposed of, and as adding responsibility for contingencies such as processor failure and loss of waste, where previously the obligation ended at collection.

The clauses make that structure explicit. Article 12 states that the generator is responsible for transporting waste to the designated processor, and then continues. Where waste has been taken out of the factory but it appears that it has not been handled in accordance with the permit, the waste is considered not to have been managed, and the generator is obligated to complete the handling in accordance with the permit. The same article states that this applies in cases of loss, accidents, or unauthorised disposal.

If a load never reaches the treatment facility, the liability does not stay with whoever was driving. It comes back to whoever generated it. That one sentence turns an industrial waste management system from a nice-to-have into the only way to discharge the obligation.

Get the waste code wrong and every record downstream is wrong

Classification is the entrance to the whole regime. Annex 1 of the notification divides waste and unused materials into 19 chapters and identifies each item with a six-digit code.

The 19 chapters follow industrial reality. Chapter 01 covers exploration, mining and mineral treatment. Chapter 02 covers agriculture and food processing. Chapter 03 covers wood, pulp and paper. Chapter 04 covers leather, fur and textiles. Chapter 05 covers petroleum refining. Chapters 06 and 07 cover inorganic and organic chemical processes. Chapter 08 covers coatings, adhesives and printing inks. Chapter 09 covers the photographic industry. Chapter 10 covers thermal processes. Chapter 11 covers chemical surface treatment of metals. Chapter 12 covers shaping and mechanical surface treatment of metals and plastics. Chapter 13 covers oil wastes. Chapter 14 covers organic solvents and refrigerants. Chapter 15 covers packaging, absorbents and wiping cloths. Chapter 16 covers business activities and material types not otherwise listed. Chapter 17 covers construction and demolition. Chapter 18 covers health care and related research. Chapter 19 covers waste management facilities and off-site wastewater treatment.

A Japanese-owned manufacturing plant will use Chapters 12, 11, 15 and 16 most often. Machining swarf, grinding sludge, plating effluent, degreasing solution, contaminated rags and gloves, and used packaging are the daily reality.

There is a prescribed order for selecting a code, and a surprising number of plants assign codes on the shop floor without knowing it exists.

Skip that order and one thing happens. Waste accumulates under the catch-all codes ending in 99. File the annual report on that basis and the authority receives a submission it cannot interpret, so it asks. To answer, you try to trace back to the physical material, and you cannot, because the only record says “not otherwise specified”. Sloppy classification always returns as an accountability problem twelve months later.

Hazard status has its own markers. A six-digit code marked HA is an absolute entry, treated as hazardous waste without analysis. A code marked HM is a mirror entry, requiring analysis against the criteria in Annex 2 to decide whether it is hazardous. Codes with no marker are non-hazardous, but you should first confirm the item is not excluded altogether by Article 5, which carves out excrement and urine generated on the premises, non-hazardous unused materials from offices, staff accommodation and canteens, untreated wastewater discharged through pipelines for treatment outside the premises, and pressure-resisting gas containers that can be reused or refilled.

From a system design point of view, this code structure is the master data design. Hold the six-digit code and the HA or HM marker on the waste item master, print them on the container label, and resolve them automatically at the weighing step. Get this loose and every application and every report downstream inherits the error.

The filing deadlines are already writing your requirements document

What an industrial waste management system needs to do is, to an unusual degree, specified for you. The regulation says who files what and by when.

The Department of Industrial Works runs an electronic system for waste management. Operators log in to the DIW industrial waste electronic management system with a national ID card number and password to file removal permit applications. The site publishes a contact for the industrial waste management division for operators who cannot get into the system.

The equivalent of a waste manifest is defined in Article 6 as the “management documentation”. The definition reads as documents issued by the generator through the central data reporting system of the Ministry of Industry, serving as evidence for the transfer of waste to the processor for proper management until completion. In other words, the instrument that legally counts is an electronic record issued from a government system, not a paper slip. In Thailand, electronic waste manifests are not an option to evaluate. They are the baseline.

Rearranging the clauses into a deadline table shows what the system has to carry.

The second half of that table, the processor’s clocks, matters most to the generator. Article 20 requires the processor to notify the generator at least 5 days before the deadline expires if it cannot complete management in time. Article 14 then gives the generator 5 days to notify the authority and 30 days to apply for a transfer to another processor.

Put differently, the moment hazardous waste leaves your gate, a 30-day countdown starts on someone else’s site. On day 25 you may receive a message saying it cannot be processed, and when you do, a 5-day clock and a 30-day clock start on yours. The fact that no human being can hold those clocks in their head is the most honest business case for building the system.

Article 17 carries a practical implication too. The processor inspects every incoming load and submits the result and the management documentation back to the generator. The inspection parameters listed include appearance, colour, specific gravity, phase, flash point, pH value, halogen content, cyanide content, water percentage, activation value per dose and overall radioactivity. If the material turns out not to match what was authorised, the processor notifies the generator promptly. Very few plants have decided who receives those returning records and where they are filed, and that is usually the first hole an audit finds.

There are only four data items worth instrumenting

Waste IoT sounds like a large programme. Mapped against what the regulation actually asks for, there are only four kinds of data to capture.

Three of those four you can build yourself. Weight, identity and time captured on the shop floor already produce most of what applications and reports need. The fourth, vehicle position, you cannot produce. It has to be written into the contract.

The physical arrangement is not complicated. Put one portable platform scale and one terminal at the entrance to the storage bay. Setting a container down reads its weight, scanning its barcode resolves the item and its six-digit code, and the timestamp at that moment is recorded as the containment start date. Scanning again at removal records the end date and the removal weight. Those two scans produce exactly the label content Article 7 paragraph 2 requires, namely the generator’s name, the name and code of the waste category, and the start and closure dates of containment.

Keeping one photograph per removal is worth the effort as well. A picture of the container and the storage bay taken at removal makes later enquiries dramatically faster to answer. Article 7 paragraph 4 requires the storage layout to be kept updated and ready for inspection, so photographs sit comfortably inside the intent of the rule.

One caution belongs here. GPS logs from transport vehicles contain the driver’s location, and photographs at the gate can capture people. Under Thailand’s personal data protection law these are data you need a position on. If the purpose of collection, the retention period and the sharing scope are not written into the contract and your internal rules, a system built for one compliance obligation creates another. Factory IoT and PDPA Compliance 2026, where collected data becomes regulated works through that boundary, and it is worth reading before you settle how GPS logs will be handed over.

Half the record lives in somebody else’s system

The most commonly missed part of the design is managing the records you cannot create.

You can create the segregation, identification, weighing, storage and removal records. Everything after that arrives from the transporter and the processor, or not at all. The inspection report and management documentation under Article 17 is one such record. The processor’s monthly report under Article 22, due by the 15th of the following month, is corroborating evidence for how your waste was actually handled.

So what the system needs is not a sending function but a function for holding what comes back against a deadline. Concretely, you need a register that tracks the following for each removal. The permit number and its validity, the handover date and weight, whether the processor’s receipt confirmation has come back, the completion deadline of 30 days for hazardous waste or 60 days for non-hazardous, whether the completion evidence has come back, and if it has not, the start date for the 5-day and 30-day clocks under Article 14.

Without that register, deadline management depends on one person’s memory and a spreadsheet. The day that person transfers, nobody knows which cases are still open. Being asked in an audit to produce the completion evidence for hazardous waste removed last March, and having nothing, is a direct consequence of that dependency.

It also feeds supplier selection. Hold licence type and expiry, treatment method, receiving capacity and, above all, the historical rate of meeting deadlines in the register, and choosing a replacement when a processor stops accepting takes hours. Without it, it takes weeks. That gap drives most of the numbers in the costing below.

EPR moves the end point one step further out

Everything so far is law in force. What follows is a bill under consideration. Nothing can be stated as settled, but the direction is not ambiguous.

The Department of Industrial Works put forward a Draft Industrial Waste Management Act and held a public hearing that ran until 1 April 2025. According to the analysis published by Baker McKenzie, the draft adopts the principle of Extended Producer Responsibility, or EPR.

Several points in the draft deserve attention. The scope covers almost all types of waste generated by the industrial sector, excluding infectious waste and radioactive waste. Electronic waste and vehicle scrap are included, whether generated inside or outside Thailand. Operators are responsible for industrial waste until it is fully treated or disposed of, including collection and transportation, and must ensure that only DIW-licensed entities handle disposal.

The definition of who bears that responsibility has the widest reach. According to the same analysis, the definition of generator extends to generators, manufacturers, assemblers, importers, owners, and brand or trademark owners. A company with no plant of its own in Thailand, contracting out all its manufacturing, can therefore land inside the scope.

Structurally, a Sustainable Industry Fund under the Ministry of Industry would address remediation of environmental damage. Disposers, collectors and transporters would place security deposits contributing to initial compensation for operational damages. Existing factory licences, specifically types 101, 105 and 106 under the Factory Act, are expected to be deemed equivalent licences on a temporary basis.

The status has to be stated precisely. The legislative process is not complete. Provisions overlap with the Draft WEEE Act covering electrical and electronic equipment waste, and the two may be merged before adoption. Nobody can currently say when a specific obligation starts.

On the electronics side there is movement. Nation Thailand reported on 11 January 2026 that Thailand generated over 400,000 tonnes of electronic waste in 2023, including used smartphones and tablets. The WEEE bill, built on the EPR principle, would make producers responsible for collecting and recycling end-of-life products, and is being pushed forward. The same report cites the Thailand Development Research Institute on the absence of a systematic collection system, which leaves much of the waste stored at home or sold to informal collectors who dismantle devices improperly and leave toxic residues. The article also notes that recovering materials from one million recycled mobile phones yields over 15 kilograms of gold, 350 kilograms of silver and over 15,000 kilograms of copper, and that Australia’s MobileMuster programme recovered 109 tonnes of old mobile phones in 2024, generating materials worth up to 2.5 million US dollars.

Packaging is moving the same way. The Pollution Control Department commissioned Mae Fah Luang University to draft a Sustainable Packaging Management Act, and posted the draft for public hearing in March 2024. It runs to 53 articles in four parts covering policy, management responsibility, supervision and implementation. Designated manufacturers would have to use packaging designed and specified on environmentally friendly principles, display required labels or symbols, collect and reuse or safely dispose of used packaging, participate in buy-back or deposit-refund schemes announced by the Minister, and communicate sorting and return instructions to consumers. Alongside that, the draft sets criteria for registering the operators responsible for sustainable packaging management and reporting the volume of packaging placed on the market.

Do not miss the common structure. Every EPR regime assumes operator registration and volume reporting. A company that cannot state, in numbers, how much it placed on the market, how much it collected and how much it recycled will not be able to comply on the day the regime starts. Building a system that records weight mechanically is both compliance with the notification in force today and preparation for what is coming.

How much industrial waste does Thailand actually generate

For calibration, here is the national picture. The environment statistics published by the National Statistical Office give annual industrial waste generation, sourced from the Pollution Control Department and the Department of Industrial Works.

Read the numbers carefully. The 2022 figures stand well clear of the years on either side, at 33.84 million tonnes non-hazardous and 2.71 million tonnes hazardous. Treating that as a genuine surge in generation would be a mistake. Changes to reporting rules or to what was counted are the more likely explanation, and at minimum it is not credible that real generation doubled in one year and halved in the next.

The practical takeaway from this table is the volatility, not the level. If a national aggregate moves this much, individual plant submissions vary at least as much. A factory that counts its own numbers the same way every year gains explanatory power from that alone.

Building up the cost and the benefit on a model plant

To make this concrete, take a hypothetical plastic moulding plant in Rayong province. What follows is our own estimate, not measured data.

The assumptions are 320 employees, 12 waste item types of which 5 are hazardous, annual generation of 1,850 tonnes non-hazardous and 210 tonnes hazardous, 240 removals off site per year, and a supplier base of 4 processors and 3 transporters.

Administrative effort today looks like this. Each removal takes 55 minutes of paperwork, electronic filing and reconciliation, which across 240 removals is 220 hours. Monthly reconciliation and correction takes 8 hours a month, or 96 hours a year. Compiling the annual report due on 30 April takes 40 hours. That totals 356 hours a year. At a labour cost of 220 baht per hour, that is 78,320 baht a year.

This is the first fork in the road. Justify an industrial waste management system on administrative effort alone and it will never be approved. Nobody spends seven figures in baht to remove 78,320 baht of work. What has to be counted is not the effort but the losses from events that happen because the records do not exist.

Building up the loss side gives the following.

The first of these is the most realistic in Thailand. Processors do stop accepting, whether through enforcement action or a delayed licence renewal, and when they do the 5-day and 30-day clocks in Article 14 start turning. A plant with no alternative already qualified has to contract at emergency rates.

Applying frequencies converts these into an annual expected loss.

979,300 baht a year. That is the figure the investment should be compared against, not the 78,320 baht of administrative effort.

The build divides into four layers

Ask for a quotation and you will usually receive a proposal built around automating submissions to the government system. But the functionality has a clear hierarchy, and the order in which you add the layers changes the payback substantially.

The layer concept is the same one that governs traceability design generally. Which layer lets you answer which question, and where the cost jumps, is set out as a four-layer model in Traceability System Build Cost 2026, which layer makes the price jump, which works well as a basis for explaining the layer split internally.

The effect of each layer is worth stating explicitly. Layers 1 and 2 remove the gaps in the record itself, so they reduce untraceable waste and audit non-conformities, but they do nothing directly about a processor that stops accepting. Layer 3 speeds up filing, and the only thing it reduces is administrative effort. Layer 4 manages supplier deadlines and completion evidence, so it catches the early signals of a suspension and shortens the search for a replacement.

The order you build in changes payback by more than a factor of two

Comparing combinations of the four layers gives the following. The assumptions are that Layers 1 and 2 alone cut untraceable-waste and audit losses by 60 percent, that adding Layer 4 takes that to 70 percent, that Layer 4 cuts the suspension loss by 60 percent while its absence leaves only a 20 percent reduction, and that on administrative effort Layers 1 and 2 bring each removal down from 55 minutes to 25 minutes for a saving of 120 hours a year, while Layer 3 brings each removal to 12 minutes and cuts monthly reconciliation to 24 hours a year and the annual compilation to 24 hours, for a saving of 260 hours a year.

One conclusion comes out of that table. Adding Layer 3 before Layer 4 stretches payback from 2.1 years to 6.1 years. Option B costs 190,000 baht more up front than Option D and returns 295,190 baht a year less in net benefit.

The reason is straightforward. All Layer 3 removes is administrative effort. And once Layers 1 and 2 are already in place, adding Layer 3 saves only a further 140 hours a year, or 30,800 baht. Against that, Layer 3 costs 96,000 baht a year to run. Layer 3 runs at an annual deficit on its own. Layer 4, by contrast, takes 60 percent out of a 680,200 baht event. The magnitudes are not comparable.

For most plants, then, the right answer is Layers 1, 2 and 4 in that order, with Layer 3 deferred. Filing can stay manual for now, done by a person working from the Layer 2 data. Once weight, time and code are captured mechanically in Layer 2, entering a submission is already far less work than it was.

Layer 3 becomes justifiable only where the number of removals is an order of magnitude higher. The next section puts a number on that.

What happens when the assumptions move

The estimate above leans heavily on three assumptions. Take each in turn.

Assumption 1 is the frequency of a processor suspension. Suppose it happens once every two years rather than once a year, which is closer to reality for a plant that consolidates onto large suppliers and monitors licence renewals. The annual expected loss from suspensions falls from 680,200 baht to 340,100 baht. On that basis Option D returns an annual benefit of 439,830 baht and a net benefit of 295,830 baht, stretching payback to 3.6 years, while Option A comes in at 4.0 years. The conclusion about ordering holds, but the gap narrows.

Assumption 2 is the number of removals. Suppose it is 1,200 a year rather than 240, which describes a chemical plant shipping many small consignments with a high hazardous share. The baseline effort is 1,200 removals at 55 minutes each, or 1,100 hours, plus 96 hours of monthly work and 40 hours of annual compilation, for 1,236 hours a year. Layers 1 and 2 bring each removal to 25 minutes, giving 636 hours a year. Layer 3 brings each removal to 12 minutes and reduces the monthly and annual work as well, giving 288 hours a year. The incremental saving attributable to Layer 3 is therefore 348 hours a year, or 76,560 baht, against an incremental running cost of 96,000 baht. Even at this volume Layer 3 still runs at an annual deficit. Break-even sits at roughly 1,600 removals a year, and only beyond that does recovering the 450,000 baht initial cost become a conversation at all. It is better understood as a layer you choose because you cannot dedicate a person to filing, not because the arithmetic favours it.

Assumption 3 is the hazardous share. Suppose it is high enough that processor suspensions happen twice a year. The 30-day deadline in Article 20 applies to hazardous waste and is shorter than the 60 days allowed for non-hazardous, so the higher the hazardous share, the higher the probability that a processor runs past the deadline. Annual expected loss from suspensions becomes 1,360,400 baht, Option D returns an annual benefit of 1,052,010 baht and a net benefit of 908,010 baht, and payback shortens to 1.2 years.

Of the three, the one you are least sure about is the first. That is precisely why the first task is to build the supplier register, load two years of history into it, and count how many suspensions and missed deadlines actually occurred. Until that number exists, arguing about Layer 3 produces no answer.

What to do in 90 days

Ninety days is a workable unit for this.

The first 30 days are an inventory. Re-assign an Annex 1 six-digit code to every waste item you currently handle. Doing so always turns up items that were hiding under a code ending in 99, and items marked HM that were never analysed. In parallel, pull 24 months of removal records and build a single table of volumes, weights and deadline performance by supplier. That table becomes the basis for your loss estimate.

The second 30 days are about capturing records on the floor. Put a scale and a terminal in the storage bay, reprint container labels under the new code structure, and get containment start and end dates recorded automatically. Roll out time synchronisation across the devices in this window as well. Resist the urge to rush into automated integration with the government system here.

The third 30 days are for standing up the supplier register. For each removal, make the permit number, handover date, weight, receipt confirmation, completion deadline and completion evidence visible in one place. At the same time, add a clause to the transporter contract specifying how GPS logs will be provided. Once that register is running, there is still no hurry to evaluate Layer 3.

After that, run for six months, including through the rainy season, and settle the real frequency of missed deadlines. There is no need to rush. With Layers 1 and 2 in place you can already answer most of what an audit will ask.

Frequently asked questions

What is an industrial waste management system?

It is a mechanism for recording factory waste mechanically by classification code, weight and timestamp, so that everything from the removal permit application to confirmation that treatment was completed can be tracked in one register. Product traceability ends at shipment. Industrial waste traceability covers everything up to the completion of treatment or disposal. In Thailand, the Ministry of Industry notification of B.E. 2566 sets out concrete requirements for removal permits, vehicle tracking, annual reporting and receiving records back from processors.

Are electronic waste manifests mandatory in Thailand?

The Thai equivalent of a manifest is defined as management documentation, issued by the generator through the Ministry of Industry’s central data reporting system. Removal permit applications are likewise to be made with the electronic system as the primary method. Running the process on paper slips alone therefore falls outside what the regulation contemplates. Filing at a Department of Industrial Works office is permitted only where the electronic route is not available.

How much does an industrial waste management system cost?

In the model plant used here, segregation and identification cost 180,000 baht up front, weighing and removal records 620,000 baht, filing and reporting integration 450,000 baht, and completion tracking with a supplier register 260,000 baht, for a total of 1,510,000 baht initial and 240,000 baht a year to run. You do not have to build all four at once. Limiting the build to Layers 1, 2 and 4 costs 1,060,000 baht initial and 144,000 baht a year, and pays back faster.

Where should waste IoT recording start?

With weight. Put one portable platform scale and one terminal in the storage bay and build the habit of scanning the container barcode at the same time. That alone assembles the generator name, classification code, and containment start and end dates required on the label, and the same data produces the quantity for the removal permit and the monthly totals. Vehicle GPS logs cannot be produced in-house, so secure them by writing the handover method into the transporter contract.

When and where does the report to the Department of Industrial Works go?

The generator reports the previous year’s storage and on-site handling electronically through the Ministry of Industry’s central data reporting system by 30 April of the following year. Processors carry a separate obligation, submitting a monthly report on the raw materials received and products to the same system by the 15th of the following month. The records you receive from a processor are that monthly report plus the inspection result and management documentation issued on receipt.

When will Extended Producer Responsibility affect manufacturers?

The timing is not settled. The Draft Industrial Waste Management Act was open for public hearing until 1 April 2025, the legislative process is not complete, and it may be merged with the Draft WEEE Act. The direction, though, is clear. The definition of who bears responsibility is being drafted to reach importers and brand owners, not only manufacturers. Whatever shape the final regime takes, it will require reporting the volume placed on the market and the volume recovered, so a mechanism that records weight mechanically is worth building ahead of time.

Summary

An industrial waste management system is not an extension of production traceability. Because responsibility ends at the completion of treatment rather than at shipment, half the record sits outside your own company. Build out your internal system without grasping that, and you still cannot answer what an audit asks.

Thailand switched over in November 2023. The Ministry of Industry notification of B.E. 2566 requires removal permits to be filed through the electronic system, transport vehicles to be tracked, the previous year’s position to be reported by 30 April, and the generator to notify the authority within 5 days and apply for a transfer within 30 days once a processor says it cannot complete the work. Processors are held to completion deadlines of 30 days for hazardous waste and 60 days for non-hazardous. No one can hold those clocks in their head.

In the model estimate, the annual expected loss from having no records came to 979,300 baht. Against that, Layers 1, 2 and 4 paid back in 2.1 years, all four layers in 3.5 years, and skipping Layer 4 to build Layer 3 first in 6.1 years. Layer 3 reduces only administrative effort, and even at five times the removal volume it still runs at an annual deficit on its own. The order of construction is what determines the return.

Given the direction of travel towards EPR, what to build now is not in doubt. It is a mechanism that can count what you placed on the market and what you disposed of, by code and by weight, the same way every year. Waiting until the bill is finalised leaves too little time.

If you are still at the stage where nothing has been decided internally about waste records or removal management, that is a perfectly good place to start a conversation. We work through it in the order the job actually happens, from re-assigning six-digit codes to your current waste items, to deciding what belongs in the supplier register, to drawing the line on how far to automate weighing and identification. A list of your waste items and the last twelve months of removal records is enough to make the discussion concrete. Please get in touch through the contact page.

References

• Notification of Ministry of Industry, Subject Management of Waste or Unused Materials, B.E. 2566 (2023), unofficial translation, JETRO – Source for the enforcement date and exclusions, the Article 6 definition of management documentation, Article 7 container labelling, Articles 9 and 10 removal permits, Article 12 vehicle tracking and continuing liability, the annual reporting duty in Article 13, the 5-day and 30-day clocks in Article 14, Article 17 receiving inspection, the 30, 60 and 180-day limits in Article 20, the 15th of the following month in Article 22, and the Annex 1 six-digit code structure with HA and HM markers
• Upcoming Amendment to the Industrial Waste Management Regulation (Thailand), Nagashima Ohno and Tsunematsu, 8 September 2023 – Source for the existence of the amending Notification No. 2 dated 8 August 2023 and for the annual reporting deadline of 30 April of the following year under Article 13
• Thailand Embraces Polluter-Pays Principle as New Regulation on Industrial Waste Takes Effect, Tilleke and Gibbins, 4 December 2023 – Commentary on the 1 November 2023 effective date, the extension of liability until complete disposal, and electronic filing
• DIW industrial waste electronic management system, ระบบการจัดการสิ่งปฏิกูลหรือวัสดุที่ไม่ใช้แล้ว – The live electronic system operators use to file removal permit applications
• Department of Industrial Works, factory portal – Competent authority and related procedures
• Thailand The Draft Industrial Waste Management Act, A new waste management regime, Baker McKenzie and Global Compliance News, 21 April 2025 – Source for the EPR principle in the draft act, the public hearing running to 1 April 2025, scope, the extension of the generator definition to brand owners, the Sustainable Industry Fund and security deposits, transitional treatment of factory types 101, 105 and 106, and possible merger with the Draft WEEE Act
• Thailand The Draft Industrial Waste Management Act, Lexology reprint – Reprint of the same commentary
• Thailand awaits new law to manage over 400,000 tonnes of e-waste a year, Nation Thailand, 11 January 2026 – Source for over 400,000 tonnes of electronic waste generated in 2023, the WEEE bill and the EPR principle, the absence of a systematic collection system, metal recovery from one million mobile phones, and the Australian collection figures
• สถิติสิ่งแวดล้อมของประเทศไทย พ.ศ. 2567, National Statistical Office of Thailand, industrial waste generation – Source for non-hazardous and hazardous industrial waste generation from 2019 to 2023, compiled from the Pollution Control Department and the Department of Industrial Works
• Thailand, Draft Sustainable Packaging Act, Enviliance ASIA – Source for the Pollution Control Department commissioning Mae Fah Luang University, the March 2024 public hearing, the structure of 53 articles in four parts, and operator registration with reporting of volumes placed on the market