Ms. Pham Thuy Linh's unit (Ninh Binh) has environmental criteria equivalent to group II projects, and has a register of hazardous waste source owners issued by the Department of Natural Resources and Environment. The unit is carrying out procedures for re-issuance of an environmental permit.

Ms. Linh asked, for hazardous waste content, her unit only needs to declare in Section 4, Chapter III, Appendix X of Decree No. 08/2022/ND-CP (according to Article 83 of the Law on Environmental Protection 2020) after removing the hazardous waste source owner's register is it correct?

The Ministry of Natural Resources and Environment responded to this issue as follows:

The Law on Environmental Protection 2020 has drastically reformed administrative procedures for people and businesses through the regulation of environmental permits, including the abolition of the procedure for granting a hazardous waste source owner register. (Point a, Clause 1, Article 83 of the Law on Environmental Protection 2020 stipulates that it is the responsibility of hazardous waste generators to declare the volume and type of hazardous waste in the application for an environmental permit or environmental registration contents).

Therefore, Ms. Linh's unit only has to comply with the provisions of Point a, Clause 1, Article 83 of the Law on Environmental Protection 2020, which stipulates that hazardous waste generators are responsible for "declaring the volume and type of hazardous waste in the application for an environmental permit or environmental registration contents".

In case the project owner acts dishonestly when declaring the volume and type of hazardous waste, through the post-inspection process of the competent state agency, the violation will be detected, handled and requested to the owner. The project will carry out remedial measures according to regulations.