Ms. Nhi asked, is the owner of these waste ink cartridges her company or the ink cartridge supplier? Who is responsible for collection and disposal? If Ms. Nhi's company is responsible for the collection and treatment of these waste toner cartridges; can her company transport them in small quantities from the company to the supplier's collection point by personal vehicle?

In addition to returning the waste ink cartridges to the supplier for disposal, can her company authorize another unit? If yes, please recommend some licenses to the company.

For companies that generate a very small amount of hazardous waste from consumption activities like Ms. Nhi's company, how should it be handled to meet legal requirements at a reasonable cost? Because the units specializing in the collection and treatment of hazardous waste only collect in large quantities and at high costs.

Ms. Nhi also wanted to know the penalty that consumers like her company will have to pay, if they throw these used ink cartridges into ordinary waste bins?

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

In Clause 1, Article 3 of Circular No. 02/2022/TT-BTNMT dated January 10, 2022 of the Ministry of Natural Resources and Environment detailing the implementation of a number of articles of the Law on Environmental Protection, "Waste source owner is an organization or individual that owns or is assigned to manage and operate a waste-generating facility". Therefore, the waste source owner of the waste toner cartridge is the company.

According to the provisions of Point a, Clause 4, Article 83 of the Law on Environmental Protection 2020, hazardous waste generators have vehicles and equipment that are allowed to transport hazardous waste generated and meet the technical requirements specified in the regulations prescribed in Article 73 of Circular No. 02/2022/TT-BTNMT.

According to the provisions of Point c, Clause 1, Article 83 of the Law on Environmental Protection 2020, waste source owners can reuse, recycle, treat, co-treat and recover energy in accordance with the law or convert deliver hazardous waste to an establishment with appropriate environmental permits for treatment.

The classification of hazardous wastes not in accordance with regulations shall be sanctioned according to the provisions of Article 29 of the Government's Decree No. 45/2022/ND-CP dated July 7, 2022 on sanctioning of administrative violations in the field of environmental protection.