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This page was translated from German with AI. If in doubt, the German original applies.

Procedure and roles

This page explains the procedure behind the consignment note (Begleitschein) and the acceptance note (Übernahmeschein) as far as you need it for an integration: who is involved, who creates and signs a layer and when, which deadlines apply and what ZEDAL takes care of. What the individual calls look like is shown in Consignment note by role and Consignment note and acceptance note.

The legal basis is the German ordinance on waste records (Nachweisverordnung, NachwV); the format is defined by the BMU interface specification. The sections are cited at every point so that you can look them up. This page summarizes; it does not replace the wording of the ordinance.

The documents

Document Purpose Number Legal basis
Disposal certificate (Entsorgungsnachweis, EN), collective disposal certificate (Sammelentsorgungsnachweis, SN) Preliminary control (Vorabkontrolle): the authority confirms that a waste may be disposed of in a particular facility. Runs for years and covers many transports. EN or SN, federal state code, 9 characters, check digit Sections 3–9 NachwV
Consignment note (BGS) Tracking control (Verbleibskontrolle): accompanies one transport from the waste producer to the disposer and refers to the certificate. “1” and 13 digits, check digit Sections 10, 11 NachwV
Acceptance note (UNS) Takeover from the individual waste producer in collective disposal (Sammelentsorgung); also for small quantities. “2” and 13 digits, check digit Sections 12, 16 NachwV

This guide covers the consignment note and the acceptance note. The BmuDocumentApi does read disposal certificates, but their procedure is not the subject of these pages.

The consignment note and acceptance note numbers come from the federal states’ system (Section 28(4) NachwV). In ZEDAL, you fetch them with FetchNumbers, see Numbers. The field formats are listed in the field rules.

The parties

The NachwV collectively calls the parties to a transport waste transport parties (Abfalltransportbeteiligte, ATB). Each of them has their own field in the consignment note, creates their own layer and signs it with a qualified electronic signature (QES, Section 19(1) NachwV).

Party Field in BGSDokument LayerType Rolle Signs at the latest NachwV
Waste producer erzeuger ERZEUGER ERZ on handover to the carrier Section 11(1) No. 1
Carrier, up to three befoerderer1 … befoerderer3 BEFOERDERER BEF on takeover of the waste Section 11(1) No. 2
Interim storage facility (operator of a site for short-term storage or transshipment) zwischenlager ZWISCHENLAGER ZWL on takeover of the waste Section 11(1) No. 3
Disposer entsorger ENTSORGER ENT without undue delay after acceptance Section 11(1) No. 4
Authority – BEHOERDE BEH – own layer, created by the authority

Carriers and interim storage facilities may also sign after the takeover, but before the handover to the next party, if this has been agreed in writing with the previous party (Section 19(2) NachwV).

Rolle also has the values PROV (provider), BEVERZ, MAK (broker) and SONST. For the layers of a consignment note, you only need the ones listed above.

Rolle and LayerType are two separate values

LayerType says which layer is appended. Rolle (in the schema ATBRolle) says for whom a layer is created that does not already carry its role in its name: template and supplement layers, plus the base layer of an acceptance note. That is why the API requires the role exactly there, in XmlOptions.atb_rolle.

Layers: how a consignment note grows

An electronic consignment note is not a form that is filled in one step after another, but a stack of layers (Annex 3 No. 2(c) NachwV). Each party creates their own layer, which contains the previous state in full, enters their details in it and signs it. Their signature therefore covers their own declaration and the taking note of all previous details. Once something has been signed, nobody changes it anymore. Corrections after the disposer’s signature go into a separate supplement layer.

flowchart TD
    V["Template layer<br/>optional, any role"] --> E[Waste producer]
    E --> B1[Carrier 1]
    B1 -->|directly| ENT[Disposer]
    B1 -->|via an interim storage facility| Z[Interim storage facility]
    Z --> B2["Carrier 2 (and 3)"]
    B2 --> ENT
    ENT --> ERG["Supplement layer<br/>for corrections"]
    ENT --> BEH[Authority]
    ERG --> BEH

Which layer may follow which is defined by the BMU schema:

Layer may follow Signature
Template layer – (first layer) optional
Waste producer Template layer or as the first layer mandatory
Carrier Waste producer, carrier, interim storage facility mandatory
Interim storage facility Carrier mandatory
Disposer Carrier mandatory
Supplement layer Disposer, supplement layer, authority mandatory
Authority Disposer, supplement layer, authority optional in the schema

This results in two rules that integrations tend to overlook: after an interim storage facility, a carrier always comes next, never the disposer directly. And the disposer always takes over from a carrier.

The template layer is a prefill without mandatory fields that any party can create. Because it is not permanently assigned to any party, it carries a role.

The route of a consignment note

The normal case with one carrier, when all three parties use ZEDAL via an integration:

sequenceDiagram
    autonumber
    participant ERZ as Waste producer system
    participant BEF as Carrier system
    participant ENT as Disposer system
    participant Z as ZEDAL
    participant ZKS as ZKS-Abfall / authorities

    ERZ->>Z: Fetch number (FetchNumbers)
    ERZ->>Z: Create consignment note, fill in waste producer layer (BmuDocumentApi)
    Note over ERZ: Person signs the waste producer layer (QES)
    ERZ->>Z: save and forward (ImportTransportDocument, distribute)
    Z-->>BEF: Deliver consignment note
    Z-->>ENT: Deliver consignment note
    BEF->>Z: fetch, create and fill in carrier layer
    Note over BEF: Driver signs on takeover (QES)
    BEF->>Z: save and forward
    Z-->>ENT: Deliver new version
    ENT->>Z: fetch, create and fill in disposer layer
    Note over ENT: Person signs after acceptance (QES)
    ENT->>Z: save, forward, flag for reporting (distribute, dekadenmeldung)
    Z-->>ERZ: Deliver completed consignment note
    Z-->>BEF: Deliver completed consignment note
    Note over Z: Ten-day report, usually 10 days after acceptance
    Z->>ZKS: Transmit consignment note to the authority

The fully signed consignment note goes from the disposer to the authority responsible for the disposal facility and at the same time to the waste producer and all carriers (Section 11(3), Section 19(4) NachwV). The route to the authority runs via the ZKS-Abfall, the joint institution of the federal states for electronic record keeping (Section 20 NachwV).

During forwarding (Vermittlung), ZEDAL determines whom to deliver to from the official numbers of the waste producer, carriers, interim storage facility and disposer in the document. Parties at ZEDAL receive the consignment note in their transport paper area (Versandpapier-Bereich), parties at other providers of the German electronic waste record procedure (eANV) receive it via the ZKS-Abfall. The authority is not a party in the sense of forwarding; it receives the consignment note via the ten-day report (Dekadenmeldung). Conversely, consignment notes from parties at other providers arrive in your inbox. How your system fetches from both incoming channels is described under Fetching incoming documents.

Deadlines

Who What Deadline NachwV
Waste producer Sign the waste producer layer at the latest on handover Section 11(1) No. 1, Section 19(1)
Carrier, interim storage facility Sign their own layer at the latest on takeover; with a written agreement, before the handover to the next party Section 11(1) Nos. 2 and 3, Section 19(2)
Disposer Sign the disposer layer without undue delay after acceptance Section 11(1) No. 4
Disposer Consignment note to the authority, the waste producer and all carriers at the latest 10 calendar days after acceptance Section 11(3), Section 19(4)
all Changed consignment note again to authorities and parties without undue delay Section 11(6)
Waste producer and collector Fill in the acceptance note at the latest on takeover Section 12(3)
all parties required to keep a register Enter the document in the register 10 calendar days after receipt Section 24(2) and (3)
all parties required to keep a register Retain the register 3 years from entry Section 25(1)
all Subsequent submission after a disruption 10 calendar days after the disruption is resolved Section 22(4)

The 10-day deadline for the disposer starts with acceptance, not with their signature. So save the disposer layer in ZEDAL directly after signing; ZEDAL schedules the report to the authority from the acceptance date.

Special cases

Multiple carriers

Up to three carriers are entered in befoerderer1 to befoerderer3; each of them creates their own carrier layer. If the carrier changes en route, the new carrier certifies the takeover in the consignment note itself, not via an acceptance note (Section 19(4) NachwV).

Interim storage facility

The interim storage facility creates its layer after the first carrier and enters the handover in zwischenlager.uebergabe_datum. After that, a carrier follows again and brings the waste to the disposer.

Collective disposal with acceptance notes

If a collector collects small quantities from many waste producers, they use a collective disposal certificate instead of a disposal certificate (Section 9 NachwV), and the waste producer’s obligations under the record procedure apply to the collector themselves (Section 9(3) NachwV). The process has two levels:

  1. One acceptance note per waste producer. The waste producer and the collector fill it in at the latest on takeover (Section 12(3) NachwV).
  2. One consignment note per collection tour. The collector fills it in at the start of the collection and enters themselves as the carrier (Section 13(1) NachwV). The waste producer field contains a fictitious producer number: federal state code, an “S”, the rest zeros. Before the handover to the disposer, the collector enters the numbers of the acceptance notes; in the electronic consignment note, they go into the dedicated field uns_nrn, not into vermerke. If the collector collects in several federal states, they keep a separate consignment note per state (Section 13(2) NachwV).

From the handover to the disposer onward, the collective consignment note runs like any other.

Small quantities

If a waste producer generates a total of no more than two metric tons of hazardous waste per year, they do not need a consignment note. The waste producer and the disposer then use an acceptance note (Section 2(2), Section 16 NachwV).

Acceptance refused

If the disposer does not accept the waste, they record this in their layer with entsorger.annahme_verweigert.

Disruption and receipt slip

If electronic communication fails, a receipt slip (Quittungsbeleg) replaces the consignment note (Section 22 NachwV). You submit the electronic version within 10 calendar days after the disruption has been resolved. In the document, quittungsbeleg on the respective party records whether a receipt slip was used; for the disposer, quittungsbeleg_verwendet does so as well.

Correction after completion

Signed layers remain unchanged. A correction or supplement goes into a supplement layer with the role of whoever is making the correction, and the consignment note goes again, without undue delay, to the authorities and parties (Section 11(6) NachwV). The procedure is shown in Consignment note by role.

Cancellation

The NachwV itself has no concept of cancellation. ZEDAL keeps a cancellation flag on the transport document, which you set with cancel when saving; it then appears in zusatz.storniert. ZEDAL delivers a canceled consignment note to the parties, but never reports it to the authorities. See Consignment note by role.

What ZEDAL takes care of and what remains with you

Task ZEDAL Your system
Generate BMU XML, append layers, write fields, check schema and check digits BmuDocumentApi provides the data, holds the XML
Consignment note and acceptance note numbers FetchNumbers fetches them before a note is created
Qualified signature WebSigner: signing process, approval at the trust service provider shows the person the signing link
Delivery to the other parties Forwarding on save (distribute) fetches incoming documents regularly
Transmission to the authorities via the ZKS-Abfall Ten-day report after the disposer layer has been saved (dekadenmeldung) sets the flag; has the report set up for the disposer account
Register, monitoring of deadlines, retention – keeps the register and monitors the deadlines

Only a person can sign

The qualified signature is a declaration of intent by the person who signs, with the signing means under their sole control. Your system can prepare everything up to that point: import data, create layers, validate, create the signing process. The person must approve the signature themselves, at the trust service provider with their second factor. Design your user interface so that this step comes at the right point in the process: for the driver at the takeover, for the disposer at the truck scale.

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