New waste classification system in Ukraine: what has changed

Ukraine has introduced a new waste classification system, aligning national legislation with European Union standards. The change was implemented by the Resolution of the Cabinet of Ministers of Ukraine No. 1102 dated October 20, 2023, which approved the Waste Classification Procedure and the National Waste List. This is a key element of the Law of Ukraine “On Waste Management” No. 2320-IX, adopted on June 20, 2022, and fully enforced since January 1, 2025.

How the new system works

All waste is now classified using six-digit codes (XX XX XX) according to the National Waste List.

• The first two digits indicate the waste group.

• The next two — the subgroup.

• The last two — the specific type of waste.

Codes marked with an asterisk (*) designate hazardous waste, while codes without an asterisk apply to non-hazardous waste. This approach mirrors the European Waste Catalogue (EWC).

What changed compared to the old system

Previously, Ukraine used two different classification methods:

1. Hazard classes (I–IV):

• Class I — extremely hazardous,

• Class II — highly hazardous,

• Class III — moderately hazardous,

• Class IV — low-hazard.
  This Soviet-style model is no longer valid.

2. Medical waste categories (A–D):

• Category A — non-infectious waste similar to municipal waste;

• Category B — epidemiologically hazardous (blood-contaminated materials, infected instruments);

• Category C — particularly hazardous (e.g., tuberculosis, HIV);

• Category G — toxicologically hazardous (cytostatics, chemical preparations);

• Category D — radioactive waste.
  This classification is also phased out. Instead, all medical waste is now categorized using codes from the National Waste List.

Why this is important

• Incorrect waste coding may result in administrative liability, improper storage or treatment, and risks to human health and the environment.

• The new system introduces transparency, clarity, and compliance with EU practices.

• Medical and pharmaceutical waste is now classified by specific codes, for example:

  • 18 01 03* — waste from medical care that may be infectious,

  • 18 01 06* — chemical waste from healthcare facilities, considered hazardous.

The European approach

The reform implements Ukraine’s obligations under the EU Waste Framework Directive 2008/98/EC. It ensures:

• unified waste classification rules;

• improved transparency and oversight in waste management;

• stronger environmental protection and corporate responsibility.

Conclusions

• The old terms “hazard classes (I–IV)” and “medical waste categories (A–D)” are no longer applicable.

• The only valid system today is the National Waste List with six-digit codes and the asterisk (*) for hazardous waste.

• Businesses and healthcare facilities must work exclusively with licensed operators who apply the new rules and provide official disposal certificates.