Waste licence, SAWIS and EPR deadlines for South African waste generators and producers

Three separate clocks run for most waste-handling and producer businesses: a waste management licence under the National Environmental Management: Waste Act 59 of 2008 before starting a listed activity, periodic SAWIS reporting once registered as a data provider, and ongoing EPR registration and reporting for producers of paper and packaging, electrical and electronic equipment, lighting, and (since March 2023) portable batteries, lubricant oils and pesticides.

Reviewed by TefCo Compliance Research — last verified 15 September 2026.

In short

A waste management licence is required before undertaking any activity on the listed activities schedule made under the Waste Act 59 of 2008, section 20.
Persons carrying out a listed SAWIS activity must register on the South African Waste Information System and then submit information on the reporting cycle set by the National Waste Information Regulations.
EPR producers of paper and packaging, EEE, lighting, batteries, lubricant oils and pesticides must register with the Department and report through their EPR scheme.
Facilities holding an Atmospheric Emission Licence must submit their annual AEL report — NAEIS emissions data reporting closes on 31 March each year for the preceding year.

When a waste management licence is triggered

Section 20 of the National Environmental Management: Waste Act 59 of 2008 prohibits a person from commencing certain waste management activities without a waste management licence. Which activities require a licence — and whether they fall under a Category A or Category B process — is set out in the List of Waste Management Activities, most recently consolidated in Government Notice 921 of 29 November 2013 and amended several times since, including in 2014, 2015, 2017 and 2022.

Because the listed activities schedule has been amended repeatedly, the safe approach is to check the current consolidated list against your specific activity and throughput before assuming an older exemption still applies.

The three recurring clocks for a waste business
Obligation	Trigger / cycle	Source
Waste management licence	Before commencing a listed activity	Waste Act 59 of 2008, section 20
SAWIS registration and reporting	On starting a listed SAWIS activity, then on the prescribed reporting cycle	National Waste Information Regulations, GN R.625 (2012)
EPR producer registration	Before placing identified products on the market	EPR Regulations, GN R.1184 (2020)
AEL annual report / NAEIS emissions data	Annually; NAEIS closes 31 March for the preceding reporting period	National Atmospheric Emission Reporting Regulations, GN R.283 (2015)

SAWIS: registration first, reporting on a cycle

The National Waste Information Regulations require a person conducting an activity listed in Annexure 1 to register on the South African Waste Information System (SAWIS) and then submit waste information on the reporting cycle and within the timeframes the regulations and any amendment set. The regulations have been amended since 2012, including a 2018 proposal to shorten the quarterly submission window, so a registered reporter should confirm the current reporting period length directly on SAWIC rather than relying on the original 2012 text.

SAWIS reporting periods and submission windows have been amended more than once since 2012. Confirm the current cycle and due dates for your registered activity on the SAWIC portal before treating any specific date as fixed.

EPR: registration, then a scheme, then reporting

Under the Extended Producer Responsibility Regulations, 2020 (Government Notice 1184, Government Gazette 43879 of 5 November 2020), which took effect on 5 May 2021, a producer of an identified product must register with the Department, either join or establish a Producer Responsibility Organisation and EPR scheme, pay the applicable EPR fee, and comply with the scheme's monitoring and reporting obligations under section 18 of the Waste Act.

The identified product streams originally covered were paper and packaging, electrical and electronic equipment, and lighting. In March 2023 the regime was extended to portable batteries, lubricant oils and pesticides, and the underlying regulations and sector notices have since been amended further, including amendments gazetted in November 2024.

Air quality: AEL holders have their own annual clock

A facility holding an Atmospheric Emission Licence under the National Environmental Management: Air Quality Act 39 of 2004 must submit an annual AEL report, including a compliance audit, to its licensing authority. Separately, facilities classified as data providers under the National Atmospheric Emission Reporting Regulations must submit emissions data to the National Atmospheric Emission Inventory System (NAEIS) for the preceding reporting period by 31 March each year.

Frequently asked

Does a small recycler need a waste management licence?

It depends on the specific activity and throughput thresholds in the current List of Waste Management Activities gazetted under section 20 of the Waste Act 59 of 2008. Some sorting, shredding or baling activities fall under norms and standards with a registration requirement rather than a full licence — check the current listed activities schedule for your exact activity.

Is SAWIS reporting the same as an EPR report?

No. SAWIS reporting is a general waste information obligation under the National Waste Information Regulations for anyone conducting a listed SAWIS activity (such as landfilling, treatment or recycling). EPR reporting is a separate obligation on producers of identified products, run through a Producer Responsibility Organisation or the producer's own approved scheme.

Who has to register for EPR?

Producers — including brand owners, manufacturers, converters and importers — of paper and packaging, electrical and electronic equipment, lighting, portable batteries, lubricant oils or pesticides placed on the South African market must register under the EPR Regulations, 2020.

Sources

TefCo Corporate Compliance (Pty) Ltd is a compliance management platform, not a legal, tax or advisory firm. This guide is general information, not advice. Fees, dates and thresholds change — confirm current figures with the regulator before you rely on them.