3.5 Industry Waste Management Plans

The industry waste management plan (IndWMP) is a planning instrument that will identify how a specific waste stream will be managed by industry. The IndWMP gives industry the opportunity to set out the additional standards that it will meet for waste management activities and how it will adhere to these. The IndWMP will commit the industry to targets for the management of the waste which may include recycling, recovery or re-use targets or in some cases waste collection targets depending on the waste stream. The industry will be required to report on these agreed targets, which will indicate the success or not of the plan.

IndWMPs can be waste stream specific or company specific, and can be submitted on a voluntary basis or as directed by the Minister through a notice in a government gazette. IndWMPs will assist industries to:

  • Identify management and financing mechanisms for specific waste streams.
  • Identify waste avoidance and minimisation targets for industrial sectors or companies.
  • Set performance targets for the management, recycling, re-use and recovery of either a specific waste stream or wastes from a specific industry.
  • Support a licence application.
  • Identify the regulatory support required to achieve maximum compliance with the plan among industry stakeholders.

3.5.1 Mandatory and Voluntary IndWMPs

The Waste Act provides for mandatory and voluntary industry waste management plans. The Minister or MEC may give directions that a person, category of persons or an industry that generates waste prepares an IndWMP. The Minister is the regulatory authority for IndWMPs in which waste generating activities affect more than one province or are conducted in more than one province.

The following industries are preparing mandatory IndWMPs in consultation with DEA:

  • Tyre industry for waste tyres.
  • Paper and Packaging for packaging and paper waste.
  • Lighting industry for mercury containing lamps e.g. CFLs.
  • Pesticide Industry for residual pesticides and pesticide containers.

Over the course of the next five years, IndWMPs will be required for different forms of ewaste and batteries, and other waste streams that are best managed through an IndWMP.

3.5.2 Plans for waste streams or individual companies

IndWMPs apply to a waste stream or an individual company.

A waste stream IndWMP applies to producers of products that result in a particular type of waste. Producers include importers of a product or product type. Examples of waste streams that would be considered for this type of plan include various types of batteries, waste tyres, residue pesticides and pesticide containers, paper and packaging, and various types of waste electric and electronic equipment (WEEE).

Individual company plans would apply to large companies that have multiple waste management activities that require licensing and / or comprise of multiple sites that have multiple licensing requirements. A company IndWMP can support multiple permit applications where waste management activities have been listed and must be licenced. The plans could also support a motivation to the Minister for listed waste management activities not to require a licence.

3.5.3 Content of IndWMPs

Section 30 of the Waste Act specifies the minimum requirements for a mandatory plan, but the Minister or MEC may include additional requirements. Elective plans should also provide at least the information stipulated in Section 30. DEA's Generic Guideline Document for Preparing Industry Waste Management Plans elaborates on the requirements for the different types of plan. The guideline emphasises that an IndWMP should support decisionmaking by generators of waste. The guideline reinforces the need for accurate information, including a detailed status quo analysis of the current waste management system, realistic targets for waste minimisation, milestone indicators with achievable time-frames for different interventions and sound record-keeping systems. The IndWMP must remain current through regular reviews and updates.

3.5.4 Preparation of plans

IndWMPs must be produced in a consultative manner in line with the directions given by the Minister or MEC, and the contents of a proposed IndWMP must be brought to the attention of relevant organs of state, interested persons and the public. Any comments submitted in respect of the IndWMP must be considered, and a copy of all comments received must be submitted with the proposed plan to the Minister or MEC.

On occasion the Minister or MEC may give directions that an independent person prepares an IndWMP for the cost of the persons or industry responsible for the waste-generating activities. The Minister or MEC will only invoke this measure if no representative body or structure is capable of preparing an IndWMP, or if the fragmented nature of an industry precludes the industry from agreeing on a suitable person to prepare the plan, or if the responsible party doesn't satisfactorily comply with an initial request.

The Minister may require that an organ of state, excluding a municipality, prepares an IndWMP, and similarly, the MEC may request that the provincial department responsible for environmental affairs prepare an IndWMP. Organs of state may be required to prepare an IndWMP where the industry is largely dominated by state owned entities, or the industry relates to defence of the state or deals with information that is deemed sensitive to the security of the state. The industry responsible for producing the waste must pay the cost of preparing the plan.

3.5.5 Approval of plans

On receipt of the plan the Minister or MEC may approve the plan with amendments, or require a revised plan or reject the plan with reasons48.

An approval must appear in the gazette and stipulate the period for which the approval applies. An approved plan prepared by an organ of state or provincial department must indicate in the gazette how and when the plan will be implemented.

If the Minister or MEC requests amendments and the person(s) preparing the plan do not meet these within the stipulated timeframes, it constitutes a failure to submit an IndWMP. The Minister or MEC will reconsider a plan if it is the first resubmission.

If the Minister or MEC rejects an IndWMP more than once, or if a person required to produce a plan fails to do so, then the Minister or MEC may specify the waste management measures that must be taken49, ensuring that the industry is not advantaged by the failure to submit an approved plan.

IndWMPs must be reviewed at intervals specified in the written approval or the gazette. IndWMP review periods will take into account the review periods of waste management licences.


  1. As per section 32 of the Waste Act.
  2. As per section 33(1) of the Act.