EWC chapter 04: leather, fur and textile waste codes explained

Last updated 21 October 2026

In short

EWC chapter 04 covers wastes from the leather and fur industry (04 01) and the textile industry (04 02). It contains 21 codes across 2 subcategories, of which 4 are hazardous. In the leather subcategory only degreasing wastes containing solvents (04 01 03*) are absolute hazardous; chrome-tanning liquors and sludges are not automatically hazardous. In textiles, three mirror-entry pairs determine hazardous status: finishing wastes with organic solvents (04 02 14*), dyestuffs containing dangerous substances (04 02 16*), and effluent sludges containing dangerous substances (04 02 19*).

Tanneries, textile mills, dye houses and laundries produce a range of waste streams — from chrome-containing tanning sludge to solvent-based finishing residues. Classifying these correctly matters: the chromium-containing codes in the leather subcategory are not asterisked, while three mirror pairs in the textile subcategory hinge on whether dangerous substances are present above hazardous thresholds.

What is EWC chapter 04?

EWC chapter 04 covers wastes from the leather and fur industry (04 01) and the textile industry (04 02). It contains 21 codes across 2 subcategories, of which 4 are hazardous.

The chapter covers the industrial processing end — waste residues from tanning hides, finishing leather goods, dyeing and weaving textiles, and treating fabrics at mills and dye houses. It does not cover mixed clothing or textile waste from households or commercial clearances; those fall under EWC chapter 20 (20 01 10 for clothing, 20 01 11 for textiles).

Subcategory 04 01 covers the leather and fur industry: liming, tanning, degreasing and finishing processes at tanneries and fur dressers. Subcategory 04 02 covers the textile industry: weaving, dyeing, finishing, and on-site effluent treatment at mills and dye houses.

What subcategories and codes does chapter 04 contain?

The table below covers all 21 codes across the two subcategories, showing which are hazardous (marked with *) and what each covers.

EWC chapter 04 — all codes
EWC codeDescriptionHazardous?
04 01 01Fleshings and lime split wastesNo
04 01 02Liming wasteNo
04 01 03*Degreasing wastes containing solvents without a liquid phaseYes *
04 01 04Tanning liquor containing chromiumNo
04 01 05Tanning liquor free of chromiumNo
04 01 06Sludges, in particular from on-site effluent treatment, containing chromiumNo
04 01 07Sludges, in particular from on-site effluent treatment, free of chromiumNo
04 01 08Tanned leather waste (including shavings, trimmings, buffing dust) containing chromiumNo
04 01 09Wastes from dressing and finishingNo
04 01 99Wastes not otherwise specifiedNo
04 02 09Wastes from composite materials (impregnated textile, elastomer, plastomer)No
04 02 10Organic matter from natural products (e.g. grease, wax)No
04 02 14*Wastes from finishing containing organic solventsYes *
04 02 15Wastes from finishing other than those mentioned in 04 02 14No
04 02 16*Dyestuffs and pigments containing dangerous substancesYes *
04 02 17Dyestuffs and pigments other than those mentioned in 04 02 16No
04 02 19*Sludges from on-site effluent treatment containing dangerous substancesYes *
04 02 20Sludges from on-site effluent treatment other than those mentioned in 04 02 19No
04 02 21Wastes from unprocessed textile fibresNo
04 02 22Wastes from processed textile fibresNo
04 02 99Wastes not otherwise specifiedNo

EWC chapter 04 contains 21 codes across 2 subcategories. Four are hazardous: one absolute hazardous entry in 04 01 (degreasing waste 04 01 03*) and three mirror-entry pairs in 04 02 (finishing 04 02 14*/15, dyestuffs 04 02 16*/17, effluent sludge 04 02 19*/20). The chromium-containing codes in 04 01 (04 01 04, 04 01 06, 04 01 08) are not asterisked and require a classification assessment.

Is tanning waste containing chromium automatically hazardous?

No. The three chromium-containing codes in subcategory 04 01 — tanning liquor (04 01 04), on-site sludge (04 01 06) and tanned leather waste (04 01 08) — are not asterisked entries. Whether the waste is hazardous depends on a classification assessment for the specific chromium compound and concentration present.

Standard chrome tanning uses trivalent chromium (Cr³⁺), which is significantly less toxic than hexavalent chromium (Cr⁶⁺). Tanning liquors and sludges from a well-controlled chrome tanning process do not automatically trigger hazardous waste status. The producer must assess whether the waste exceeds hazardous thresholds before classifying it as non-hazardous.

The paired “free of chromium” codes (04 01 05 and 04 01 07) are not the hazardous mirror entries for 04 01 04 and 04 01 06 — they describe a different process (vegetable or synthetic tanning without chromium). Neither pair is an asterisk mirror pair in the EWC hazardous waste sense; both sides require their own classification assessment.

Chromium-containing vs chromium-free codes in 04 01
EWC codeDescriptionHazardous by default?
04 01 04Tanning liquor containing chromiumNo — requires classification assessment
04 01 05Tanning liquor free of chromiumNo — requires classification assessment
04 01 06Sludge from on-site effluent treatment, containing chromiumNo — requires classification assessment
04 01 07Sludge from on-site effluent treatment, free of chromiumNo — requires classification assessment
04 01 08Tanned leather waste (shavings, trimmings, buffing dust) containing chromiumNo — requires classification assessment

What is 04 01 03* — degreasing waste from the leather industry?

04 01 03* covers degreasing wastes containing solvents without a liquid phase — the solid or semi-solid residues remaining after organic solvents used to degrease hides have evaporated or been absorbed. This is an absolute hazardous entry with no non-hazardous mirror pair.

Some tanneries degrease sheepskins or pig hides using organic solvents. The spent residue — contaminated solid material with no free liquid solvent remaining — is classified as 04 01 03*. It requires a hazardous waste consignment note for every movement, an upper-tier registered carrier, and records retained for at least 3 years. There is no equivalent non-hazardous code for solvent-based degreasing waste.

What are the mirror entry pairs in subcategory 04 02?

Subcategory 04 02 contains three mirror-entry pairs where hazardous status depends on whether dangerous substances are present: finishing waste (04 02 14*/15), dyestuffs and pigments (04 02 16*/17), and on-site effluent sludges (04 02 19*/20).

For each pair, the producer must assess whether the specific substances present — solvents, reactive dyes, heavy-metal pigments, biocides — meet hazardous waste classification thresholds. The classification cannot be assumed from the code description alone.

Mirror entry pairs in EWC subcategory 04 02
Hazardous codeNon-hazardous codeKey classification question
04 02 14*04 02 15Does the finishing waste contain organic solvents above hazardous thresholds?
04 02 16*04 02 17Do the dyestuffs or pigments contain dangerous substances above threshold concentrations?
04 02 19*04 02 20Does the on-site effluent sludge contain dangerous substances above threshold concentrations?

A dye house using only reactive dyes free of heavy metals or restricted biocides may be able to classify its dyestuff waste as 04 02 17 (non-hazardous) following a proper assessment. A facility using disperse dyes containing azo compounds or heavy-metal complex dyes will likely need to classify the waste as 04 02 16* (hazardous). The classification obligation rests with the waste producer.

What records do chapter 04 hazardous codes require?

The four hazardous codes in chapter 04 (04 01 03*, 04 02 14*, 04 02 16*, 04 02 19*) all require a hazardous waste consignment note, an upper-tier registered waste carrier, and records kept for at least 3 years.

The non-hazardous codes require a standard waste transfer note (WTN) retained for at least 2 years.

Document and retention requirements — chapter 04 leather & textile waste
Code typeDocument requiredCarrier tierRetention
Hazardous (04 01 03*, 04 02 14*, 04 02 16*, 04 02 19*)Hazardous waste consignment noteUpper-tier only3 years minimum
Non-hazardous (all other chapter 04 codes)Standard waste transfer note (WTN)Upper or lower tier2 years minimum

Which chapter covers household and commercial clothing waste?

Clothing and textile waste from households, charity collections, shops or clearances is classified under EWC chapter 20 — not chapter 04. Chapter 04 applies only to waste from industrial textile manufacturing processes.
  • Textile mill processing waste (dye sludge, fibre off-cuts) = chapter 04 (04 02 codes)
  • Leather tannery residues = chapter 04 (04 01 codes)
  • Clothing collected for reuse or recycling = 20 01 10 (clothing)
  • Mixed textiles from households or commercial premises = 20 01 11 (textiles)
  • Leather or plastic offcuts from shoe or bag manufacture = 04 01 codes if the leather is involved; assess other trim waste against chapter 12 or chapter 07 if it arises from a chemical process

This guide is general information about EWC waste codes, not legal advice. Check your specific classification obligations against the primary sources below and, if in doubt, contact the Environment Agency, SEPA, NRW or NIEA for your nation.

Frequently asked questions

What is EWC chapter 04?
EWC chapter 04 covers wastes from the leather and fur industry (subcategory 04 01) and the textile industry (subcategory 04 02). It contains 21 codes across 2 subcategories, of which 4 are hazardous.
Is chrome tanning waste hazardous?
Not automatically. Tanning liquor containing chromium (04 01 04) and sludge containing chromium (04 01 06) are not asterisked EWC codes — they are not hazardous by definition. Whether the waste is hazardous depends on a classification assessment against hazardous waste thresholds for the specific chromium compound and concentration. Trivalent chromium (Cr3+), used in standard tanning, does not automatically make tannery waste hazardous.
What is the hazardous degreasing waste code for the leather industry?
04 01 03* — degreasing wastes containing solvents without a liquid phase. This is an absolute hazardous entry with no non-hazardous mirror pair. It arises at tanneries where hides are degreased using organic solvents and the solvent has evaporated or been absorbed into residual solids.
What EWC codes apply to dyestuff waste from textile manufacturing?
Dyestuff and pigment wastes from the textile industry use a mirror pair: 04 02 16* (dyestuffs and pigments containing dangerous substances — hazardous) and 04 02 17 (dyestuffs and pigments other than those in 04 02 16 — non-hazardous). Classification depends on whether the specific dyes or pigments used contain substances that meet hazardous waste thresholds.
What is the difference between 04 02 21 and 04 02 22?
04 02 21 covers wastes from unprocessed textile fibres — raw fibre before any treatment, dyeing or finishing. 04 02 22 covers wastes from processed textile fibres — fibre that has been treated, dyed or finished. Both are non-hazardous codes; whether the waste is actually hazardous depends on a classification assessment for any substances applied during processing.

Related guides

This guide is general information from ComplyWaste, not legal advice. Always check the primary sources for your situation.