Over the past year our team has interviewed 50+ teams across Europe—internal ESG teams, sustainability consultants, property management firms, and waste suppliers—that all work with waste data. We wanted to figure out why everyone struggles with waste reporting. In this article, we break down what we have learned. Here are the top six challenges we have identified:

1. Multi-tenant buildings: "Shared containers. Shared confusion."

2. Compiling data from suppliers: "Who in the world has one single waste supplier?"

3. Managing waste code preferences: "Believe it or not, there are many types of paper."

4. Subcontractors and indirect client relations: "Wait… But I need their waste data too!"

5. Manual work deluxe: "Count up the hours. Every single hour."

6. Auditing: "Are these numbers even real…?"

Let’s start with the least obvious one first.

Reason #1: Shared containers. Shared confusion.

If your company is renting an office space, you’re going to have a hard time reporting waste accurately. A tenant in a multi-tenant building does not currently have any way to get accurate, weight-based reports about their waste. If they have Net Zero goals, or ISO14001 certification, that’s a problem. ESG teams in this situation are forced to come up with a solution. Who do they turn to? It’s not so straightforward.

The ESG team might ask their landlord. Unfortunately, their landlord often has no clue because they don’t have any staff on site. They simply own the building and manage the finances. The hire a property management firm to handle the on-site activities. So they ask the property management firm. Unfortunately, property managers rarely measure waste on site, and are themselves reliant on the reports they get from a waste management provider. So the ESG team turns to the waste management provider. But there’s a catch.

While some waste management providers have systems in place for weighing and reporting waste today, mainly the larger and more modern ones, multi-tenant buildings are still a unique challenge. That’s because all the tenants share containers. So if the waste suppliers send any waste reports, tenants only end up getting averages based on spend or square meters. Not so scientific unfortunately. (And so many middlemen!)

What we heard:

Some innovative waste management firms have identified this challenge, and are now trying to implement new solutions. Can waste pick-up crews visit the offices to measure waste? We’ve heard of tenants being unwilling to host garbagemen. Can they rearrange waste rooms in the building to separate tenants? Yes, but there’s an obvious cost-space trade-off. So far, there’s no winning solution.

As you might be able to guess, not all ESG teams are satisfied with spend-based estimates or averages. In fact, as legislation moves forward, we’ve discovered another approach that seems to be growing in popularity: asking the cleaning staff who handle the last-mile delivery of the waste. Can the cleaners help? Sometimes, actually.

In practice it could look a few different ways, but it wasn’t uncommon for the cleaning company to help out. Sometimes they were a part of the building’s property management firm. Sometimes, they are independent. In many cases it was better than nothing, but it had its flaws too.

What we heard:

We heard several ways companies approached weighing waste on site. Some cleaners weighed the waste in the kitchen and wrote paper notes that were then circulated around and turned into spreadsheets. Other times, they carried it to the bins outside where there was a floor scale. A much simpler alternative was simply tallying the number of garbage bags on a paper sheet tacked up to the wall. Every approach had a flaw: they were all prone to manual errors. None of these approaches were perfect, and the ESG teams and cleaning staff let us know. Numbers were easily misread. There was no evidence for any of the measurements. Staff had to manually create spreadsheets. Lots of emailing back and forth. So on and so forth.

As you will see in the next challenges, multi-tenant buildings encapsulate a lot of the challenges that waste reporting faces today. But these challenges are everywhere. Especially the next one.

Reason #2: Who in the world has one single waste supplier?

While many modern waste management firms have processes and equipment in place to measure and report waste to clients, the truth is that most companies don’t just have a single waste management partner. There are obviously many reasons for that.

In some countries, state-run waste management firms have a monopoly on certain waste fractions. In other cases, highly specialized waste management firms are needed for different geographic areas or industrial waste types. Regardless, as soon as a company employs more than one waste supplier, a new challenge emerges: ESG teams have the task of assembling all the reports they get!

What we heard:

During our interviews, we asked ESG teams how much time they spent arranging their waste supplier’s waste reports. We heard everything from a couple hours a quarter, to a full work day every quarter, to a full work week every year that could be spent arranging suppliers data. So, 8 – 40 hours a year. This is pure bookkeeping and administration that is adding no value to your company. Every ESG team admitted it’s not a very user-friendly experience, nor a valuable one.

Why is it like this? What’s so difficult about rearranging waste reports exactly? Well, it turns out that despite efforts from the EU and national governments to standardize waste reporting, each supplier still reports differently enough to make it difficult.

What we heard:

We had all sorts of confusing situations explained to us. Some waste suppliers manually send you spreadsheets with custom formatting and conventions. Some suppliers have invested in an online customer portal, where the formats vary. Sometimes the waste is measured every pick up, sometimes less often. Other suppliers don’t measure waste, and instead give you a monthly or quarterly estimate. We’ve even heard of waste suppliers changing waste codes from report to report. All of this adds complexity for the ESG team, who has to make sense of it all.

The job of the ESG analyst is to figure out how to present all this data and turn it into their own report. A big part of that challenge is simply figuring out how to organize the types of waste. You’d think waste codes would solve that. Think again.

Reason #3: Believe it or not, there are many types of paper.

Waste codes. What are they? Well, considering how easily they get mixed up in waste reporting, the answer could be that no one really knows.

As mentioned previously, the EU and national governments have made great efforts to standardize how waste is categorized. The European Waste Catalogue (EWC) is one of the most thorough examples of this, but other variations of waste classification systems exist around the world. While progress has certainly been made, it’s clear from our conversations that people are still confused. Why is that exactly? A few reasons actually.

The first reason is that diagnosing waste is complicated. The legislation itself leaves room for interpretation and professional judgement. When you’re creating the report, there are several parameters that could easily be judged differently, depending on the interests and preferences of the company reporting. That’s not to say they get it wrong. They might just simply be reporting the waste from a different perspective. Let's explain what this mean.

One key part of assessing which EWC code to use is to determine the business process that generated the waste. Was the waste created from manufacturing, service, cleaning, or demolition? You might see how different companies could answer differently. Confusingly, the answer changes the waste code. For instance, one example of EWC guidance suggests that for a waste type like Waste electrical and electronic equipment (WEEE), household WEEE should use chapter 20 “20 01 xx”, whereas WEEE from businesses should generally use “16 02 xx”. That means a residential real estate firm might report it differently than a waste management provider. Confusing.

Discrepancies can of course be due to making mistakes. If Company A’s waste has a hazardous substance in it, or is assumed/assessed to have one in it, and Company B has the same waste without a hazardous substance, or simply sees it differently, the code will differ. For example, soil/stones containing hazardous substances have a hazardous entry code “17 05 03*” vs the non-hazardous “mirror” entry “17 05 04”.

With the legislation leaving necessary room for professional judgement reason, it's also true that there will always be borderline cases, mixed waste streams, wastes whose nature changes in treatment. Because of this, two companies may simply interpret things differently. Or, one company may have more detailed characterization of the waste, leading them to use a more specific code rather than a generic “99” code. The other company may use a more general code. The “99” codes (“not otherwise specified”) are a known weak point, because they are less specific, and may allow more variation in how they’re used.

A final reason for waste code discrepancies is that each company is responsible for reporting the waste at their stage in the value chain. One company might report pre-treatment waste and another reports post-treatment waste. The codes then differ accordingly.

What we heard:

Waste suppliers largely follow their own company’s waste code preferences, and not their clients. This makes sense. A company’s waste management contract, internal procedures, or what their waste hauler accepts from their clients will determine how they code. In other words, the codes will align with the hauler’s permit. The end result is still that the task of checking waste codes, assigning waste codes, asking for clarification about the waste codes used is all left to the ESG team at the company reporting.

On top of all the reasons for confusing discrepancies, every company groups their waste codes differently for the purposes of analysis and year-end reporting. The waste supplier obviously does not have insight into their clients’ reporting preferences. Even if they used the right codes, which they often don’t, the codes aren’t grouped accordingly, adding to the workload of the ESG team.

Here’s where things get trippy. Consider the fact that every indirect customer also needs waste data. The waste code challenge doesn’t just get bigger. It gets exponentially bigger.

Reason #4: Wait… But I need their waste data too!

Companies share waste data amongst themselves. They have to. Every company has an intricate net of stakeholders that each have some of the waste data they need. This is of course one problematic aspect of the multi-tenant building situation. Waste suppliers send data to property management firms who send the data to tenants and landlords. But it’s not exclusively a challenge for this situation. The siloed waste data problem is everywhere.

What we heard:

A company that hired a construction firm will ultimately be required to report the waste the construction operation produces. But the construction firm doesn’t have their waste data because they don’t handle the waste management. They subcontract for that task. So now the original company is in a tricky spot: they aren’t a direct customer to the waste supplier, but they need access to whatever data is being supplied to the customer portal. And the construction company doesn’t have an easy way, or even an incentive, to help out. They also can’t export only the data relevant to the company. They would have to sort through it per site. The result is that the original company has no simple way to view the waste connected to their single site. They’re stuck, and left estimating with any numbers they can get their hands on.

Plus, there’s another problem here. As mentioned previously, each customer has their own waste code preferences. Each company’s contractors and subcontractors might apply their own codes to the reports, and along the way there appears to be a high chance of both double counting and gaps. Not to mention, a lot of manual work.

Which brings us to the next point.

Reason #5: Count up the hours. Every single hour.

As you might be able to tell by now, nearly nothing is automated in any of the scenarios described so far. Every step relies on either the ESG team, or the suppliers, emailing spreadsheets back and forth. Even in instances where data is uploaded to a customer portal, customers are required to download the waste data and adjust it themselves to fit their reporting preferences. How much time is spent on all this work?

If your own ESG team is struggling to report waste, or your company is the one supplying waste data to clients, you might want to evaluate how much time and money is spent on something that only amounts to acquiring data, not making strategic decisions based on that data.

Here are some questions to consider, based on common time-sinks we’ve heard so far:

1. How much time is spent measuring waste data, like collecting invoices, writing down weights, or double-checking scales? Map out the process from start to finish. You might be surprised what you find out.

2. How much time does it take to prepare one report for one client, and how often do you send that report? Be honest.

3. How much time do you spend chasing waste suppliers for data? There’s what you have agreed on paper, and there’s what you do in reality.

4. How often do you have a question about the waste reports? An email that you think takes 5 minutes, might actually take 45 minutes if you count the breaks and mental preparation too.

5. How quickly do you get an answer to the questions above? Some of the questions don’t have a quick answer. Time spent sitting around waiting for an answer is time wasted too.

6. How much time and money do you spend auditing your waste data? It might be an hour, or be a part of a more extensive consulting project to audit your corporation’s ESG report.

The last question, number six, leads us to the final challenge.

Reason #6: Are these numbers even real…?

It’s something we heard again and again. Since averages, estimates, and what can feel like hearsay are common, ESG teams just don’t often have a lot to work with. They have to do their best with what they’ve got. So, at the end of the day, when the company’s waste report is done and dusted, even they wonder: how much can we really trust these numbers?

What we heard:

A general skepticism about waste data was a common theme in every conversation. From skepticism about waste paper notes, to skepticism about the estimates they receive from waste management firms, every company indicated they didn’t fully trust the numbers. The waste industry isn’t as open and transparent as it could be, and most people working with waste data are well aware of that fact.

The validity of waste data is a universal problem that is not only recognized by ESG teams, but also by waste researchers around the world. And this problem undermines the overall purpose of tracking waste. If you can’t trust them, you can’t make real changes to your business based on those numbers.

At the end of the day, that is the real waste.

A wasted opportunity

Our team has learned all about these waste reporting challenges. We think there’s a better way to do it. We believe it should be easy for stakeholders to share waste data openly, and automate the boring stuff. We think that if we can save time doing the boring stuff, like simply sharing data and reporting it across your value chain, we can spend our time doing better things like improving data quality and improving your business’s bottom line with waste data. It's a real wasted opportunity. But you now have an opportunity to change that.

You're invited to be the change

If you recognize these six challenges and you want to participate in a project to develop a better way to report waste, we encourage you to reach out.

Our EU-based consulting team is developing a platform to share waste data, customize waste code preferences, and automate waste reporting so your teams can focus on what matters: making better decisions with the data. We want to offer stakeholders several simplified waste reporting tools, including tools to generate accurate tenant-level waste data. Our current focus is commercial real estate and multi-tenant buildings, but we invite all companies to reach out if you recognize the challenges described in this article. The first ten early adopters will gain access to benefits such as lifelong discounts and the ability to request product features tailored to your exact reporting needs.

If this sounds interesting, reach out today!