This year, the Environmental Company of the State of São Paulo (CETESB) issued Board Decision No. 020/2025/C, amending the regulatory framework regarding the movement of environmentally relevant waste within the State of São Paulo, which must be subject to prior authorization from CETESB. The decision updates the criteria for requiring the Certificate for the Movement of Environmentally Relevant Waste (CADRI, in Portuguese), establishes specific rules for its collective modality, and introduces new mechanisms.
What is CADRI?
The CADRI – acronym of Certificate of Approval for the Disposal of Industrial Waste – is a document issued by CETESB authorizing the transfer of environmentally relevant waste from the generator to external facilities for energy recovery, treatment, reuse, recycling, or disposal.
It ensures that waste is managed in an ecologically sound manner by duly licensed companies, serving as a precautionary measure to avoid penalties resulting from mismanaged waste.
The list of environmentally relevant waste can be consulted in the Annex to the Decision
Key Changes
Previously, the CADRI was required for the movement of all environmentally relevant waste within the State of São Paulo, regardless of which licensing agency the generator was subject to. Following the publication of Board Decision No. 020/2025/C, the CADRI will only encompass generators licensed by CETESB (Article No. 3).
Paragraph 5 of Article 3 clarifies that CADRIs will not be issued to generators licensed exclusively by municipalities. This aligns with CONSEMA Normative Resolution No. 01/2024, which accredits municipalities to conduct local environmental licensing (for further details, see our previous publication on the topic). The exception, set forth in Article 3, §4, applies to contaminated soils and healthcare waste, which remain subject to CADRI requirements when destined for facilities licensed to manage hazardous waste.
Another important alteration appears in §§1 and 2 of Article 3, which prohibit the issuance of CADRIs for the transport of waste between transfer stations, since transfer operations are deemed as purely logistical and do not constitute a stage of treatment or disposal. Once waste reaches a transfer station, the respective CADRI must indicate solely the final recipient.
The regulation of collective CADRIs is among the most impactful changes. This modality applies when the same category of waste is generated in small quantities by multiple companies within the same sector, provided it is collected by a licensed transporter. According to Article 4, §§1–3, a maximum of 50 individual generators may participate in a single application, with waste compositions limited at 20 kg per day or 7.3 tons per year. The licensed recipient facility must submit the application, including the Operating Licenses of all participating generators.
In cases of improper disposal, waste seized or collected by public authorities will not be subject to CADRI (Art. 3, §3) if the responsible party cannot be identified. However, its ultimate destination will be determined by CETESB.
The Technical Assessment – Authorization for Receiving Environmentally Relevant Waste from Other States (Art. 5) will be mandatory in all interstate waste transfer cases involving activities subject to CETESB’s environmental licensing, reinforcing control over the interstate transport of waste, in accordance with Article 25 of the National Solid Waste Policy (Federal Law No. 12.305/2010).
Through a Technical Guideline, CETESB clarified that licensed facilities may receive waste from activities not subject to the agency’s licensing without requiring CADRI. In such cases, however, compliance with the State’s Solid Waste Management Online System (SIGOR) – particularly regarding the Waste Transport Manifest (Manifesto de Transporte de Resíduos – MTR, in Portuguese) – remains mandatory.
Failure to comply with these regulations may constitute an environmental infraction, subjecting the responsible party to the penalties provided in the Environmental Crimes Law (Federal Law No. 9.605/1998) and in Federal Decree No. 6.514/2008, without prejudice to civil and criminal liability for environmental damage.