Clear Carbon - Enterprise Environmental Management Platform

When must NPI transfers be reported?

Clause 9(1)(f) of the NPI NEPM requires mandatory transfer data for each substance whose Category 1, 1b or 3 threshold is exceeded. Category 1a (TVOC) and the combustion categories 2a and 2b do not trigger transfer reporting on their own.

Key points

  1. Triggered by Category 1, 1b or 3 thresholds
  2. Category 2a and 2b substances alone do not need transfer reports
  3. Voluntary transfers, such as recycling, are optional
  4. Overburden, waste rock and uncontaminated soil are excluded
  5. Material contained on site for a full year is a mandatory transfer

Mandatory and voluntary transfers

Mandatory transfers go to places of final disposal: landfill, tailings storage, underground injection or other long-term containment, off-site destruction, an off-site sewerage system, or off-site treatment leading only to one of these. Voluntary transfers go to reuse, recycling, reprocessing, purification, immobilisation, remediation or energy recovery. A voluntary transfer report must be covered by the due diligence statement.

What is not a transfer

The NPI Guide excludes overburden, waste rock, uncontaminated soil, material removed in construction or road building, soil used to cap landfill, domestic sewage from on-site amenities, and general refuse.

On-site containment

Material held in on-site containment for a full reporting year is reported as a mandatory transfer, even if it is later reused. A tailings storage facility is treated as part of the facility whose waste it receives.

How transfers are estimated

Transfers are estimated using transfer estimation techniques and transfer factors, the transfer equivalents of emission estimation techniques and emission factors. The methods are set out in the industry reporting materials, including DCCEEW’s transfers information booklet.

Common examples

Waste sent off site to landfill, liquid waste discharged to an off-site sewer, and tailings pumped to a tailings storage facility are all mandatory transfers. Scrap sent for recycling or solvent sent for recovery are voluntary transfers.

Transfer data is published alongside each facility’s emissions in the NPI database, and as its own file in the data.gov.au download.

Why it matters

A facility that trips only a combustion threshold does not need to report transfers, while one that uses 10 tonnes of a Category 1 substance must report transfers of that substance to mandatory destinations. Getting the trigger right avoids both under-reporting and unnecessary work.

References & sources

Primary regulatory documents and authoritative references underpinning this answer.

  1. DCCEEW: Transfers of NPI substances in waste, frequently asked questionsdcceew.gov.au
  2. DCCEEW: National Pollutant Inventory Guide (Version 6.1)dcceew.gov.au
  3. National Environment Protection (National Pollutant Inventory) Measure 1998legislation.gov.au