Head of practice
Attorney. Specialist in commercial and labor law. Over 16 years of experience in legal support of businesses - debt recovery, contract enforcement, recovery of damages, commercial property and lease disputes.
Permit documentation for scrap metal operations
Since 2015, with the adoption of the Law of Ukraine “On Licensing Certain Types of Economic Activities”, the obligation for business entities planning to engage in scrap metal operations to obtain a license has been abolished. At the same time, in contrast to and with the adoption of the Law of Ukraine “On Scrap Metal”, there has been a need to obtain a number of permits for such activities. In the article, we will examine this issue in more detail.
What scrap metal operations require obtaining permits?

The legislation of Ukraine establishes certain rules and restrictions on operations with scrap metal, which are as follows:
- collection of scrap metal (detection, inspection, removal of metal waste generated during the production process);
- processing of such waste (sorting, pressing, packaging, cutting, crushing, cleaning from contamination, as well as primary metallurgical processing to obtain finished metal products, primarily cast iron, steel, non-ferrous metals, etc.);
- storage of scrap metal (temporary placement at specially equipped sites);
- transportation and further sale (including export of such waste).
It is worth emphasizing that the Law of Ukraine “On Scrap Metal” also requires mandatory accounting of all operations with scrap metal, storage of documentation confirming its origin, compliance with radiation safety requirements and environmental standards. More information can be found within the framework of a legal consultation with one of the specialists of our law firm.
What requirements must a company meet to obtain a permit to carry out operations with scrap metal?
The main requirements for such companies are:
- firstly, the presence of the status of a specialized metallurgical processing enterprise;
- secondly, an appropriate material and technical base (must have their own or rented land plot with a hard surface, the area of which is determined taking into account production needs; a container for storing waste without the penetration of harmful substances into the soil; equipment and a specially equipped room with a video surveillance and archiving system);
- thirdly, a minimum number of qualified specialists (must have employees who have the necessary knowledge and skills to carry out operations with scrap metal);
- fourthly, a system for ensuring control over explosion, fire, environmental and radiation safety in accordance with the requirements of current national legislation.
Let us dwell in more detail on the equipment for carrying out the necessary operations. In particular, the list of necessary equipment and facilities for specialized enterprises was approved by Order No. 524 of the Ministry of Economic Development and Trade of Ukraine dated March 29, 2016. It should be understood as:
- scrap processing equipment;
- lifting mechanisms;
- compartments for separate storage;
- measuring equipment for tracking the level of radiation contamination.
How to obtain the status of a specialized metallurgical processing enterprise?
To obtain the specified status of a company, you need to go through a procedure in several stages.
First, familiarize yourself with the requirements for such an enterprise in the legislation. To do this, you need to analyze the Law of Ukraine “On Scrap Metal” and other regulatory legal acts that determine the basic requirements for the material and technical base of the enterprise. Our lawyers can also help with this as part of the legal support service for business.
Secondly, prepare a number of documents for the competent authority to confirm compliance with all criteria. Such documents will be an extract from the Unified State Register of Legal Entities on state registration of a legal entity and the selected KVED (38.32, 24.10, etc.), certificates of ownership of real estate, lease agreements, equipment descriptions, certificates of verification or certificates of conformity of equipment, staffing lists, contracts with accredited laboratories for radiation control, etc.
Third, obtain an inspection certificate from the local state administration on compliance with the requirements.
What other documents do you need to prepare for scrap metal operations?
Along with the inspection report, the company must separately obtain a permit to perform high-risk work and to operate high-risk equipment. Such a document is issued by the State Labor Service and confirms the right of the enterprise to begin work.
Thus, the legislation establishes clear requirements and the need to obtain permits for scrap metal operations: collection, processing, storage, transportation and sale of relevant waste. Such documents include an inspection report on the company’s compliance with the status of a specialized metallurgical processing enterprise and a permit from the State Labor Service to perform hazardous work.
The process of obtaining permits for scrap metal operations includes familiarization with legislative requirements, preparation of the necessary package of documents and passing the examination. Lawyers of “Prikhodko and Partners” provide professional assistance at every stage of the procedure. To find out the cost of legal support, fill out the form below.
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