New Rules for Waste with Unidentified Owners: What Has Changed and Why It Matters

Ukraine has introduced a new procedure for identifying and registering waste whose owner cannot be established. The changes were adopted by the Cabinet of Ministers of Ukraine through Resolution No. 903 of 1 July 2026, "On Certain Issues of Identification and Registration of Waste with Unidentified Owners."

The new regulation represents a significant shift in how illegally dumped waste is addressed. Instead of focusing solely on cleaning up waste, the procedure establishes a comprehensive framework for identifying where the waste came from, determining who is responsible, and ensuring that it is managed in line with the "polluter pays" principle.

From "Ownerless Waste" to Identifying Responsibility

One of the most important changes is the replacement of the concept of "ownerless waste" with "waste whose owner has not been identified."

This distinction is more than just a change in terminology. It reflects the understanding that waste should not automatically be treated as having no owner simply because the responsible party is initially unknown. Instead, public authorities are now expected to actively investigate who generated the waste.

Evidence such as photographs, video recordings, transport information, packaging, documents, and reports from citizens may all be used to identify the responsible person or company.

If the polluter is identified, they will be required to reimburse the costs of locating, collecting, transporting, and treating the waste, as well as compensate for any environmental damage caused.

A Clear Procedure for Responding to Illegal Dumping

The new rules establish a structured process for responding to illegally disposed waste:

Responsibilities are also more clearly divided. Local governments will manage cases within settlements, while regional and other competent state authorities will be responsible for waste found outside populated areas. This should reduce uncertainty over which authority is responsible for taking action.

Better Documentation Means Better Enforcement

A key feature of the new procedure is mandatory documentation of every identified waste site. Authorities must prepare a formal inspection report that will serve as the basis for further actions, including investigations, laboratory testing, cost calculations, and, where appropriate, legal proceedings.

In practice, this means that properly documenting evidence will become increasingly important. Photographs, vehicle registration numbers, packaging labels, transport records, and other evidence may all help identify those responsible for illegal dumping.

Why Laboratory Testing Matters

The new procedure also allows authorities to finance and carry out laboratory testing of waste, soil, water, and air where environmental contamination is suspected. This will make it easier to determine the nature and potential hazards of waste, select appropriate treatment methods, and build stronger evidence for enforcement actions.

At the same time, successful implementation will depend on the availability of accredited laboratories, qualified experts, and sufficient financial resources.

Digital Records for Greater Transparency

Another important innovation is the introduction of electronic registration through Ukraine's Waste Management Information System. A nationwide digital database will allow to monitor where illegal dumping occurs, estimate waste volumes, track investigations, record clean-up measures, and monitor public spending. In the long term, these data should support better environmental planning, more informed decision-making, and stronger oversight of waste management across the country.

Key Benefits of the New Legislation

The new procedure has the potential to deliver several important improvements:

• a single, nationwide approach to dealing with illegally disposed waste;

• stronger prospects for identifying those responsible;

• improved use of laboratory evidence during investigations;

• greater transparency through digital reporting and record-keeping;

• closer cooperation between local authorities, environmental inspectors, law enforcement, and civil society;

• further implementation of the "polluter pays" principle, ensuring that those responsible bear the costs of environmental damage.

Challenges Ahead

While the new framework is a positive step forward, its success will ultimately depend on effective implementation. Many municipalities may face practical challenges, including limited funding, shortages of qualified personnel, and insufficient technical capacity to carry out inspections, laboratory analyses, and clean-up operations.

There is also a risk that the system could become overly administrative, with waste sites being recorded in the database without being removed in practice. Success should therefore be measured not only by the number of registered sites, but also by how many are actually cleaned up and how often those responsible are identified and held accountable.

The Role of Civil Society

The new rules also create more opportunities for citizens and civil society organisations to contribute to environmental protection. Members of the public can report illegal dumping, provide photographic or video evidence, monitor clean-up activities, and support public oversight of waste management.

At Foundation for Change, we will continue working to promote effective waste management in Ukraine, support the implementation of European environmental standards, and help ensure that legislative reforms translate into meaningful improvements for communities and the environment.