GRI 306 Waste (2020 Update)
The 2020 revision of GRI 306 significantly overhauled waste reporting — introducing the waste diverted from disposal vs directed to disposal framework and requiring lifecycle thinking about waste generation. Companies that previously reported under GRI 306 (2016) need to understand what changed and how to transition.
The 2020 revision of GRI 306 significantly overhauled waste reporting — introducing the waste diverted from disposal vs directed to disposal framework and requiring lifecycle thinking about waste generation. The 2020 GRI 306 revision replaced the 2016 version with a fundamentally different structure.
What changed in the 2020 revision
The 2020 GRI 306 revision replaced the 2016 version with a fundamentally different structure. The 2016 standard focused on total waste by disposal method. The 2020 standard introduces a two-category framework:
Waste diverted from disposal: Waste that is prevented from going to disposal — through recycling, reuse, composting, recovery, and other recovery operations. This is the 'good' waste stream — value is extracted rather than destroyed.
Waste directed to disposal: Waste that ends up in landfill, incineration, or other final disposal. This is the 'bad' waste stream — value is lost and environmental harm occurs.
The new structure also introduces enhanced requirements:
306-1 Waste generation and significant waste-related impacts: Qualitative description of significant waste impacts — this is new context-setting disclosure absent from the 2016 standard.
306-2 Management of significant waste-related impacts: Description of management approach — also new in 2020.
306-3 Waste generated: Total waste by type — hazardous and non-hazardous; and by composition where significant (food waste, electronic waste, plastic, metal, paper/cardboard, glass, other).
306-4 Waste diverted from disposal: Total by recovery operation — reuse, recycling, composting, other recovery; split between on-site and off-site treatment; and split between hazardous and non-hazardous.
306-5 Waste directed to disposal: Total by disposal operation — landfill, incineration with energy recovery, incineration without energy recovery, other; split between on-site and off-site; and split between hazardous and non-hazardous.
Transitioning from GRI 306 (2016) to GRI 306 (2020)
Companies that reported under GRI 306 (2016) cannot directly compare prior year data with 2020-compliant current year data — the frameworks are sufficiently different that meaningful comparison requires restated comparative data.
What was lost in the transition: The 2016 standard's simple table of total waste by disposal method (recycled, reused, composted, recovered, incinerated, landfilled, other) is replaced by the more complex 2020 framework. The 2016 data can be partially mapped to 2020 categories but not precisely — the methodologies are different.
Recommended approach for transition year: Report current year under 2020 standard fully. Provide prior year data under 2016 format as a reference, clearly labelled as under the old standard. Note that direct year-on-year comparison is not meaningful due to methodology change. In year 2+ under 2020 standard, provide restated prior year comparative under 2020 methodology.
For companies using ESRS E5: the ESRS E5-5 resource outflows waste disclosure aligns with GRI 306 (2020) framework — waste diverted from disposal and waste directed to disposal are the same categories. Collecting ESRS E5-5 data satisfies GRI 306 (2020) with the same data collection effort. Implement the 2020 standard as part of your ESRS data collection infrastructure.
Key calculation points for GRI 306 (2020)
Determining diverted vs directed: The classification depends on the waste's final destination — not the intermediate step. Waste collected for recycling but then contaminated and sent to landfill by the recycler is directed to disposal (landfill), not diverted from disposal (recycling). Use waste contractor confirmation of actual disposal route, not assumed destination.
On-site vs off-site: 306-4 and 306-5 require splitting waste by on-site and off-site treatment. On-site treatment is waste processed within your own operational boundary (composting, on-site recycling, on-site energy recovery). Off-site is waste sent to external treatment facilities — the typical case for most companies. Most companies will report minimal on-site and predominantly off-site figures.
Hazardous waste classification: Use jurisdiction-specific hazardous waste definitions — EU Waste Framework Directive list of hazardous waste properties, US EPA hazardous waste criteria, or equivalent national standard. Classify waste as hazardous if it meets any hazardous property criterion — not only if it is regulated as such. Some jurisdictions have varying thresholds; use the most conservative applicable definition.
Composition disclosure: 306-3 requires composition breakdown where significant — GRI does not mandate composition disclosure for all waste but expects it where specific waste types are particularly important for understanding your environmental impact. For a food company, food waste composition is significant. For an electronics manufacturer, WEEE composition is significant. For an office-based company, paper/cardboard and electronic waste are the most significant categories.
Frequently asked questions
Does GRI 306 (2020) require waste intensity metrics?
Not explicitly — GRI 306 (2020) does not mandate a waste intensity ratio like GRI 302 requires energy intensity. However, providing waste per unit of production or per revenue is considered good practice context — particularly for manufacturing companies where absolute waste is heavily influenced by production volume. ESRS E5 also does not mandate intensity — but industry peers increasingly report it.
How do we handle waste from construction projects and office fit-outs?
Construction and demolition waste from your own projects is included in GRI 306-3 waste generated. Report total tonnes with composition breakdown (concrete, wood, plasterboard, metal, mixed). For large fit-out projects, construction waste can temporarily significantly increase reported waste volumes — contextualise year-on-year changes with reference to one-off construction activities.
We are a service company — do we have material waste to report?
More than expected — office paper, IT hardware (WEEE), food waste from staff canteens, and packaging from purchased goods all represent waste streams. WEEE from regular hardware refresh cycles is frequently underestimated — a company of 500 employees replacing laptops every 4 years generates approximately 1–2 tonnes of WEEE annually. Conduct a waste audit before concluding materiality is low.