Scheduled Waste Management Malaysia: DOE Requirements, eSWIS & Factory Compliance Guide

Disclaimer: This article provides general guidance based on the Environmental Quality Act 1974, Environmental Quality (Scheduled Wastes) Regulations 2005, and official DOE information as of February 2026. Regulations may be amended. Always verify current requirements with the Department of Environment (DOE) or qualified professionals before making compliance decisions.

Malaysia classifies 77 types of hazardous waste as "scheduled waste" under the Environmental Quality (Scheduled Wastes) Regulations 2005. Every factory, workshop, and facility that generates these wastes must follow strict DOE rules for storage, labeling, transportation, and disposal.

Get any of these wrong and you face fines up to RM10 million and mandatory imprisonment under the Environmental Quality (Amendment) Act 2024.

This guide covers:

• All 5 scheduled waste categories and SW code classification
• Storage requirements: the 180-day and 20 metric tonne limits
• Labeling, packaging, and incompatible waste segregation rules
• eSWIS v2 consignment note process step by step
• Licensed treatment and disposal options
• Updated penalties under the EQA Amendment 2024
• Complete compliance checklist for factory operators

What Is Scheduled Waste in Malaysia?

Scheduled waste is any waste listed in the First Schedule of the Environmental Quality (Scheduled Wastes) Regulations 2005. These are wastes with hazardous characteristics: toxic, flammable, corrosive, reactive, or infectious. The Department of Environment (DOE) regulates their entire lifecycle from generation to final disposal.

The legal framework sits under the Environmental Quality Act 1974 (Act 127), with the 2005 Regulations providing operational requirements. The Environmental Quality (Amendment) Act 2024, effective 7 July 2024, significantly increased penalties for non-compliance.

If your facility generates any of the 77 scheduled waste types, you are a "waste generator" with legal obligations under Regulation 8. You must notify DOE within 30 days of generating a new category of scheduled waste.

Scheduled Waste Categories and SW Codes

Malaysia organises 77 scheduled waste types into 5 series. Each waste type has a unique SW code that you must use on labels, inventory records, and eSWIS registration documents.

Series	Category	Code Range	Common Examples
SW1	Metal and Metal-Bearing Waste	SW101 - SW110	Lead-acid batteries, e-waste, mercury-containing items, arsenic waste
SW2	Inorganic Constituents	SW201 - SW207	Asbestos waste, spent catalysts, metal hydroxide sludges, spent acids
SW3	Organic Constituents	SW301 - SW327	Spent oils, used solvents, PCB waste, thermal fluids, paint sludge
SW4	Mixed Inorganic/Organic	SW401 - SW432	Clinical waste, pharmaceutical waste, cyanide sludges, explosives residue
SW5	Other Wastes	SW501	Residues from treatment or recovery of scheduled waste

How to Identify Your Waste's SW Code

Correct classification is the foundation of compliance. Assigning the wrong SW code can invalidate your consignment notes and trigger enforcement action.

Step	Action	Details
1	Collect waste description	Source process, raw materials used, Safety Data Sheets (SDS)
2	Cross-reference First Schedule	Match waste against the 77 types in the 2005 Regulations
3	Analyse properties	Physical state, chemical composition, pH, flash point
4	Assess hazard characteristics	Corrosivity, flammability, toxicity, reactivity, infectiousness
5	Laboratory analysis (if unclear)	TCLP testing, composition analysis by accredited lab
6	Assign SW code	Record in eSWIS inventory with supporting documentation

Who Must Comply with Scheduled Waste Regulations?

Three groups have legal obligations under the 2005 Regulations. Each has distinct responsibilities, and failure by any party in the chain creates liability for all.

Party	Legal Basis	Key Obligations
Waste Generators	Regulation 8	Notify DOE within 30 days, classify waste, store properly, maintain inventory, arrange licensed disposal
Licensed Transporters	Section 18(1A) EQA, Regulation 13	Hold DOE transporter license, use approved vehicles, carry Seventh Schedule documentation, avoid sensitive areas
Treatment/Disposal Facilities	Section 18(1) EQA	Hold DOE facility license, accept waste only from licensed transporters, verify consignment notes, complete eSWIS records

Industries that commonly generate scheduled waste include manufacturing (spent oils, solvents, metal sludges), construction (paint waste, asbestos), electronics (e-waste, etching solutions), healthcare (clinical waste), and oil and gas (drilling muds, contaminated materials). If you operate a manufacturing facility, scheduled waste compliance is not optional.

Storage Requirements: The 180-Day Rule

Regulation 9 sets two hard limits on on-site storage. Break either one without DOE approval and you are in violation.

Limit	Threshold	What Happens If Exceeded
Time	180 days from generation date	Must obtain written DOE approval or face enforcement
Quantity	20 metric tonnes on-site	Must obtain written DOE approval or arrange immediate disposal

Storage Area Design Standards

Your scheduled waste storage area is not just a corner of the warehouse. DOE expects purpose-built infrastructure that prevents leaks, spills, and contamination.

Requirement	Specification
Flooring	Concrete, free of cracks and gaps, impervious to chemicals
Secondary containment	Concrete dikes with 110% capacity of the largest container stored
Drainage	Sump system; no direct discharge to drains or waterways
Shelter	Roofing to protect containers from rain and direct sunlight
Signage	"DANGER: SCHEDULED WASTES STORAGE" warning signs visible from all approaches
Fencing	Restricted access; locked when unattended
Fire protection	Appropriate extinguishers and sprinkler systems for waste types stored
Segregation	Separate compartments for incompatible waste types (see Fourth Schedule)
Location	Away from production areas, employee zones, and flood-prone areas

The catch? Many factories treat the storage area as an afterthought. During DOE inspections, storage area deficiencies are among the most common findings. Cracked flooring, missing bunding, and overflowing sumps are red flags that trigger enforcement.

Labeling and Packaging Requirements

Regulation 10 requires every container of scheduled waste to carry a label with specific information. Missing or illegible labels are a common audit finding.

Mandatory Label Information

Label Element	Details
Date of generation	The date the waste was produced (starts the 180-day clock)
Generator name	Registered company name
Address	Facility address where waste was generated
Telephone number	Emergency contact for the waste generator
SW code	Correct code from the First Schedule
Hazard symbol	Per Third Schedule (11 label types); multiple labels if waste has multiple hazards

Label specifications: Minimum 10 cm x 10 cm, placed at 45-degree angle for visibility, weather-resistant, and legible at all times. If a container holds waste with multiple hazardous properties, you need multiple hazard labels.

The 11 Hazard Label Types (Third Schedule)

Label No.	Hazard Type	Background Colour
1	Explosive Substances	Light orange
2	Inflammable Liquids	Red
3	Inflammable Solids	White with vertical red stripes
4	Spontaneously Combustible Solids	Upper white / lower red
5	Solids Dangerous When Wet	Blue
6	Oxidizing Substances	Yellow
7	Organic Peroxides	Yellow
8	Toxic Substances	White
9	Infectious Substances	White
10	Corrosive Substances	Upper white / lower black
11	Miscellaneous Dangerous Substances	White with vertical black stripes

Container Selection by Waste Type

The container must be chemically compatible with the waste inside. Using the wrong container type can cause leaks, reactions, or container failure.

Container Type	Suitable For	Condition Requirements
Bunghole drums (steel/plastic)	Liquid waste	No holes, dents, or corrosion
Open top drums	Solid waste, sludge	Sealed with cover and clamp
Intermediate Bulk Containers (IBC)	Oils, solvents, acids in bulk	No cracks; valve functioning
Jerricans / Carboys	Chemical waste, solvents	No cracks; sealed caps
Clinical waste containers	Pathogenic / clinical waste	Specialised puncture-proof design
FIBCs / Jumbo bags	Dry solids (dust, slag, ash)	Double HDPE lining; fill to max 90%

Incompatible Waste Segregation

The Fourth Schedule identifies waste combinations that can cause violent reactions, toxic gas release, fire, or explosions. Mixing incompatible wastes is one of the most dangerous compliance failures. It can cause injury, environmental contamination, and facility shutdowns.

You must store incompatible waste groups in separate compartments with physical barriers between them. Here are the key dangerous combinations.

Group A	Group B	Reaction Risk
Alkaline caustics, alkaline cleaners	Acid sludge, spent acid	Heat generation, violent reaction
Reactive metals (aluminium, lithium, sodium)	Any Group 1 acids/bases	Flammable hydrogen gas release
Alcohols	Concentrated acids, metal hydrides	Heat and toxic gas generation
Aldehydes, halogenated hydrocarbons	Oxidizers, flammable wastes	Fire or explosion
Spent cyanide solutions	Acidic wastes	Toxic HCN gas release
Spent sulfide solutions	Acidic wastes	Toxic H₂S gas release

If your facility generates both acidic and alkaline wastes (common in manufacturing), you need separate storage bays. This is not a suggestion. The Fourth Schedule makes it a legal requirement.

eSWIS: The Digital Compliance System

The Electronic Scheduled Waste Information System (eSWIS) is DOE's mandatory online platform for tracking scheduled waste from generation to disposal. As of April 2025, all waste generators must use eSWIS v2 for inventory management and consignment notes.

What eSWIS Covers

eSWIS Function	What You Do	Regulatory Basis
Waste notification	Register as waste generator, declare waste types	Regulation 3
Inventory tracking	Record monthly waste generation by SW code and quantity	Regulation 11
Consignment notes	Create digital chain-of-custody documents for each waste transfer	Sixth Schedule
Facility/transporter verification	Check that your disposal partner holds a valid DOE license	Section 18 EQA

How the Consignment Note Process Works

The consignment note is your proof of proper disposal. Without a completed consignment note in eSWIS, DOE considers the waste unaccounted for. Here is the step-by-step process.

1. Licensed waste contractor initiates the e-Consignment Note in eSWIS with details: waste type (SW code), quantity, your facility information, and receiving facility details.
2. Driver records collection digitally when picking up the waste from your premises. The system timestamps the pickup.
3. You verify and digitally sign off on the transfer details, confirming the waste type and quantity match what was collected.
4. Receiving facility verifies the waste against the consignment note upon arrival. They check that the actual waste matches what was declared.
5. Treatment/disposal is completed and the receiving facility closes the consignment note in eSWIS. This serves as your permanent certificate of disposal.

Keep digital and physical copies of all completed consignment notes. Regulation 11 requires you to retain records for a minimum of 3 years from the date of waste generation.

Transportation Requirements

You can't just put scheduled waste on a lorry and send it off. Regulation 13 and Section 18(1A) of the EQA set strict requirements for how scheduled waste moves from your facility to treatment or disposal.

Requirement	Details
Valid DOE transporter license	Only licensed transporters may carry scheduled waste; verify via eSWIS facility list
Approved vehicles and containers	Vehicle type must match waste characteristics (liquid, solid, clinical)
Proper packaging and labeling	All containers labeled per Third Schedule before loading
Route restrictions	Avoid densely populated areas, water catchment zones, environmentally sensitive areas
Seventh Schedule documentation	Driver must carry waste properties, handling instructions, and emergency procedures
Driver training	Regulation 13(5) requires training on handling, transport safety, and spill response

Your liability as generator doesn't end when the waste leaves your gate. If the transporter is unlicensed or causes a spill, you share the liability. Always verify transporter licenses through the eSWIS portal before engaging any waste management contractor.

Treatment and Disposal Methods

Malaysia's licensed facilities offer four primary treatment approaches. The method depends on the waste type, volume, and hazard characteristics. The largest integrated facility is Cenviro's Waste Management Centre (WMC) in Negeri Sembilan, licensed to handle 76 of the 77 scheduled waste types.

Method	How It Works	Suitable Waste Types
Incineration	High-temperature combustion (850-1,200°C) destroys organic compounds	Organic waste, clinical waste, combustible solvents
Chemical treatment	Neutralisation, oxidation, or reduction to detoxify waste	Acids, alkalis, cyanide solutions, heavy metal solutions
Physical treatment	Filtration, sedimentation, solidification, encapsulation	Sludges, contaminated soils, solids
Recycling/Recovery	Metal extraction, oil re-refining, solvent distillation	E-waste, spent oils, used solvents, metal-bearing sludges

Waste that cannot be treated or recycled goes to secure landfills designed to prevent leaching and groundwater contamination. Any residues from treatment processes must undergo further treatment until rendered harmless.

Special Management Option (Regulation 7)

If you have complex waste streams or want to implement on-site treatment, you can apply to DOE under Regulation 7 for special management arrangements. The application requires a non-refundable fee of RM300 and a written proposal following DOE guidelines. DOE may approve with or without conditions.

Employee Training Requirements

Regulation 15 mandates that every worker who handles scheduled waste must receive competency training. This is not a one-time exercise. Training must cover all aspects of waste handling relevant to their role.

Training Topic	What It Covers
Waste identification	Recognising scheduled waste types, reading SDS, understanding SW codes
Safe handling procedures	PPE requirements, lifting techniques, chemical compatibility
Labeling	Correct label format, hazard symbol selection, placement rules
Storage protocols	Segregation rules, 180-day tracking, secondary containment checks
Spill response	Containment procedures, notification requirements, cleanup methods

Keep training records with dates, topics, trainer qualifications, and attendee signatures. DOE inspectors will ask for these. Connect your scheduled waste training with your broader emergency response plan to ensure consistency.

Spill Response Obligations

Regulation 14 requires waste generators to provide technical expertise for containment and cleanup during accidental discharges. You can't just call the fire department and walk away.

Your spill response plan should include:

• Immediate containment using spill kits appropriate to the waste type
• Notification to the DOE Director General immediately upon discharge
• Preventing waste from reaching drains, waterways, or soil
• Environmental impact assessment as directed by DOE
• Proper disposal of spill cleanup materials as scheduled waste

Transporters have the same obligation under Regulation 13. If a spill occurs during transport, the transporter must immediately notify DOE, implement containment measures, and recover the substance. This is why verifying your transporter's capability and training matters.

Penalties Under the EQA Amendment 2024

The Environmental Quality (Amendment) Act 2024, effective 7 July 2024, is the most significant increase in environmental penalties in Malaysian history. If you were used to the old fine levels, recalibrate.

Offence	Maximum Fine	Imprisonment
Illegal scheduled waste disposal / dumping	Up to RM10,000,000	Up to 5 years (mandatory)
Illegal trafficking of scheduled waste (Section 34B)	RM500,000	Up to 5 years
Hazardous waste mishandling	Minimum RM100,000	Up to 5 years
Discharging pollutants into water/land	Minimum RM50,000; up to RM10,000,000	Up to 5 years
Air pollution offences	RM10,000 to RM1,000,000	Up to 5 years
Operating unlicensed waste facility	Specified under new provisions	Up to 5 years

The 2024 amendment also introduced mandatory imprisonment for serious environmental crimes. Before July 2024, the maximum imprisonment was 2 years. Now it is 5 years, and for certain offences, imprisonment is mandatory upon conviction.

Compare this with OSHA 1994 penalties (maximum RM500,000 under the 2022 amendment). Environmental waste offences now carry penalties 20 times higher. The DOE has enforcement teeth that DOSH can only dream of.

Record Keeping and Inspection

Regulation 11 requires detailed inventory records retained for a minimum of 3 years. During a DOE inspection, incomplete records are treated as non-compliance.

What Your Records Must Include

Record Element	Details Required
Waste generation date	Exact date for each batch (starts 180-day clock)
SW code	Correct classification from First Schedule
Waste name and components	Description of the waste and its chemical/physical makeup
Quantity	In metric tonnes, both generated and managed
Handling method	Storage, on-site treatment, or off-site disposal
Storage/processing location	Where on your premises the waste is kept or treated
Personnel sign-off	Name and signature of person who handled the waste
Consignment notes	Completed eSWIS consignment notes for all waste transfers

Weekly Inspection Checklist

Conduct weekly inspections of your scheduled waste storage area. DOE may arrive unannounced, and the condition of your storage area is the first thing they check.

Inspection Item	What to Check
Container condition	No leaks, holes, dents, bulges, or corrosion; properly sealed
Label compliance	Date, generator details, SW code present; hazard symbols visible and legible
Storage duration	No waste stored beyond 180 days without DOE approval
Quantity limit	Total on-site does not exceed 20 metric tonnes
Secondary containment	Bunding intact, drainage clear, no standing liquids in sump
Access and aisle space	Emergency routes clear, containers organised, no obstructions
Fire safety equipment	Extinguishers functional, no-smoking signs enforced
Segregation	Incompatible wastes in separate compartments per Fourth Schedule

Document every inspection with date, findings, and corrective actions taken. This creates an audit trail that demonstrates due diligence. Integrate these inspections with your broader factory safety compliance checklist.

Common Compliance Mistakes

After years of working with industrial facilities, these are the scheduled waste mistakes we see repeatedly. Most are avoidable with proper systems.

Mistake	Why It Happens	How to Fix It
Exceeding 180-day storage	No tracking system for generation dates	Use eSWIS inventory + monthly countdown review
Wrong SW code assigned	Staff not trained on classification	SDS-based classification procedure + lab testing when uncertain
Missing or faded labels	Outdoor storage without weather protection	Covered storage area + weather-resistant labels + weekly checks
Incompatible waste stored together	Single storage area without segregation	Build separate bays with physical barriers; reference Fourth Schedule
Using unlicensed transporters	Lowest-cost procurement without verification	Verify all transporters via eSWIS portal before engagement
Incomplete consignment notes	Driver leaves before generator signs off	SOPs requiring digital sign-off before vehicle departs
No secondary containment	Storage area designed for general use	Install concrete bunding at 110% capacity of largest container

Insurance Implications of Scheduled Waste

Scheduled waste incidents create liability that extends beyond DOE fines. A chemical spill can contaminate neighbouring properties, injure workers, or trigger cleanup costs that run into millions of ringgit.

Comprehensive General Liability (CGL) insurance covers third-party bodily injury and property damage from accidental pollution events. If your scheduled waste contaminates a neighbour's property or injures a member of the public, CGL responds. But standard CGL policies often exclude gradual pollution. You need to understand exactly what your policy covers.

Industrial All Risks (IAR) insurance covers your own property and business interruption. If a chemical spill forces a production shutdown, or if a fire in your waste storage area damages your facility, IAR covers the rebuild and lost revenue. Facilities handling large volumes of scheduled waste should review their IAR sum insured against the actual replacement cost of their assets.

The key question: does your current insurance programme account for your scheduled waste risk profile? Many factory operators have property and liability cover that was sized before they understood the full scope of EQA penalties and cleanup costs.

FAQ

What is the maximum storage time for scheduled waste in Malaysia?

180 days from the date of generation. You can store up to 20 metric tonnes on-site within this period. If you need to exceed either limit, you must apply for written approval from the DOE Director General before the limit is reached.

What is eSWIS and do I need to use it?

eSWIS (Electronic Scheduled Waste Information System) is DOE's mandatory online platform for waste generator notification, inventory tracking, and consignment notes. All scheduled waste generators must use eSWIS v2 (fully operational since April 2025) to record inventory and create consignment notes for waste transfers.

How much are the fines for scheduled waste offences in 2024?

The Environmental Quality (Amendment) Act 2024, effective 7 July 2024, raised maximum fines to RM10 million for illegal dumping and discharge offences. Hazardous waste mishandling carries a minimum fine of RM100,000. Mandatory imprisonment of up to 5 years now applies to serious environmental crimes.

What are the 5 categories of scheduled waste in Malaysia?

SW1 (metal and metal-bearing waste), SW2 (inorganic constituents), SW3 (organic constituents), SW4 (mixed inorganic/organic waste), and SW5 (other wastes from treatment/recovery). There are 77 specific waste types across these 5 categories, each with a unique SW code.

Can I treat scheduled waste on-site instead of sending it to a licensed facility?

Yes, but only with DOE approval under Regulation 7. You must submit a written application with a non-refundable RM300 fee and a detailed proposal following DOE guidelines. DOE may approve with conditions or reject the application. On-site treatment without approval is an offence.

What happens if my transporter causes a spill?

Both the transporter and the waste generator share liability. The transporter must immediately notify DOE, implement containment, and recover the spilled material. As the generator, you are expected to provide technical expertise about the waste characteristics. Always verify your transporter's DOE license and training records before engagement.

How do I know if my waste is classified as scheduled waste?

Cross-reference your waste against the 77 types listed in the First Schedule of the Environmental Quality (Scheduled Wastes) Regulations 2005. Check the source process, raw materials, Safety Data Sheets, and hazard characteristics (toxic, flammable, corrosive, reactive, infectious). If classification is unclear, send samples to an accredited laboratory for analysis.

What records must I keep and for how long?

Regulation 11 requires inventory records showing waste generation dates, SW codes, quantities, handling methods, storage locations, and personnel sign-offs. Completed consignment notes from eSWIS must also be retained. All records must be kept for a minimum of 3 years from the date of waste generation.

Do I need to train my workers on scheduled waste handling?

Yes. Regulation 15 requires competency training for all workers who handle scheduled waste. Training must cover waste identification, safe handling, labeling, storage protocols, and spill response. Keep dated training records with attendee signatures, as DOE inspectors routinely check these during audits.

What is the difference between this article and the scheduled waste registration guide?

Our scheduled waste registration guide focuses on the initial DOE registration process and getting set up in eSWIS. This article covers ongoing management: storage, labeling, transportation, treatment, inspections, and penalties. Read both for complete compliance coverage.

Foundation Conclusion

Scheduled waste management is one of the highest-liability compliance areas for Malaysian factories and industrial operations. The 2024 EQA amendment raised the stakes to RM10 million fines and mandatory imprisonment, making this a boardroom issue, not just an EHS department task.

A single chemical spill, storage violation, or unlicensed disposal can trigger DOE enforcement, third-party liability claims, and business interruption. Your CGL and IAR insurance coverage should reflect the actual environmental risk profile of your operations, not just the value of your buildings and machinery.

Talk to our risk specialists about environmental liability coverage