Waste 2025
General Introduction
Waste from industrial processes and manufacturing operations have the potential to impact the environment, human health, and local ecosystem.
As governments and industry stakeholders continue to focus on reducing waste and promoting more sustainable manufacturing practices, more stringent requirements and regulations may be imposed. New materials and technologies are also being developed to reduce and recapture waste and work towards a circular economy that is more sustainable. By proactively managing and working to minimize waste generated from your facility, you can reduce impacts on the environment, exposure to regulatory risks or new requirements from business partners and contribute to a more sustainable future.
In general, the Higg FEM Waste section encourages you to:
- Identify and understand the types of wastes that are generated at your facility.
- Ensure all wastes are appropriately managed onsite (e.g., storage and disposal)
- Understand how your wastes are treated/disposed of after leaving your facility.
- Track and report the quantity of wastes generated at your facility.
- Evaluate, plan for, and adopt solutions to reduce waste through better manufacturing practices, recycling/reuse, and preferred waste treatment solutions.
- Implement leading practices to divert wastes from landfill and into the circular economy.
Additional details on the intent and criteria for each Higg FEM waste question is provided in the guidance below along with useful technical guidance and resources to support your facility in the management and reduction of waste.
Waste At Your Facility
Waste is any material or substance that has no further use and is discarded from a facility which can pollute or contaminate the environment and surrounding communities. In the FEM, wastes are categorized as follows:
- Non-hazardous Waste: is any waste that causes no harm to human or environmental health. Non-hazardous waste usually includes both non-hazardous production waste as well as domestic waste. Examples of non-hazardous waste include:
- Non-hazardous production waste such as textile, leather, plastic, paper, metal, or packaging waste, etc.
- Domestic waste such as food waste and sanitary wastes including household waste from the office and/or dormitory areas (e.g., toilet paper, yard/garden waste, glass, and food packaging), etc.
- Hazardous Waste: is any waste that could cause harm to public health and/or the environment because of its chemical, physical, or biological characteristics (e.g., it is flammable, explosive, toxic, radioactive, or infectious). Hazardous wastes can be liquids, solids, or gases. Examples of hazardous waste include:
- Hazardous production waste such as used chemicals, chemical containers/drums, waste oils, contaminated materials (e.g. materials that contain other substances that are hazardous waste such as rags containing solvents), etc.
- Waste from facility operations such as wastewater treatment sludge if hazardous, fly ash, fluorescent light bulbs, electronic waste, batteries, etc.
Note: For all companies manufacturing or distributing in or to the European Union, the WEEE (Waste from Electrical and Electronic Equipment) directive is an important directive to follow. The WEEE directive governs the reduction and separation of electronic waste.
Reportable Wastes in the FEM
The Higg FEM requires that facilities track and report waste generation data for several specific waste categories listed below. Additional details on reporting waste quantities in the FEM are provided in the relevant questions.
| Non-hazardous Wastes | Hazardous Wastes |
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Note: The legal classification of hazardous waste may differ from one country or jurisdiction to another. Facilities should, at minimum, follow local regulatory requirements and definitions for classifying wastes as hazardous or non-hazardous. If legal requirements do not exist, it is recommended that facilities use industry guidelines or internationally recognized definitions of hazards wastes (such as those listed in the Basel Convention http://www.basel.int/TheConvention/Overview/TextoftheConvention/tabid/1275/Default.asp). Additionally, where industry guidelines are more stringent than local requirements, it is recommended that facilities follow industry guidelines.
Waste to be Excluded from the Higg FEM Reporting Scope:
The following waste materials should not be reported in the FEM, as these types of waste are not generated from a “business as usual” situation:
- Medical waste
- Major construction and demolition projects waste
- Waste from natural disasters such as flood, fire, tornado, hurricane.
Waste Disposal Methods in the Higg FEM
The Higg FEM requires facilities to indicate how their wastes are currently being disposed of and plans or targets for improving waste disposal methods. The FEM includes several predefined waste disposal methods that can be selected. The table below provides a description of the available waste disposal method options in the FEM. These are categorized into Preferred, Less Preferred and Least Preferred options based on their associated environmental impacts.
| Waste Disposal Method | Description |
| Preferred Options (Material Recovery) | |
| Reuse | Pre or post-consumer wastes are reused to make new or second hand products without modification or additional manufacturing steps before using the waste. |
| Recycle (including Upcycle) | Pre or post-consumer wastes are reprocessed to produce new items of equal (or better) quality (e.g., textile to textile recycling or processing plastic bottles into fabric). |
| Downcycle | Pre or post-consumer wastes are recycled and processed to produce material or products of lesser economic value (e.g., recycled textiles used for rags, carpet padding, or sound insulation products). |
| Less Preferred Options (Energy Recovery or Non-valorized Disposal) | |
| Incineration with energy recovery for Non-Recyclables only | Energy recovery from the process of incinerating non-recyclable waste. Note: Recycling infrastructure and capabilities may differ among regions and countries. |
| Energy Recovery – Residual Management (e.g., Physical / Chemical / Biological Treatment) | Energy Recovery as a form of residual management, ie. Sludge Treatment that leads to Biogas Generation, heat generation from biological treatment (composting), energy generation from any such activity that does not include “Incineration” |
| Onsite incineration without energy recovery for Non-Recyclables | Incineration of non-recyclable wastes onsite at the facility that does not recover energy from the incineration process. |
| Offsite incineration without energy recovery for Non-Recyclables | Incineration of non-recyclable wastes offsite at a third-party facility that does not recover energy from the incineration process. |
| Non-valorized disposal – Other Treatment | Any disposal method that does not recover usable materials or attributes of the waste such as converting them into more useful by products like raw materials, fuels, or other sources of energy. |
| Non-valorized disposal – Responsibly Managed Landfills (for waste that cannot be managed in any of the options under Preferred options or Less Preferred Options) |
In the Higg FEM, responsibly managed landfills aligns with the ZDHC Disposal Pathways definitions for landfills with significant control measures as defined in the ZDHC Sludge Management Document Version 1.0. available here: https://www.roadmaptozero.com/output, and as described below: Landfills with Significant Control Measures are landfills that control both leachate and gas produced from the materials placed in the landfill and are engineered to store waste in a manner that is safe to the surrounding environment. For purposes of the WW Guideline, significant control measures are defined as:
Landfills with Limited Control Measures are landfill types that do not meet the description requirements specified in the Landfill with Significant Control Measures section. The permeability, leachate and gas control, and documentation are generally less restrictive. Leachate control may be non-existent or consist of simple collection and drain to local sewer lines. Gases may be vented versus stored, treated and used. Monitoring requirements for these types of landfills are less stringent – requiring less frequent sampling, inspections, and records for a shorter time depending on the local laws and regulations. |
| Least Preferred Options | |
| Energy Recovery (e.g., Incineration with energy recovery for Recyclables) | Energy recovery from the process of incinerating of recyclable waste. Note: Material recovery is the preferred method for recyclable wastes. Note: Recycling infrastructure and capabilities may differ among regions and countries. |
| Landfill/Dumping with No Control Measures | In the Higg FEM, landfill/dumping with no controls aligns with the ZDHC Disposal Pathways definitions for landfills with limited or no control measures as defined in the ZDHC Sludge Management Document Version 1.0. available here: https://www.roadmaptozero.com/output, and as described below: Landfills with Limited Control Measures are landfill types that do not meet the description requirements specified in the Landfill with Significant Control Measures section. The permeability, leachate and gas control, and documentation are generally less restrictive. Leachate control may be non-existent or consist of simple collection and drain to local sewer lines. Gases may be vented versus stored, treated and used. Monitoring requirements for these types of landfills are less stringent – requiring less frequent sampling, inspections, and records for a shorter time depending on the local laws and regulations. Landfills with No Control Measures are landfills constructed with no control measures. Any landfill that has not been designed to contain waste, limit percolation, or control leachates from exposure or entering the environment is considered a landfill with no control measure. This includes dump piles and holes with no lining or packing to limit waste exposure to the ground and/or groundwater. There may be few or no monitoring requirements for these types of landfills. In many cases, these types of landfills are constructed by simply digging a hole and then filling the hole with waste, or it may consist of filling a naturally occurring depression with waste. |
| Onsite Incineration without energy recovery for Recyclables | Incineration of recyclable wastes onsite at the facility that does not recover energy from the incineration process. |
| Offsite incineration without energy recovery for Recyclables | Incineration of recyclable wastes offsite at a third-party facility that does not recover energy from the incineration process. |
| Other | Any other waste disposal method that does not fit the description of the above noted methods. Note: A detailed description of the other methods should be provided. |
Waste Data Quality
Accurately tracking and reporting waste data over time provides facilities and stakeholders with detailed insight into opportunities for improvement. If data is not accurate, this limits the ability to understand a facility’s wastes and identify the specific actions that will help reduce environmental impacts and drive efficiencies.
When establishing a waste tracking and reporting program, the following principles should be applied:
- Completeness – The tracking and reporting program should include all relevant sources (as listed in the FEM). Sources should not be excluded from data tracking and reporting should be based on materiality (e.g., small quantity exceptions).
- Accuracy – Ensure that the data input into the waste tracking program is accurate and is derived from credible sources (e.g., calibrated scales, invoices, established scientific measurement principles or engineering estimates, etc.).
- Consistency – Use consistent methodologies to track waste data that allows for comparisons of waste quantities over time. If there are any changes in the tracking methods, waste sources, or other operations that impact waste data, this should be documented.
- Transparency – All data sources (e.g., invoices, weighing records, etc.), assumptions used (e.g., estimation techniques), and calculation methodologies should be disclosed in data inventories and be readily verifiable via documented records and supporting evidence.
- Data Quality Management – Quality assurance activities (internal or external data quality checks) should be defined and performed on waste data as well as the processes used to collect and track data to ensure reported data is accurate.
Higg FEM Level Progression
If your facility did not achieve Level 1 in this section, you will have the option to complete Level 2 and 3 questions and will be asked the following question:
Your facility has not achieved Level 1 within this section, the maximum score for this section will be limited to your answers in Level 1, You now have the option to answer Level 2 and Level 3 questions, would you prefer to proceed answering these additional questions?
If you Answer Yes: Level 2 and 3 questions will be available to answer in this section.
If you Answer No: Level 2 and 3 questions will not be available in this section.
Notes:
- If your facility did not achieve Level 1 in this section, answering Level 2 and 3 questions will not result in additional score beyond what you have already achieved in Level 1
- It is recommended that facilities consult with their business partners on whether they require responses to Level 2 and Level 3 questions, even though you have not achieved Level 1 in this specific section.
Facilities are encouraged to complete Level 2 and Level 3 questions when possible as these can provide valuable insights on your facilities environmental performance and opportunities for improvement with the advanced Higg FEM aspects in Level 2 and 3



