- 📊 Waste characterization (kg/day by type: organic, recyclable, hazardous)
- 📋 Integrated Management Plan in MARN format
- 🤝 Contracts with MARN-authorized manager (transport and disposal)
- 🏢 Patente, NIT and legal representation of the company
- 💵 Payment receipt Q500 at BANRURAL MARN account
- 📐 Site plan with temporary storage areas
The Integrated Waste Management Plan is the technical-administrative instrument that MARN requires from EVERY company generating common solid waste in Guatemala. Its legal basis is Government Agreement 164-2021 (Regulation for the Integrated Management of Common Solid Waste) in force since 2022 with progressive compliance. It is one of the most accessible MARN procedures in cost (~Q500 fee) but most demanding in internal organization — it implies training personnel, installing differentiated containers, hiring authorized managers, and reporting monthly.
Quick summary: Mandatory for every generating entity with production greater than 25 kg/day (practically every formal company). Low cost: Q1,500-5,000 preparation + Q500 MARN registration. Approval timeline 30-60 working days. Validity 5 years with mandatory annual update. Plan technical structure based on 4R+V hierarchy (refuse, reduce, reuse, recycle, valorize) and source separation with color codes. For hazardous waste and hospital waste, additional rules apply (Agreement 281-2015). Fine for non-compliance Q5,000-Q50,000.
Information verified May 2026 — Government Agreement 164-2021 in force.
What is the Integrated Waste Management Plan?
It is the technical document that each generating entity must prepare, submit to MARN and execute to responsibly manage the solid waste it produces. Its objective is to reduce final disposal in landfills or dumpsites through application of the 4R+V hierarchy and integration of waste into the circular economy.
4R+V Hierarchy (Agreement 164-2021 Art. 5)
- Refuse — avoid generating the waste at the source (eliminate unnecessary packaging, replace disposables with reusables).
- Reduce — minimize the quantity generated (bulk purchases, process optimization).
- Reuse — give second use to the waste without transforming it (returnable packaging, spare parts).
- Recycle — transform the waste into new raw material (paper, PET plastic, glass, metals).
- Valorize — energy recovery or composting when recycling is not viable.
- Final disposal — last option, only to authorized landfill (NOT clandestine dumpsites).
Source separation system with color codes
| Color | Type of waste | Examples |
|---|---|---|
| Green | Compostable organics | Food scraps, fruits, vegetables, napkin paper |
| Blue | Recyclable (paper and cardboard) | Newspaper, notebooks, boxes, office paper |
| Yellow | Recyclable (plastics) | PET, polyethylene, polypropylene clean |
| White | Glass | Clean bottles, jars |
| Brown | Metals | Aluminum cans, tinplate, light scrap |
| Gray | Non-recoverable | Diapers, waxed paper, expanded polyethylene |
| Red | Hazardous | Batteries, solvents, fluorescents |
| Black | Sanitary/bioinfectious | Only applies to hospitals (rule 281-2015) |
Who is required?
Agreement 164-2021 Art. 4 declares the Plan mandatory for every generating entity with production greater than 25 kg/day of common solid waste. In practice, almost every formal company exceeds that threshold. Sectors explicitly covered:
- Industries of any size — manufacturing, food, textile, chemical
- Medium and large businesses — supermarkets, department stores, large hardware stores
- Hospitals, clinics, laboratories — additionally Agreement 281-2015
- Hotels — all sizes in tourist areas
- Industrial restaurants and cafeterias — corporate canteens, franchises
- Condominiums and subdivisions >50 dwellings — collective management
- Mass events — concerts, fairs, conferences (>500 attendees)
- Shopping centers and plazas — integrated management
- Municipal markets — coordinated municipal responsibility
- Special generators (EPR) — producers/importers of packaging, tires, batteries, electronics, lubricants, agrochemicals
- Municipalities — responsible for public cleaning service
Micro-enterprises with generation less than 25 kg/day are exempt from the formal Plan but must use the regulated municipal service and do basic separation.
File requirements
From the owner:
- Formal request on MARN format.
- Articles of incorporation, legal representation certificate, patente and NIT.
- Legal personhood document if public entity.
From the Plan:
- Initial diagnostic with quantitative characterization (kg/day by type) and qualitative of waste generated.
- Site plan with location of:
- Temporary storage areas (covered, ventilated, identified)
- Delivery point to authorized transporter
- Specific generation areas (kitchens, workshops, offices)
- Documented operating procedures for:
- Source separation with color codes
- Temporary storage by type
- Internal collection and transport
- Final disposal
- Annual training program for personnel (minimum 4 hours/year per employee).
- Contingency plan for spills, fires or emergencies.
- Performance indicators and annual reduction/valorization targets.
- Implementation and reporting timeline.
From authorized managers:
- Active contract with MARN-authorized transporter (verify list at marn.gob.gt → Waste Management).
- Active contract with authorized final disposal plant (certified landfill, NOT dumpsite).
- For hazardous waste: contract with specialized manager authorized under Agreement 281-2015.
- Transport and disposal manifests for the last 6 months (if already operating).
From payments:
- BANRURAL receipt for the Q500 registration fee.
If EPR applies (producers and importers):
- Specific EPR Plan with recovery targets.
- Documented reverse logistics system.
- Alliances with authorized managers for post-consumer.
- Semiannual compliance reports.
Step by step
1. Characterize your waste
For 7 days, weigh and classify the waste you generate by type (organic, recyclable, hazardous, sanitary). This gives you kg/day per category — the basis of the Plan. Medium businesses may hire a consultant for this stage (Q2K-8K).
2. Prepare the Plan in MARN format
Download the official format from marn.gob.gt → Waste Management. Small businesses can do it internally with the MARN guide; medium/large hire a consultant (Q3K-15K). Minimum structure: diagnostic, 4R+V hierarchy, separation, storage, transport, disposal, training, indicators, timeline.
3. Hire authorized managers
Identify at marn.gob.gt the authorized transporters and certified final disposal plants operating in your area. Sign active contracts with both. For hazardous waste, hire a specialized manager under Agreement 281-2015. Monthly service cost: variable (Q500-Q15K/month depending on volume).
4. Implement source separation
Buy differentiated containers with color codes and visible labeling. Train personnel on correct separation (4 initial hours + quarterly reinforcements). Designate an internal Plan manager (can be the occupational safety and health manager, or HR).
5. Pay the fee
Deposit Q500 in MARN’’s BANRURAL account. Keep the original receipt.
6. Submit the file in SIGEIA
Upload to sigeia.marn.gob.gt: Plan, contracts with managers, plans, prior manifests (if applicable) and receipt. For large and medium companies, in-person delivery is also accepted at the Environmental Window (7a Av 8-23 Zona 9 Edificio Etisa).
7. DIGARN technical review
DIGARN reviews in 20-30 days. Typically issues prevenciones for: non-measurable indicators, non-authorized managers, lack of training program, omission of EPR chapter when applicable. Response period: 15-30 days.
8. Approval and Registry issuance
Once approved, MARN issues a Generator Registry with unique number and 5-year validity. This number must be displayed visibly at the establishment entrance and on invoices from authorized managers.
9. Implement and report annually
From the approval date, implement the Plan, keep monthly generation records by type, submit annual compliance report to MARN every 12 months with: kg generated, kg valorized (% recovered), kg disposed in landfill, training conducted, incidents, planned improvements.
Cost and timeline
| Item | Cost (GTQ) | Time |
|---|---|---|
| Waste characterization | Q2,000 - Q8,000 | 7 days |
| Plan preparation (internal or consultant) | Q1,500 - Q15,000 | 15-30 days |
| MARN registration fee | Q500 | Pay at intake |
| Differentiated containers (initial purchase) | Q500 - Q5,000 | 1-2 weeks |
| Initial personnel training | Q1,000 - Q10,000 | 1 day |
| Contracts with authorized managers | Variable monthly (Q500-Q15K/mo) | Ongoing |
| Annual reports | Q500 - Q3,000/yr | Annual |
| PROCEDURE TOTAL | Q2,000 - Q5,500 | 30-60 days |
| INITIAL IMPLEMENTATION TOTAL | Q5,000 - Q30,000 | 45-90 days |
Common mistakes
- Non-MARN-authorized manager — hiring non-authorized transporters or plants invalidates the Plan. Verify the official list at marn.gob.gt before signing a contract.
- Non-measurable indicators — writing “reduce waste” without an annual numerical target (kg/year, % valorization) generates prevention. Use SMART targets.
- Not considering hazardous waste separately — batteries, lamps, solvents, lubricants mixed with recyclables = cumulative sanction.
- Generic copy-paste Plan — using another company’’s Plan without your own characterization is detected and rejected. Characterization must be site-specific.
- Not updating annually — Approved Plan but without annual report = considered nonexistent for sanctions purposes.
Penalties for not having or non-compliance with the Plan
| Infraction | Sanction | Legal basis |
|---|---|---|
| No registered Management Plan | Fine Q5,000-Q50,000 depending on size | Agreement 164-2021 Art. 60 |
| Expired or outdated Plan | Fine Q3,000-Q25,000 + regularization period | Agreement 164-2021 Art. 60 |
| Disposal in clandestine dumpsite | Fine Q10,000-Q100,000 + closure | Agreement 164-2021 Art. 61 |
| Mixing hazardous waste with common | Fine Q15,000-Q200,000 + Agreement 281-2015 sanction | Agreement 164-2021 + 281-2015 |
| Falsehood in annual report | Registry cancellation + criminal complaint | Penal Code Art. 347 |
| Operating without environmental license AND without Plan | Cumulative sanction Decree 68-86 Art. 14 + Agreement 164-2021 | Both legal bodies |
| Burning waste without authorization | Additional fine Q5K-Q50K + environmental complaint | Decree 68-86 + Agreement 164-2021 |
Related procedures
- MARN Hub: Ministry of Environment Procedures — full directory.
- General Environmental License — Waste Plan is part of the Environmental Management Plan.
- Environmental License Category A — large projects with significant generation.
- Environmental Impact Study EIA — includes Waste Plan.
- Environmental Diagnostic — for businesses operating without Plan.
- Wastewater Discharge Permit — Agreement 236-2006, complementary for industries.
- MEM Procedures — energy projects generate special waste.
- MAGA Procedures — agribusiness with high volumes of organic waste.
- Register a business and get a NIT.
Official MARN links
- SIGEIA (Environmental Management System): https://sigeia.marn.gob.gt/
- Common Solid Waste Regulation (Agreement 164-2021): marn.gob.gt → Marco Legal
- Hospital Waste Regulation (Agreement 281-2015): marn.gob.gt → Marco Legal
- Environmental Evaluation Regulation (Agreement 137-2016): marn.gob.gt → Marco Legal
- Environmental Protection Law (Decree 68-86): marn.gob.gt → Marco Legal
- List of authorized managers and transporters: marn.gob.gt → Waste Management
- Environmental Window (in person): 7a Avenida 8-23 Zona 9, Edificio Etisa, Guatemala City
- MARN PBX: 2423-0500
- WhatsApp service: 5213-2971
- Hours: Monday to Friday 8:00-16:30 (file intake until 15:00)