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Recycled construction material from demolition waste: separation and quality proof

Recycled construction material from demolition waste: check the hazardous-substance survey, deconstruction, separation, quality class and permitted use under Austrian rules.

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8 September 2026 · Mag. Bernhard Brandauer, Rechtsanwalt

Demolition material can become a recycled construction material for a new project. The deconstruction must be planned so that hazardous substances, disruptive materials and usable mineral components remain separate.

Austria's Recycling Construction Materials Ordinance links production to a documented survey, orderly deconstruction, an acceptance check and proof of quality. Simply crushing mixed material is therefore not enough.

This article explains the key steps for owners and contractors. The main source is the Recycling Construction Materials Ordinance in the RIS, especially sections 4 to 13.

Assess your situation

What must be checked before use?

Two short questions show whether the demolition records or the quality proof should be checked first.

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01 Question 1

Where does your project stand?

The relevant duties begin before demolition starts.

All paths at a glance

Overview of all answers.

01

A reliable deconstruction plan is needed before demolition.

Clarify the quantity, building, possible hazardous substances and reusable components before work begins. Assign responsibility for the survey, separation and documentation.

For larger buildings, check whether the thresholds in section 4 of the Ordinance are met.

02

The quality class and the intended use must match.

Check the assessment record, quality class, designation, delivery note and the use restrictions in section 13 together. The location must stay within the material's protective and use limits.

03

Mixed or unexplained material should not be used yet.

Separate material piles, secure their origin and photographs, and have suitability checked by a qualified person. Material from obviously contaminated areas or with suspected contamination cannot simply be turned into a recycled construction material.

What survey is required before demolition?

Section 4 of the Ordinance requires a survey of hazardous and disruptive substances before demolition if the project produces more than 100 tonnes of construction and demolition waste. Excavated soil is excluded from this threshold. The orientation survey is carried out by a qualified deconstruction specialist.

If the project produces more than 100 tonnes and has a total gross volume above 3,500 m³, a more extensive survey by an external authorised specialist or facility is generally required. The separate exception for linear structures and paved areas must be checked.

The survey also records components that could be prepared for reuse. The owner must retain the survey records for at least seven years after completion of the demolition and present them to the authority on request.

How must deconstruction be organised and recorded?

Under section 5, demolition must be carried out as deconstruction in accordance with ÖNORM B 3151. Reusable components should be removed and handed over in a way that does not make later reuse more difficult. Hazardous and disruptive materials that impair recycling must be removed before any mechanical deconstruction.

Examples include asbestos-containing, tar-containing and PCB-containing waste as well as gypsum-based disruptive materials. The statutory examples do not make other suspected materials harmless. Known or suspected contamination must be clarified before a recovery decision is made.

If more than 100 tonnes of construction and demolition waste arise, deconstruction records must be kept in accordance with ÖNORM B 3151. They must be available on the site during demolition. At the first transfer of mineral or wood waste to a third party, a copy must accompany the waste.

Which materials must remain separate?

Section 6 generally requires the main components identified for deconstruction to be separated on site. If separation at the place where the waste arises is technically impossible or involves disproportionate costs, it must take place at an authorised treatment facility. Joint treatment is permitted only where it is allowed and intended for a particular recycled construction material.

Hazardous and non-hazardous waste, as well as site waste and other waste, must be kept separate. For new buildings with a total gross volume above 3,500 m³, wood waste, metal waste, mineral waste, site waste and, where applicable, other waste must be separated.

Under section 8, the manufacturer performs a visual acceptance check to assess whether the material is suitable. The manufacturer also checks the deconstruction records and assessment record for completeness, plausibility and consistency with the delivered waste. A wrongly labelled or mixed pile does not lose its risks simply because it has been delivered.

How is quality proven and where may the material be used?

Section 9 requires compliance with the quality classes, parameters and limit values in Annex 2. A recycled construction material is assigned to a quality class on the basis of quality assurance. It must also meet the construction requirements of the state of the art.

Section 10 requires an investigation system under Annex 3. Chemical analyses must be performed by an accredited conformity assessment body. The manufacturer must retain the documentation for at least seven years. The test, origin and designation must relate to the specific material batch.

Use is restricted by section 13. U-A, U-B and U-E materials may not be used in certain protected areas, below the highest groundwater level or in surface waters. U-B and U-E are subject to additional requirements, including a low-permeability bound surface or base layer in specified cases. The intended location must therefore be considered when the material is processed.

Key checks

From demolition material to usable construction material

Each stage needs its own records and clear responsibility.

Recycled construction material check matrix
Stage Record Risk if missing
Survey Survey of hazardous and disruptive substances, thresholds and reusable components Unknown contamination is mixed during demolition and later recovery becomes uncertain.
Deconstruction Deconstruction records, separate piles and transfer documents Origin and responsibility can no longer be traced reliably.
Quality Acceptance check, investigation, quality class and designation The material cannot prove the Annex 2 requirements or its technical use.
Use Use area, prohibitions and delivery note Even tested material may be unlawful at the specific location.

The specific assessment depends on the material, origin, quality class, location and complete records.

Process

Four steps to a reliable recovery decision

The sequence prevents suitable material from becoming unusable through mixing.

  1. 01
    Step 1

    Survey the building

    Record quantity, gross volume, hazardous substances and reusable components before demolition.

  2. 02
    Step 2

    Separate during deconstruction

    Remove hazardous substances, separate main components and keep records on the site.

  3. 03
    Step 3

    Prove quality

    Link acceptance, investigation system and quality class to a specific material batch.

  4. 04
    Step 4

    Approve the use

    Match use area, prohibitions, designation and transfer documents before installation.

Practical tip: Before demolition, obtain written information on how material flows, the hazardous-substance survey and quality assurance will be organised. If origin, separation or location is unclear, do not use the material until it has been assessed. You can book an initial consultation for a first legal assessment.

FAQ

Recycled construction material from demolition waste

Is a hazardous-substance survey required before every demolition? +

Section 4 generally links the duty to more than 100 tonnes of construction and demolition waste, excluding excavated soil. If the project also exceeds 3,500 m³ gross volume, a more extensive survey by an external authorised specialist or facility is required in principle. The individual project and statutory exceptions must be checked.

May I crush concrete, bricks and other materials together? +

Main components must generally remain separate under section 6. Joint treatment is possible only if it is permitted and intended for a particular recycled construction material. Materials containing hazardous or disruptive substances must be removed first.

Is a laboratory report enough to prove quality? +

A single laboratory report does not answer every question. Under sections 9 and 10, quality requirements, the investigation system, the quality class and the documentation must fit together. Designation, transfer and use restrictions under sections 11 to 13 must also be checked.

Can tested recycled material be used anywhere? +

No. Section 13 sets use areas and prohibitions for each quality class. Protected areas, the highest groundwater level, surface waters and bound surface or base layers can be decisive.

Topics
Recycled construction materialDemolitionDeconstructionConstruction wasteQuality proofConstruction law

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