Mercury Regulation Compliance · Regulation (EU) 2017/852
Your mercury obligations placed level by level, and the action plan that brings them into compliance.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Mercury Regulation Compliance · Regulation (EU) 2017/852
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Regulation (EU) 2017/852 of 17 May 2017 on mercury assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism, a level, a level above, and the action linking the two, is what turns a finding into a trajectory.
Is mercury-containing waste characterised and traced through to final disposal?
- N1
No specific mercury characterisation. Residues leave the site following usual practice, with no dedicated analysis or tracking of destination.
- N2
Analyses exist for a few streams, carried out following an external request. Final destination is not systematically documented.
- N3
Every identified stream is characterised under an analysis plan, and consignment notes allow tracing through to the treatment facility.
- N4
Traceability covers all streams through to proof of permanent storage, with contractor control and verification of prior solidification.
- N5
Characterisation and traceability data feed indicators reviewed periodically, which trigger source reduction actions and revisions of the analysis plan.
Action to move from L2 to L3
Draw up a written analysis plan covering all streams in the inventory, with frequency and method per stream, integrate it into the site’s environmental sampling schedule, and check the completeness of consignment notes and disposal evidence at the quarterly QHSE review.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2017/852 replaced Regulation (EC) No 1102/2008 and transposes the Minamata Convention across the Union. It bans the export and import of metallic mercury and listed compounds, prohibits the manufacture and placing on the market of products with added mercury, bans primary mercury mining and the use of mercury in artisanal and small-scale gold mining. It governs the industrial processes where it still remains, requires that recovered mercury no longer be reused but treated as waste, and sets solidification rules ahead of permanent storage.
In practice, the difficulty is not knowing the text but knowing where mercury actually sits. Do your concentrates, sludges, filtration dust and gas treatment residues contain mercury, and at what concentrations. Can your suppliers and waste treatment subcontractors evidence the disposal route through to permanent storage. Do characterisation analyses exist for every stream, or only for those an authority has asked about. The question of scope is often settled at site level, not group level.
One confusion comes up repeatedly: the mercury regulation is not a chapter of REACH nor a simple offshoot of the waste directive. It creates standalone obligations, including the ban on recovering mercury for reuse, mandatory solidification before permanent storage, and dedicated documentary requirements for intra-EU trade and imports. Reports sent to the Commission and registers kept by operators fall under this text, not REACH procedures. A site can be fully up to date on its safety data sheets and still fall short on mercury traceability.
A compliance audit concludes with a gap or a pass, stream by stream and document by document. The maturity assessment answers a different question: what level of control has your organisation reached, and what specific action moves it up a level. A one-off characterisation of residues is not the same as a periodic analysis plan built into the site’s environmental monitoring, which in turn differs from a set-up whose results feed into management review and investment decisions.
In Datamensio, the framework is ready to use and remains editable. The AI adjusts themes, questions and level wording according to the CMMI method, or builds a version tailored to your activity from your operating permits, flow analyses and internal procedures.
Reference standard: Regulation (EU) 2017/852 of 17 May 2017 on mercury
The themes assessed
Scope and inventory of mercury sources
Mapping of processes, equipment, reagents, incoming materials and residues that may contain mercury; measured concentrations; inventory updated whenever processes change.
Use bans and substitution
Checking banned uses, status of still-permitted industrial processes, substitution plan for mercury-containing equipment and instruments, tracking of applicable exemptions.
Products with added mercury
Control of products placed on the market or purchased, documentary requirements for suppliers, withdrawal of banned items, handling of residual stock.
Import, export and trade
Identification of cross-border flows of mercury and listed compounds, required consents and documents, control of mixtures, coordination with customs.
Characterisation and classification of mercury waste
Analysis plan for streams, methods and laboratories used, waste codification, sampling frequency, retention of results.
Temporary storage and solidification
Temporary storage conditions, containment and sealing, prior solidification treatment, contractor control, compliance with deadlines before disposal.
Disposal and ban on recirculation
Permanent storage routes, acceptance and treatment completion evidence, ban on recovering mercury for reuse, end-to-end traceability.
Registers, declarations and reports
Maintenance of operator registers, data sent to the competent authority, elements feeding national reports, archiving and retention periods.
Monitoring of releases and exposure
Mercury measurements in air and water discharges, monitoring of soil and groundwater, monitoring of worker exposure, action trigger thresholds.
Governance, skills and improvement
Roles and responsibilities assigned, training of relevant teams, integration into the environmental management system, periodic review and follow-up on gaps.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Is Regulation (EU) 2017/852 subject to certification?
No. It is a directly applicable EU regulation, enforced by national competent authorities and subject to penalties for non-compliance. The Datamensio assessment measures the maturity of your organisation and prepares you for inspection, it does not issue any certificate.
How is this different from a regulatory compliance audit?
An audit checks point by point whether evidence exists and concludes with a gap or a pass. The assessment places your practices on a maturity scale and points to the action that moves you up a level. The two complement each other: the assessment prepares for inspection, inspection confirms it.
How long does the assessment take?
The short version can be filled in during a single working session. In collaborative mode on an industrial site, allow one to two weeks: most of the time goes into gathering flow analyses, consignment notes and evidence from process, waste and procurement teams.
Can the framework be adapted to our activity?
Yes. Themes, questions and levels can all be edited, and the AI can produce a version based on your operating permits and procedures. An extraction site, a smelter and a waste treatment operator do not carry the same obligation profile.
How does this assessment fit with REACH and extractive waste management?
Mercury obligations are standalone but rely on the same characterisation data and the same internal teams. Datamensio’s cross-framework roadmaps consolidate several assessments to avoid duplicating shared actions, particularly around substance inventories and stream traceability.
Can several sites be compared with each other?
Yes. The same framework is rolled out across all business units, with a score by theme and a benchmark between entities as well as against previous assessments. The AI groups recurring gaps into a prioritised roadmap at group level.
Do respondents need regulatory expertise?
Questions focus on practices and available evidence, not on legal interpretation of the text. A QHSE manager can answer them, assigning analytical or customs-related questions to the relevant contacts through collaborative mode.
Where is the data hosted?
In France, with OVH, backed up at Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.