Greenbaum, Rowe, Smith & Davis LLP
Daniel Flynn and Barbara J. Koonz
March 30, 2020
Effective January 21, 2020, New Jersey expanded its A-901 licensing law, originally enacted to keep organized crime out of the state’s solid waste business by requiring an A-901 license for businesses that collect, transport, process, broker, store, purchase, sell or dispose of “soil and fill recyclable material.”
Businesses currently providing “soil and fill recycling services” may continue to provide those services while going through the licensing process but must register with the New Jersey Department of Environmental Protection (NJDEP) by April 20, 2020.
If this registration deadline is missed, the business is prohibited from continuing to provide soil and recycling services until it obtains its A-901 license, a process that usually takes at least six months once the fully completed application package has been submitted.