The ZDHC MMCF Guidelines V2.2 mandates wastewater sampling, testing & reporting for a MMCF manufacturing facility twice a year - before 30^th April and before 31^st October (every year). There should be at least a three month gap between the two testing cycles. The wastewater test reports for the two cycles must be uploaded to the supplier’s ZDHC Gateway account by the ZDHC Approved Laboratory completing the sampling and testing.

In case a laboratory has done the sampling at the end of the cycle (end of April or October), they can still test and generate the report after the cycle end, as only the sampling date is considered to decide the cycle in the gateway. However the preferred option is to complete everything within the same cycle.

The sampling, testing and reporting for MMCF wastewater must be done by a ZDHC Approved Laboratory. The approval of MMCF WW testing labs is ongoing and the list is updated weekly through our website.

The general principles for sampling and reporting of the ZDHC MMCF WWG V2.2 document are directly linked to the latest published version of the ZDHC Wastewater Guidelines V2.2. For sampling, refer to Table No. 12 in MMCF Guidelines V2.2 which describes Wastewater discharge types, sample locations and test parameters for MMCF facilities.

The sludge requirement has been updated in MMCF Guidelines v2.2 as below

At a minimum, existing local legal regulations for the treatment and handling of industrial wastewater sludge shall be observed. Under such a situation, additional testing of sludge is considered optional.

If no such regulation exists, manufacturing facilities can refer to and implement the sludge disposal pathways, described in the ZDHC Sludge Reference Document V1.0, best suited to their facility’s operations.

Further discussions will be held with MMCF stakeholders to align sludge testing and disposal requirements for MMCF manufacturers with those outlined in the ZDHC Wastewater Guidelines V2.1 – Tables 4.A-4.D for the next update to the MMCF Guidelines. 

The Foundational Level conformance criteria to the ZDHC MMCF Wastewater Guidelines V2.2 are mentioned below and it will be based on achievements of the limit values for different discharge types. The Foundational Level is the baseline that all facilities must achieve.

Direct discharge facilities:

• Achieve the Foundational limits for parameters in Table 1A-1C in discharged WW.
• APEOs in untreated wastewater are at, or below, the reporting limit values.

Indirect discharge facilities (with pre-treatment)

• All conventional parameters comply with their agreements with the receiving CETP.
• Achieve the Foundational limits for cadmium, chromium [VI], lead and mercury in pre-treated wastewater.
• APEOs in untreated wastewater are at, or below, the reporting limit values.

Indirect discharge facilities (without pre-treatment)

• All conventional parameters comply with their agreements with the receiving CETP.
• Achieve the Foundational limits for cadmium, chromium [VI], lead, mercury in raw wastewater.
• APEOs in raw wastewater are at, or below, the reporting limit values.

Zero Liquid Discharge (ZLD)

• APEOs in untreated wastewater are at, or below, the reporting limit values.

Wastewater testing is a key requirement under the ZDHC MMCF Guidelines V2.2. However, some MMCF facilities encounter logistical challenges due to the lack of ZDHC Approved MMCF Wastewater Laboratories in their region. To address this issue, certain facilities have been granted an exemption from the obligation to use ZDHC Approved Laboratories for wastewater testing.

This exemption allows MMCF facilities facing logistical difficulties—stemming from the unavailability of ZDHC Approved Wastewater Laboratories—to conduct their wastewater testing at an alternative laboratory of their choice, as long as it meets the necessary accreditation standards.

Requirements for alternative laboratories

To ensure the quality and compliance of testing, exempted MMCF facilities must select laboratories that meet the following criteria:

• ISO 17025 accreditation: The chosen laboratory must be accredited under ISO 17025 to ensure quality and reliability in testing procedures.
• Accredited test methods: The laboratory's accreditation scope must include relevant wastewater testing methods aligned with the ZDHC MMCF Guidelines V2.2.

Suppliers in this situation without a directly granted exemption must contact the ZDHC team to assess their case and confirm their eligibility before submitting the MMCF Module.

This provision guarantees that MMCF facilities can continue to meet wastewater testing requirements while overcoming logistical barriers.