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New Deadlines for “Dirty Dirt Law” Compliance Requirements

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On June 4, 2021, New Jersey Governor Phil Murphy signed Executive Order 244 (EO 244) ending the Covid-19 Public Health Emergency. Certain Executive Orders that had been put in place as a result of EO 244 expired 30 days later on July 4, 2021, including Executive Order 136 (EO 136). EO 136 had extended the original timeframes required to register and to submit A-901 license applications related to soil and fill recycling services to the New Jersey Department of Environmental Protection (NJDEP).

Under the recently signed Executive Order, there are new deadlines for compliance with the “Dirty Dirt Law.” The so-called “Dirty Dirt Law” (N.J.S.A. 13:1E-127.1) signed by Governor Murphy on January 21, 2020, specifies that any business that does not already have a solid waste A-901 license and engages in, or otherwise provides, “soil and fill recycling services” is required to register with the NJDEP and to obtain an A-901 license. A description of the Dirty Dirt Law and the original deadlines were outlined in Archer’s February 2020 Client Advisory.

The new “Dirty Dirt Law” compliance deadlines are as follows:

  • Any business wishing to engage in Soil and Fill Recycling Services that did not already possess an A-901 License on January 21, 2020 must submit a Registration Form to NJDEP no later than October 14, 2021;
  • Any business that does not possess a valid A-901 License or Soil and Fill Recycling Registration must cease to engage in Soil and Fill Recycling Services after January 13, 2022; and
  • To obtain an A-901 License, a Registrant must submit a valid and administratively complete A-901 License Application to the New Jersey Office of the Attorney General no later than April 15, 2022.

If you have questions or would like more information about the soil and fill recycling services registration and A-901 licensing processes, or A-901 license renewals, annual reporting requirements, or claims issues, please contact Nick Lochetta at 609.580.3709, or at

DISCLAIMER: This client advisory is for general information purposes only. It does not constitute legal or tax advice, and may not be used and relied upon as a substitute for legal or tax advice regarding a specific issue or problem. Advice should be obtained from a qualified attorney or tax practitioner licensed to practice in the jurisdiction where that advice is sought.