The Environment Agency (EA) this week announced that it would no longer enforce certain documentation when customers drop off trade waste at wholesalers.
The change is contained in a new Regulatory Position Statement (RPS) 283 dated 11 September 2023. This states that customers dropping business waste off at wholesaler sites will not be challenged if they do not supply a Waste Transfer Note, or, in the case of hazardous waste like waste electricals and lamps, a Hazardous Waste Consignment Note.
The RPS does not change the law. Instead it is simply means that no enforcement action will be taken against those who do not comply with it.
As would be expected, there are conditions attached to the RPS. For example, the activities must not cause pollution to the environment, or harm to human health. The wholesaler collection points must comply with all other relevant waste related legislation. The businesses and contractors should only drop off waste that has arisen as a result of their own commercial activities. And the wholesalers must not charge their customers for dropping off the waste.
Commenting on the announcement, Recolight CEO Nigel Harvey said “It is great to see the EA taking this pragmatic approach. Waste documentation is clearly important to ensure traceability and accountability. But to require consignment and transfer notes every time a business drops off a small amount of waste at their local wholesaler branch seems disproportionate. This change will make it a little bit easier for businesses to ensure their waste is properly collected and recycled.”
The RPS will be in force for three years after which it will be reviewed. It only applies to England.