Consultations published on carriers/broker/dealer and waste tracking

21 JANUARY 2022

The consultations on waste carriers/brokers/dealers (for England) and waste tracking (for the UK) have finally been launched. 

Both will lead to a massive impact on those that handle waste and how waste is recorded. The waste carrier/broker/dealer registration process will be replaced by a permitting system as part of the Environmental Permitting Regulations, requiring permit-scale fees and technical competence. Exporters will also have to be permitted, a major change from the current system where broadly, anyone can export waste without any form of monitoring.

The waste tracking consultation will see the implementation of a mandatory 'cradle to grave' recording process to replace waste transfer notes and other current requirements such as the quarterly reports that permitted sites have to submit. This will also record all waste exports when linked into new controls that are expected to be consulted on for waste shipments. 

These changes will not be applied until 2023/4 at the earliest but reform in these areas is long overdue and the proposals are broadly welcome. There must be some major concerns, though.

  • There are currently tens of thousands of registered waste carriers, brokers, dealers and unregistered exporters who, under the proposals, would need to obtain a permit. Will the EA have the resources to provide a quick and efficient service and to properly police the system?
  • Will the significant cost - likely to be £1-2k per permit along with the cost of obtaining technical competence - lead to even more rogue operators?
  • Will the waste tracking system be compatible with existing operator systems?

Anyone involved in producing, moving, treating, exporting or disposing of waste needs to read these consultations very carefully and consider the proposed changes in the context of their current operations. 

Responses are required to both consultations by 15 April.