Reforms to Waste Exemption Licences

In 2018, the Government began to undertake consultations regarding the use of exemption licences at permitted waste sites, with the aim of improving operator competence standards at such sites and reducing the use of the exemptions to cover illegal activity.

The consultations raised a series of amendments to be made to the key exemptions that were deemed to encourage poor environmental practice or illegal activity. The proposed reforms make changes to storage limits on waste, the waste that can be used for specific exemptions and to remove some exemptions all together.

Land and Property Professionals, Robinson & Hall explain more…

Some reforms have already been implemented, such as disallowing multiple exemption licences to be applied for on one site. Further reform on waste records now requires waste operators (i.e. those with a waste exemption licence or environmental permit) to keep electronic records of storage and movement and to provide these on demand.

The new reforms are proposed to come into force in autumn 2024, although a formal date has not yet been released. Each exemption has a specific transition period, setting a period in the months following the reform implementation by which waste operators must conform with the changes.

The transition period applies to existing licences and licences registered in the transition period. For those exemptions that are due to be removed, waste operators will be required to apply for an environmental permit to continue these activities.

The table below details the changes to the individual exemptions.

Exemption

Reform

Transition Period (months)

U1 – Use of Waste in Construction

Change to waste codes

Name change

12

U16 – Using Depolluted End-of-Life Vehicles for Parts

Removal of exemption

3

T4 – Preparatory Treatment of Waste by Baling, Sorting, Shredding, Pulverising, Densifying, Crushing, Granulating or Compacting It

Change to storage conditions

Name change

6

T6 – Treatment of Waste Wood and Waste Plant Matter by Chipping, Shredding, Cutting or Pulverising

Change to storage conditions

Name change

6

T8 – Mechanically Treating End-of-Life Tyres

Removal of exemption

3

T9 – Recovering Scrap Metal

Removal of exemption

3

T11 – Repairing or Refurbishing Waste Electrical and Electronic Equipment

Additional fee for licence

N/A

T12 – Manually Treating Waste

Changes to storage conditions

6

T21 – Recover Waste at Waste Water Treatment Works

Change to waste codes

N/A

D7 – Burning Waste in the Open

Change to waste codes

Name change

12

S1 – Store Waste in Secure Containers

Change to storage conditions

Change to waste codes

12

S2 – Temporary Storage of Waste at a Secure Site Pending Recovery Elsewhere

Change to storage conditions

Change to waste codes

12

S3 – Storing Sludge

Change to volume of waste required for exemption

N/A

.

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