Some of us who don’t have better things to do have been awaiting with mounting excitement the arrival of several promised waste regulations from the UK government and devolved administrations. We have waited and waited. We have been told about delays. Finally after a good seven years like a bunched up bus fleet they are starting to appear on the horizon.
At the front is Simpler Recycling. A requirement on all English workplaces (except micro-businesses) to arrange separate collection of recyclables from 1st Apr 2025. In scope are the sort of things most households throw out every week – plastic, cans, cartons, paper, cardboard, glass, food waste. This doesn’t massively impact the re-use world. Glass in this context means bottles and jars, plastics are bottles, tubs, trays. Unsaleable donations of glasses, ornaments, toys and so on aren’t included and neither are textiles. The Welsh Workplace Recycling regulations already in place are similar and do include textiles, but only brand new items that have a recycling market.
Not far behind, with the same ETA but a little doubt about reliability of timetable – it’s Waste Exemptions reform in England, as part of the recent Environment Agency consultation on charge proposals for waste crime and hourly rates. The main point here is that if you take in certain waste materials you will need to start paying to register exemptions on each individual site. For those of us accepting goods for re-use it might be time to consider whether we need a waste exemption at all. If you are collecting what you consider waste and you are storing or processing it you may want to consider exactly what exemptions apply. There has been a tendency to register as many exemptions as you can while they’re free, but do you really need that T31: recovering monopropylene glycol from aircraft antifreeze? Nothing is final yet but it’s worth looking at
Digital Waste Tracking was due April 2025. It’s now officially arriving April 2026. This is huge. It transforms the way that movements of waste are recorded from a dispersed paper based system, to a centralised electronic database. It also includes pre-notification. A van with waste on board without a legitimate pre-notified destination will be breaking the law. Again it needn’t have much to do with the re-use sector, other than making sure contractors are compliant, but it will require a lot more from anyone that does accept incoming waste. This covers the whole UK.
There’s more promised. They have been due for several years and might yet take a few years to arrive. Carrier Broker Dealer reforms (England only) aims to simplify the waste carrier system and require more professional competence. The next phase of Simpler Recycling takes in soft plastics, for instance all those bags that donations arrive in. And most exciting for many of us Textiles Extended Producer Responsibility (EPR) might be getting a little nearer. The European Union has just agreed on a ‘harmonised’ approach to EPR which will require those selling new clothing to contribute towards the costs of dealing with these after first use, and crucially an ambition to define and remove waste before export for re-use. While the UK is not obliged to do the same it will be an important point of reference as policies are reviewed in coming months.
What this highlights is that we need to be crystal clear about whether we are accepting or passing on goods for re-use or waste for recycling/disposal. TRUST continues to provide due diligence on both fronts and a pre-check ahead of potential enforcement. As the regulations arrive the regulators won’t be far behind.
David Roman – Chair of TRUST Forum