Over the last few months, I’ve spoken to operators about digital waste tracking. Surprisingly, one of the most common areas of uncertainty is whether the business is required to use it and not how the system itself works.
The answer is narrower than some people realise.
The current regime applies to organisations that are licensed or permitted to receive controlled waste. If you operate a permitted installation, operation, mobile plant or other licensed receiving facility, and you receive controlled waste, you are generally required to report every load received through the digital waste tracking system.
However, there are some notable exclusions.
For example, household waste recycling centres are treated differently in certain circumstances. In addition, the regulations include provisions for genuinely digitally excluded operators, although the guidance makes clear that preferring paper records or finding software inconvenient is not enough to be digitally excluded.
What’s equally important is who has not yet been brought within scope.
The Government’s delivery plan makes clear that the current arrangements are Phase 1 and focus on waste receivers. Waste carriers, brokers and dealers are expected to be incorporated as part of Phase 2. Waste exemptions are not included in the first phase, as it only applies to permitted sites that receive waste. Waste exemptions will be included in a later phase. Tracking for organisations that handle green list waste will be built into a future phase of the service.
The system many receiving sites are now should be viewed as the first stage of a much larger programme as it is by no means the finished product.
Understanding where your business sits within the implementation roadmap is just as important as understanding how to submit the data.
Digital waste tracking does not replace waste transfer notes
Digital waste tracking has not replaced Waste Transfer Notes, Annex VII forms or hazardous waste consignment notes.
In fact, the Government’s guidance expressly states that the existing paper-based method of tracking waste continues alongside the new digital service.
This means that many operators are now operating two parallel systems:
- The long-established transfer documentation regime.
- The new digital reporting regime.
The practical consequence is that businesses cannot treat the digital record as a substitute for existing documentation.
Both must be maintained, at least for the time being.
The same principle applies to waste returns and hazardous waste consignee returns. Those obligations continue.
The result is that compliance teams are required to do more than learn a new reporting system.
There is now a requirement to manage an additional reporting layer whilst maintaining existing obligations.
I suspect some operators were hoping digital waste tracking would reduce administrative burden immediately.
The reality is that we are currently in a transitional phase where record-keeping requirements have, if anything, increased.
The real question is whether the Government ultimately intends the digital record to become the primary means of evidencing waste movements. If that happens, the role of the Waste Transfer Note may look very different in a few years’ time.
#WasteTransferNotes #WasteTracking #WasteIndustry
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