The Environment Agency has updated its core guidance on non-nuclear Radioactive Substances Regulation (RSR), introducing several new guidance documents designed to support permit holders throughout the lifecycle of regulated radioactive substances activities. The changes were published on 12 August 2026 and are particularly relevant to organisations operating under Environmental Permitting Regulations (EPR) permits for radioactive substances activities.
What has changed?
The Environment Agency’s guidance page, Non-nuclear RSR: environmental permits, has been updated to include links to three new guidance documents.
These additions cover:
The new guidance documents have been incorporated into key stages of the permitting process, with surrender guidance added under the “Surrender your permit” section and the waste management and decommissioning guidance added under the “After you get your permit” section.
Why the updated guidance matters
The non-nuclear radioactive substances regime applies to a wide range of operators, including hospitals, universities, research facilities, industrial users of radioactive sources, and organisations dealing with naturally occurring radioactive material (NORM). These operators must comply with the Environmental Permitting Regulations and the Environment Agency’s expectations for environmental protection and radioactive waste management.
While much attention is often focused on obtaining permits, the latest update highlights the regulator’s increasing emphasis on:
- Effective long-term management of radioactive waste
- Early planning for decommissioning and site closure
- Demonstrating that activities can be brought to an end safely and compliantly
- Proper surrender of environmental permits once regulated activities have ceased
Radioactive waste management planning
A key addition is the new guidance on developing and maintaining a radioactive waste management plan. This inclusion signals the Environment Agency’s expectation that permit holders should have a structured, documented approach to managing radioactive waste throughout the life of their operations.
For many operators, the guidance is likely to assist in demonstrating compliance with permit conditions, optimisation principles, and broader environmental protection objectives. A well-maintained waste management plan can also help organisations anticipate future liabilities and reduce regulatory risk.
Greater focus on decommissioning
The new guidance on planning for decommissioning of radioactive substances activities reflects a growing regulatory focus on end-of-life planning. Rather than treating decommissioning as a consideration only when operations are nearing completion, operators are increasingly expected to plan for eventual cessation from an early stage.
This approach is consistent with wider environmental regulation, where regulators expect operators to understand and manage the lifecycle impacts of their activities and to demonstrate how sites can ultimately be returned to a satisfactory condition.
New support for permit surrenders
The Environment Agency has also published dedicated guidance on surrendering a non-nuclear radioactive substances permit. The guidance has been added directly to the permit surrender section of the main RSR permitting guidance.
Permit surrender can be complex, particularly where radioactive materials or waste have been stored, used, or disposed of at a site. Operators seeking to relinquish their permits must demonstrate that they have met regulatory requirements and that no ongoing environmental liabilities remain. The new guidance should clarify the information and evidence the regulator expects.
What should permit holders do now?
Organisations holding radioactive substances permits should review the newly published guidance and assess whether their existing arrangements remain adequate. In particular, operators may wish to:
- Review current radioactive waste management procedures
- Assess whether decommissioning plans are sufficiently developed and documented
- Consider future permit surrender requirements where activities may be approaching closure
- Ensure internal management systems and compliance documentation reflect current Environment Agency expectations
How we can help
If you would like advice on the impact of the Environment Agency’s latest guidance, or assistance with your radioactive substances permit obligations, please contact a member of our team.
Our specialist team can support you with compliance awareness so that you do not get caught out. Contact James Edes today for help.