The Government has announced a one-year postponement in the implementation of its mandatory digital waste tracking system.
Initially scheduled for April 2025, the new system is now set to become compulsory from April 2026.
Background
The commitment to the digital waste tracking initiative is outlined in the Resources and waste strategy for England.
It aims to join up and digitise currently fragmented, and mostly paper based, systems to provide a single comprehensive way of tracking the amount and type of waste being produced and its end destination.
The policy paper, ‘Mandatory digital waste tracking’, states the change to mandatory digital waste tracking will:
- Provide a comprehensive way to see what is happening to the waste produced in the UK
- Help support more effective regulation of waste
- Help businesses comply with their duty of care with regards to waste
- Help us move towards a more circular economy by enabling us to maximise the value we extract from our resources
- Reduce the ability for waste criminals to operate and undercut legitimate businesses through their systemic mis-handling of waste, illegal exports, and fly tipping.
Waste types to be tracked
There are no certainties at this stage but the Government response to the consultation launched in 2022 on the introduction of mandatory digital waste tracking provides indications as to what types of waste will be tracked.
Whilst an overview is provided below, we urge all operators in the waste management industry to review the Government response so they understand the proposed scope of the digital waste tracking service.
The Government response indicates the intention is that the waste tracking service will require information to be recorded about movements of all types of controlled waste and extractive waste as defined by the waste tracking powers in the Environmental Protection Act 1990 (In relation to Great Britain) and in the Waste and Contaminated Land (Northern Ireland) Order 1997 (for Northern Ireland)
This includes all types of household, commercial and industrial waste whether it is classified as hazardous or non-hazardous waste.
The digital waste tracking service requirements will replace the existing requirements to complete waste transfer notes and hazardous waste consignment notes.
For shipments of waste under Green List Waste controls such as, exports or imports of non-hazardous waste for recycling, Annex VII documentation will still need to travel with the waste to ensure all parties, including those outside of the UK, are able to assess the waste.
However, when the UK waste tracking service is introduced, the information contained on the Annex VII form will also need to be entered onto the service.
Overall, where a record of a waste movement within the UK is required under existing legal requirements, a record on the UK waste tracking service will be required.
The main difference will be that digital waste tracking records will be required when household waste is collected from domestic premises by third parties (subject to the exceptions).
The Government intends to create exceptions from the overarching requirements for digital waste tracking records, such as:
- Household waste collected from domestic premises by local authorities – Waste tracking records for this waste will begin when it is taken into a waste receiving site.
- Household waste recycling centres (HWRCs) – Householders will not be required to record anything on the digital waste tracking service about waste they have produced which they move themselves. Operators of HWRCs will also not need to record the receipt of waste from householders on the waste tracking service. Operators of HWRCs will need to record information about any commercial business waste accepted onto sites. This is akin to current requirements to complete records about these types of transfers. Waste tracking records will also be required when waste is removed from a HWRC.
- A person or organisation collecting litter (including authorities collecting litter as a statutory duty) will not be required to create digital waste tracking records for the movement of that waste to a collection point.
- Incidental waste – Where incidental waste is generated and moved by people who are not providing a specific waste management service, for example tradespeople and mobile service operators, digital waste tracking records will not be required for the first movement of that waste to a collection point. Digital waste records will be required when the waste is moved from the collection point.
- Samples of waste – Where individual samples of waste are sent to another site for the purpose of analysis and determining its correct classification or description, then digital waste tracking service records will not be required for the movement of the sample from the producer to the site conducting the testing. It is likely that Government will include a weight or volume limit for this exception.
- Other potential exceptions are continuing to be considered by Government.
Concluding remarks
Although it is too early to say whether the transition to mandatory digital waste tracking will be a success, the extended timeline to April 2026 provides an opportunity to develop a robust system that will enhance waste management practices across the UK.
It is also reassuring that IT service development is supported by a user panel representing waste producers, carriers, brokers, dealers, waste site operators, local authorities, and regulators from across the UK.
We will continue to monitor the development of the digital waste tracking service and share progress updates as and when they come to our attention.
In the meantime, for further information and advice, please contact James Edes.