Latest News

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.

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

For further information on the waste exemption regulation reforms, please contact Emily.

Back to articles