There are some changes in the pipeline which will affect businesses that are
deemed to be hazardous waste producers.
What determines whether or not a business is classed as a hazardous waste producer?
At the moment, only those businesses that produce 500kg or more of hazardous
waste per year at a single site need to register as hazardous waste producers; however,
from 1 April 2016 this will change for businesses based in England.
As part of the Government’s Smarter Environmental Regulation Review (SERR), the
existing registration process is being overhauled.
What does this mean?
In a nut shell, it means that all businesses based in England that produce hazardous
waste, regardless of quantity, will no longer need to register the premises with
the Environment Agency. However, these changes only apply from 1 April 2016, so
if a business handles more than 500kg of hazardous waste in the 12 months prior
to this date, it will be required to register (currently £18 per site).
Please note that for businesses based in Wales the process remains the same and
they should continue to register with Natural Resource Wales.
In addition to the removal of thresholds, the consignment note codes are to be
reformed. Again these changes will only affect businesses based in England.
What are consignment note codes?
Consignment note codes are unique identifiers which relate to a business’s hazardous
waste and exist to help authorities to track it.
As of 1 April 2016, producers will need to amend the first six characters of
the consignment note code (currently the premises registration number), replacing
them with the first six letters or numbers (not symbols) of the organisation’s name.
This format must be used uniformly across all of the producer’s sites. The second
set of characters will continue to be five numbers or letters of the organisation’s
In addition, the use of 2003 SIC codes on consignment notes will no longer be
allowed. The corresponding 2007 must be used instead.
Will the system work?
The system should succeed in reducing costs and the administrative burden on
producers; however, the waste still needs to be tracked so it could complicate the
work done by treatment facilities in order to keep track of the waste.
In addition, it might be difficult for large organisations to ensure all sites
are applying these rules uniformly.
There is no official word as yet on how producers with names consisting of fewer
than six letters will apply the rules – it is likely they will be asked to use a
“filler” character or symbol.
And there is no clarification yet as to how these rules will apply to organisations
with similar names, it is conceivable that multiple organisations could produce
the same code if their names are similar. The additional information contained within
the consignment note may help differentiate such cases.
Where can I find further guidance?
Some of the issues with the new system are likely to be addressed when detailed
guidance is published on gov.uk from 1 April 2016.