Appropriate measures for permitted facilities that take non-hazardous and inert waste – Wiser responds on behalf of its clients

To determine support for the appropriate measures for permitted facilities that take non-hazardous and inert waste, the EA launched a public consultation. The consultation sought to understand if the guidance would modernise non-hazardous and inert waste sector operations and create clarity. The team at Wiser have reviewed the newly published draft proposals and submitted a constructive response. Wiser Environment’s response represents the views of many operators in the industry. Those we regularly advise includes household waste recycling centres, waste transfer stations, materials recycling facilities and sites producing soil and aggregates.

EA Visiting an Inert Waste Facility

On behalf of waste operators, Wiser Environment submitted a response to the EA’s appropriate measures for permitted facilities that take non-hazardous and inert waste consultation.

Wiser Environment responds on behalf of its clients

Alongside consultations for the Waste Management Plan for England and appropriate measures for the biological treatment of waste, and publication of Appropriate measures for Healthcare waste in July 2020, the Environment Agency (EA) launched a public consultation into the newly published guidance for permitted facilities treating or transferring non-hazardous and inert waste.

This consultation was open for responses from the 14th September until the 18th November 2020. Supporting and representing Wiser Environment’s client base, the team at Wiser submitted a formal response.

Broadly, the draft EA guidance seeks to improve the way permitted facilities in the non-hazardous and inert waste sector are operated and designed. Importantly, such guidance is applicable to both new and existing operations. Whilst Wiser Environment supports the EA’s desire to review and clarify guidance, there are certain elements that Wiser called into question.

Representing impacted clients – including household waste recycling centres, waste transfer stations, materials recycling facilities and sites producing soil and aggregates – Wiser Environment has put forward its perspective on the draft guidance.

Management systems should meet the needs of the business

Wiser Environment commented that the EA’s prescriptive management system methodology was not always appropriate; identifying that the complexities of modern waste business cannot always truly be condensed into a standardised management system. Additionally, Wiser suggests that any system should suit the needs of the business and not solely the EA. Operators that maintain a UKAS accredited ISO14001 management should not need a reductive second document. Instead, Wiser notes that certified operators should receive a form of ‘earned recognition’. Recognising the operator’s commitment to performance monitoring and continual improvement.

One size does not fit all

Having experienced the EA’s application of other guidance regardless of site-specific risk, Wiser is concerned that the guidance appears to apply ‘appropriate measures’ as a default position regardless of the scale of operation, the risk to sensitive receptors or, indeed, impact on the economics of the business. The draft document, states that: “enclosing activities within buildings is an appropriate measure for preventing and minimising emissions of pollution For waste treatment activities, we consider this to be the default [Wiser’s emphasis] control measure “.

Wiser Environment expressed concerns that EA Officers are likely to use this default position across all sites, an approach that has already been seen to be the case in certain areas of England. Wiser contend that the EA’s default control measure may be inappropriate for most small scale or independent operators. In addition to significant capital cost, local planning policy may also constrain what structures can be constructed, and potentially be a limiting factor in compliance.

A recent comment from the Environment Agency

Providing an update on the EA’s consultations and responding to criticisms received at the consultation stage, the Senior Policy Advisor at the EA – Howard Leberman – spoke during session one of the recent National Civic Amenity Site Conference. Leberman explained that the draft appropriate measures form a frame for discussion which acts as a starting point. Suggesting that these measures are not mandatory or definitive. Leberman maintained that the guidance does not suggest that every waste facility should operate within an enclosure. Instead, it depends on a variety of site-specific circumstances as to when this guidance will apply.

Leberman explained that the EA had already received significant lobbying; particularly regarding buildings being the default for waste treatment. Explaining that this was the response the EA had anticipated and that the default reference had now been removed. The onus of explaining any deviation from recommended appropriate measures will be on the operator. Judgement on this position will be made by an EA officer who Leberman is confident to have the training and experience.

Wiser’s Consultancy Director, Charles Thomas, reflected that “unless the pragmatic approach Mr Leberman eluded to is made explicit within the guidance, then less experienced officers are likely to find comfort in the safety of the default appropriate measures”.

Non-hazardous and inert waste: appropriate measures for permitted facilities – additional support available at Wiser Environment

Wiser actively participates in consultations to represent and guide its clients – ensuring that they receive appropriate regulatory support. The experienced team at Wiser is ready and available to help businesses with updates and support. For more information about how the appropriate measures for permitted facilities that take non-hazardous and inert waste could impact your business, contact Wiser Environment or call on 01480 462232.

Environmental Audit Committee – WEEE and the Circular Economy

Published on the 26th of November, the Environmental Audit Committee demonstrated the economic and environmental opportunities for WEEE. In sum, the Committee advocates that the UK Government should take proactive action to create a circular economy for electronics.

Wiser Recycling operates multiple AATFs across the UK

The Environmental Audit Committee offers sweeping changes to improve the world’s fastest-growing waste stream.

Environmental Audit Committee – WEEE & the Circular Economy

The select committee of the House of Commons, the Environmental Audit Committee, examines how the UK Government’s actions and policies impact the wider environment. Cutting across the whole UK Government, the Committee holds public bodies to account by auditing against environmental protection targets.

In their latest publication, the Environmental Audit Committee has analysed the economic and environmental opportunities for WEEE (waste from electrical and electronic equipment). Broadly, the Committee’s recommendations for the world’s fastest-growing waste stream boils down to:

  1. Take proactive action in preventing WEEE from falling into general waste streams.
  2. Set ambitious long-term WEEE collection, reuse and recycling targets that prioritise reducing consumption and improve retaining resources.
  3. Focus on funding waste recycling infrastructure with £3 billion invested by 2042.
  4. Close the online retailer loophole and ensure that those online retailers face the same producer compliance scheme obligations as retail stores.
  5. Highlight repairability scores for EEE (electrical and electronic equipment) to the consumer. Informing them of the EEE’s design and availability of spare parts.
  6. Challenge the Environment Agency (EA) to take stronger action against the illegal exports of WEEE.

Prevent WEEE from falling into general waste streams

Worryingly, the Committee revealed that a significant portion of the UK’s WEEE is not treated correctly: “A lot of it goes to landfill, incineration or is dumped overseas”. Going further, they argue that the UK’ recycling systems are not fit for purpose. Suggesting that WEEE often ends up incinerated and its valuable resources – such as gold, silver, copper, platinum and other critical raw materials  – wasted.

The current UK waste management process prioritises shredding which – according to the Committee – leads to the loss of highly engineered parts and those critical raw materials. Treating and recycling WEEE correctly would benefit the environment and economy.

Ambitious long-term collection, reuse and recycling targets

With a focus on reducing consumption and shifting away from recovery, the Committee urges the UK Government to set ambitious WEEE targets. These targets include demanding a very high-performance standard for the collection and recycling of WEEE. Furthermore, the Committee recommends redefining of WEEE targets and to avoid using weight-based metrics which fail to incentives the capture of valuable resources.

The Environmental Audit Committee lobbies for WEEE recycling investment

The Environmental Audit Committee lobbies for greater WEEE recycling investment.

Fairly invest £3 billion into waste infrastructure

Outlined by the Resources and Waste Strategy, the UK Government is set to invest £3 billion into the waste industry by 2042. Querying the investment, find that the “programme is focused on thermal energy from waste or mechanical-biological treatment plants”. 

To avoid branding recovery and recycling as equals, the Committee endorses investment strategies that fund high-quality recycling facilities over recovery operations: “Energy from Waste, though important to prevent items going to landfill, should be treated as a low priority in UK waste infrastructure investment strategies”.

Close online retailer loopholes

Painting an unfavourable picture, the Committee illustrates that the high street is under substantial pressure. The unfair producer compliance scheme obligations reduce the high street’s competitive advantage. This is because online retailers utilise loopholes to avoid respecting their producer compliance scheme obligations.

As a matter of urgency, the Committee stresses that “all large online retailers and marketplaces must arrange and pay for like-for-like electronic waste collection from a customer’s home on delivery of new electronics”.

Highlight repairability scores for EEE

The Committee established that the growth of consumer EEE has led to economic and quality of life improvements. However, as EEE becomes more complex and delicate, the UK consumer is not taking appropriate efforts to repair or reuse the products.

First, the UK Government should ban the practice of planned obsolescence which intentionally shortens the lifespan of EEE. Furthermore, the Committee suggests that producers label their EEE with a repairability score. This score will highlight to the consumer the item’s expected lifetime, design, availability of spare parts and the simplicity of repair manuals.

Stong action against illegal exporting

The Committee demonstrated the UK is one of the biggest exporters of WEEE in the world. Regrettably, the exportation of WEEE to countries with sub-standard treatment methods is commonplace. By using the repairable EEE loophole, exporters can wrongly export WEEE; causing the local UK recycling market to contract and shrink. As a first step, the Committee adds that the EA should begin to classify all returned EEE as WEEE.

SUPPORT AVAILABLE AT WISER

The team at Wiser has extensive experience within the WEEE sector and is ready to provide waste businesses with support. For more information contact Wiser Environment or call on 01480 462232. Additionally, Wiser Recycling also offers WEEE recycling support. From collections to disposal – Wiser Recycling a provide one-stop-shop for all types of WEEE recycling. For more information contact Wiser Recycling or call on 01480 464111.

Wiser Recycling provides a one-stop-shop for all types of WEEE recycling

Wiser Recycling provides a one-stop-shop for all types of WEEE recycling.

WEEE AATF collections at a 10-year low

In a dataset published by the Environment Agency, WEEE AATF collections are at a 10-year low. Quarter 2 of 2020 saw a return of only 64,422 tonnes. These statistics formalise COVID-19’s impact on the WEEE AATF industry. The experienced WEEE AATF experts at Wiser are ready to provide waste businesses with support. For more information contact Wiser Environment or call on 01480 462232.

Additionally, Wiser Recycling also offers WEEE recycling support. From collections to disposal – Wiser Recycling provide a one-stop-shop for all types of WEEE recycling. For more information contact Wiser Recycling or call on 01480 464111.

Household WEEE Received for AATF Treatment 2010-2020

Sourced from the Environment Agency WEEE received at an approved authorised treatment facility data set.

Collections at a 10-year low

Published on a quarterly basis by the Environment Agency (EA), the latest collection figures for waste electrical and electronic equipment (WEEE) reveals a significant fall in collections in quarter 2 (April-June) of 2020 – a 10-year low. Since 2007, the freely available dataset has calculated the number of WEEE tonnes received at Approved Authorised Treatment Facilities (AATF).

During the first quarter of 2020, WEEE AATF’s collected a total of 134,328 tonnes of household WEEE. Of which, large domestic appliances comprised 58,417 tonnes and cooling appliances containing refrigerant collections equalled 31,605 tonnes. During the second quarter of 2020, these household WEEE tonnages took a significant downturn. Total household WEEE collections fell by 52% to just 64,422 tonnes. As an illustration of the scale of this depreciation, Q2’s result surpasses the previous low of 100,778 tonnes recorded in Q4, 2010.

These worrying figures confirm the extend COVID-19 has had on the WEEE industry. During the pandemic, many facilities along the WEEE supply chain were forced to close or mothballed their operations. In response to the industry crisis, the WEEE Fund 2019 Compliance Fee Advisory Panel provided welcome financial support to WEEE AATFs across the UK.

On a positive note and following the end of the first period of lockdown, Wiser Recycling observed a rapid return to normal collection tonnages of WEEE. If this pattern is common throughout the industry, then the industry is likely to successfully recover. The AATF and wider recycling industry have demonstrated its adaptability in quickly addressing the improved welfare and infrastructure requirements of COVID-19.

Support available at Wiser

The team at Wiser has extensive experience within the WEEE AATF sector and is ready to provide waste businesses with support. For more information contact Wiser Environment or call on 01480 462232. Additionally, Wiser Recycling also offers WEEE recycling support. From collections to disposal – Wiser Recycling a provide one-stop-shop for all types of WEEE recycling. For more information contact Wiser Recycling or call on 01480 464111.

New Waste Compliance Taskforce

Comprising of both public and private sector organisations – including the Environment Agency, United Resource Operators Consortium and UK Waste Solutions – the Waste Compliance Taskforce will launch on the 22nd of October. The cross-sector Taskforce aims to provide the waste industry with effective means to tackle and prevent waste crime.


Set to be announced at the Waste Crime Conference on October the 22nd, the Waste Compliance Taskforce – also known as WACT – intends to raise waste crime awareness and mitigate its impact. The Taskforce is a cross-sector forum; combining both the public and private sector perspectives. The Taskforce lists sixteen organisations as members. Members include the Environment Agency, Scottish Environment Protection Agency, Natural Resources Wales, Recoup, United Resource Operators Consortium and UK Waste Solutions.

The Taskforce’s strategy is to provide a platform for working groups to share and gather waste crime intelligence and information. Currently, five specialised working groups form the Waste Compliance Taskforce: landowners, insurance, deposit return scheme, plastic exports and duty of care. The Taskforce outlines that the specialised working groups can uncover policy loopholes and enable regulators to proactively enforce.

Generally, Wiser Environment supports all initiatives that enforce and prevent waste crime. This is because organised waste crime is estimated to cost the UK economy at least £600 million a year. Illegal waste operations are able to avoid compliance standards and sell their services at uncompetitive prices; undercutting and pushing out legitimate and compliant operators from the market.

Importantly, the Taskforce should not be confused with the UK Government’s Joint Unit for Waste Crime. The Joint Unit for Waste Crime is a multi-agency body that incorporates elements of law enforcement agencies, the Environment Agency, Natural Resources Wales, the Scottish Environment Protection Agency, the police, HMRC and the National Crime Agency. The Joint Unit for Waste Crime supports waste crime enforcement whereas the Waste Compliance Taskforce intends to amplify existing campaigns.

To date – a number of regulators, trade associations, landowners, businesses and charities have endorsed the Taskforce. Unsurprisingly so given the rising waste management costs and increasingly complex legislation. Industry leaders need to stay informed and Wiser Environment can help. As of writing, the Waste Compliance Taskforce has yet to disclose if their forum is open to additional members. However, the team at Wiser do have extensive experience in the field of waste management and are ready to help and support businesses with updates and support. For more information, contact us or call on 01480 462232.

Understanding the expanded Vietnam waste import restrictions

As the Vietnamese Government has gradually expanded its Law on Environmental Protection, operators who wish to import waste into Vietnam should stay informed. Over time, Vietnam has responded to environmental incidents with increased environmental legislation. Whilst the strengthening of the Law on Environmental Protection does hold businesses to account, it also increases complexity.

To help operators maintain compliance, the Vietnam specialists at Wiser Environment can provide Environmental Impact Assessments and waste importing support. For more information, contact us or call on +44 1480 462232.

Wiser Environment can help operators import waste into Vietnam.

Wiser Environment can help operators import waste into Vietnam

Law on Environmental Protection

Encouraged by the Ministry Of Natural Resources and Environment (MONRE), the Socialist Republic of Vietnam amended their Law on Environmental Protection (No. 55/2014/QH13). Notable amendments include requirements for MONRE approved Environmental Impact Assessments (EIA) and additional restrictions to waste imports.

Taking a significant step towards sustainable development, the Vietnamese Government introduced the Law on Environmental Protection in 2014. The legislation follows the Government’s intention to strategically improve its environmental protection. Which is further emphasised in the Vietnamese Prime Minister’s statement in the Implementation of Sustainable Development in Vietnam report: “Sustainable development represents a common trend along which the entire humankind is endeavouring. It is also an important strategic goal that the Communist Party, Government and people of Viet Nam are determined to attain”.

Harm to the natural environment, biodiversity and community health

Despite the Law’s good intentions to provide statutory provisions on environmental protection activities, Vietnam’s environment continues to face significant challenges. Notable environmental incidents include avoidable pollution resulting from poor resource management.

For instance, incidents concerning the activities of a steelmaking plant and fluorescent tube manufacturer are clear examples of poor waste management leading to harm within the natural environment, biodiversity and community health.

Regarding the steelmaking plant Formosa Ha Tinh Steel Corporation, they were found responsible for the polluting the surface water within the Ha Tinh, Quang Binh, Quang Tri and Thua Thien-Hue provinces. Here, the steel manufacturer acknowledged that the mismanagement of their industrial wastes resulted in phenol, cyanide, iron hydroxides and other harmful compounds discharging into Vietnam’s surface water and killing over a hundred tons of fish.

In a further well-known incident, the fluorescent tube manufacturer Rang Dong Light Source company also admitted to causing environmental damage. In 2019 a fire broke out at a lighting storage facility and 27.2 kilograms of mercury polluted the Hanoi environment. The fire, which lasted for five-hours, raised health concerns within the local community.

Environmental Impact Assessment for waste treatment facilities

In response and establishing further environmental and legislative scrutiny, the Vietnamese Government installed Decree no. 18/2015/ND-CP. Alongside environmental protection planning and strategic environmental assessments, the Decree no. 18 stipulated when development projects required an EIA.

Specifically, waste treatment facilities that handle either hazardous waste or 10 metric tons of solid waste a day need a MONRE assessed and approved EIA report. Minimising the negative effects of the development, the EIA report scopes stakeholder opinion and ensures that developers justify the environmental impacts of their project.

Vietnam waste import restrictions

Building upon the amendments made in Decree no. 18/2015/ND-CP, the Vietnamese Government expanded its Law on Environmental Protection further with Decree no. 40/2019/ND-CP. Broadly, Decree no. 40 tightened requirements for waste imports. Namely, imported waste resources must meet the following requirements before being used as a production material:

  • Listed within Decision No. 73/2014/QD-TTg as a permitted import for production use;
  • Only import waste resources as raw materials;
  • Imports paired with e-manifests that declare pertinent information presented in Guidance Note No. 6889/TCHQ-GSQL;
  • Access to secure storage and treatment facilities that meet environmental protection requirements;
  • Confirmation from customs authorities that the importer holds a certificate of eligibility for environment protection;
  • The importer has posted a bond that ensures that they maintain financial responsibility for the environmental risk posed;
  • A MONRE approved EIA report that outlines the use of imported waste resources as production materials and confirms completion of environment protection objectives; and
  • Lastly, Vietnam will re-export any imported waste that fails to meet the aforementioned required standards.

Wiser Environment can help operators import waste into Vietnam

Wiser Environment’s Vietnam specialists, supported by our UK waste experts, possess a strong environmental legislation background and can help Vietnamese waste importers to navigate the complex Law on Environmental Protection. Meeting the Decree no. 18’s stipulations on EIAs, the team at Wiser hold a broad range of higher education and postgraduate qualifications.

With consideration to the team’s international experience, Wiser Environment is well suited to provide those who import waste into Vietnam with practical procedures and policies that improve environmental performance. Contact us or call on +44 1480 462232 for more information.