The Environment Agency have now published two new Regulatory Position Statements (RPS) relating to waste collection points. They are most relevant to many shopping centres and other multi-tenant premises.
Background:
These RPS fill a gap in how the Environmental Permitting Regulations (EPR) deal with the collection of waste.
The non-waste framework directive (NWFD) exemptions in Schedule 3 of the EPR allow for waste collection points, where waste is bulked up prior to its onward transport to a waste management facility. However, the relevant NWFD exemptions do not apply in the case where the waste collector charges a fee. This means that the NWFD exemptions are not applicable in many common circumstances, for example where a landowner (or their contractor) collects waste from different premises on their site and charges their tenants for this service.
RPS 224 effectively says that we will not require an environmental permit for the collection of waste from multiple producers at different premises on a single identifiable site, and for bulking up the waste at a collection point at the same site, prior to its removal into the waste management system – so long as the limits of the RPS are complied with. The RPS allows some preliminary treatments to facilitate onward transport into the waste management chain. However, EA did not want to allow any treatment of food waste, so have separated its collection into RPS 225.
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