Environmental Legislation Update

Please find below, an update on changes to Hazardous Waste Regulations, which may impact on the operation of your buildings.

Changes to premises registration and the consignment note number format

Changes have been made to the Hazardous Waste Regulations which will affect business waste management operations, if you have a premises registered with the Environment Agency as a hazardous waste producer.

As of 1^st April 2016, two changes to the Regulations will be implemented:

• Producers of hazardous waste in England will no longer need to notify their premises to the Environment Agency.
• The format of the unique consignment note code, which appears on every consignment note will change.

Why have the changes been implemented?

This change has been driven by the Government’s ‘Red Tape Challenge’ – to remove unnecessary administrative burden within environmental legislation.

Registration 

• If you produce or store 500kg or more of hazardous waste per year you will no longer need to register your premises with the Environment Agency from 1 April 2016.
• You must continue to have a valid registration up until 1 April 2016
• These changes only apply to England. It does not affect premises in Wales who should continue to register with Natural Resources Wales

Consignment Note Code Format

Completed consignment notes must accompany hazardous waste when moved from any premises. From 1 April 2016 the way you complete a consignment note will change.

• To accommodate the removal of premises registration, the format of the consignment note code will change 1 April 2016 regardless of the amount of hazardous waste you produce, store or handle.
• From 1 April 2016, if waste is produced in England, you will need to amend the first six characters of your consignment note code (currently the premises registration number), replacing them with the first six letters or numbers (not symbols) of the business name.  The producer should ensure consistent use of the organisation name in this regard.
• ‘EXEMPT’ will no longer be used.
• The second set of characters will continue to be five numbers or letters of your choosing. This may, in a few specified occasions, be followed by an additional letter.
• There will be guidance on gov.uk from 1 April 2016.
• Please check you are using the correct format of the consignment note number. Legally you are still required to use the current format on consignment notes up until 1 April 2016.
• Make sure you do not pre-print more consignment notes using the old format, than you will use by the end of 31 March 2016.
• If you are receiving waste from Wales into England, you should not change the consignment note code. Welsh producers will still be required to register their premises with Natural Resources Wales and use this is their consignment note number.  If the waste is moved from England into Wales, Scotland or Northern Ireland from 1 April 2016 the consignment note code will need to use the new format.

SIC Code

Requirement for the SIC code on the consignment note will change.

Currently the following codes are accepted: SIC 2003, SIC 2007, or NACE on the consignment note.

From 1 April 2016, the SIC codes published in 2007 should be used only. This aligns with the non-hazardous waste transfer note requirements for SIC codes. NACE can still be used (as per an Environment Agency issued Regulatory Position).

Please don’t hesitate to call EVORA if you have any questions.

Paul Sutcliffe    | t: 07557 529104 | e: [email protected]
Chris Bennett   | t: 07810 631599 | e: [email protected]