INDUSTRY NEWS
MARCO MUIA BSc (Hons) MSc MCIWM, Managing Director at Oaktree Environmental Limited. Marco specialises in all aspects of waste planning, environmental regulation and training, including COTC/OCC assessment.
01606 558833 |
marco@oaktree-environmental.co.uk | @wastechat ENVIRONMENTAL European Wasted Catalogue
I SPEND plenty of time during my working week dealing with waste coding queries and the one thing that stands out is that many people don’t know nearly enough about how to properly code wastes using the European Waste Catalogue (EWC).
It isn’t their fault and I am not alone in finding it the most frustrating, incomplete and ineffective system for regulating the coding of waste. It doesn’t help that there is no detailed, definitive guide on the coding of non-hazardous wastes either, with most of the guidance focused on hazardous waste.
All four of the UK regulators subscribe to “Technical Guidance WM3 ‒ Guidance on the classification and assessment of waste (version 1.1 2018)”, which is very thin on the coding and classification of non-hazardous waste. I can only find additional guidance issued by the
Scottish Environment Protection Agency (SEPA), which has drafted two current additional guidance documents which include a Waste Thesaurus and Guidance on using the EWC. When we
As we are dealing with criminal law and proceeds of crime legislation, disagreement in waste coding can be the difference between compliance and financial ruin.
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have no borders to waste movement in the UK why do we not have consistent guidance?
The original EC Decision 2000/532/ EC, which established the EWC and more recent updates, does not offer very detailed guidance either. In the withdrawn 2006 List of Wastes Guidance issued by the Environment Agency, the following paragraph was always of interest and is retained in the SEPA Guidance on using the EWC, which is reproduced below and clearly came from the same train of thought.
EA List of Wastes Guidance (2006) withdrawn
“43. Many wastes are delivered to waste management facilities for transfer or treatment prior to their final disposal or recovery. Wastes that are not subject to any treatment that changes the essential physical or chemical properties of the waste, apart from compaction retain the same LOW codes and descriptions as when the waste was originally collected. This applies to mixed wastes where some components are separated at a facility but the amount is not sufficient to change the nature of the waste and it is still most accurately described by the original description.”
SEPA Guidance on using the EWC (2015) current
“7.2 Where a treatment process does not change the physical or chemical properties of waste, then the treated waste should retain the same EWC code and description as when it was originally collected. This is because the waste has not changed nature or form and so the original EWC code is still appropriate to describe it. This applies particularly to minor sorting of mixed wastes, where a few components are removed, but where the amount of sorting is not sufficient to change the overall nature of the waste.”
The reason for showing you the above guidance extract is that I am interested to hear readers’ stories relating to the coding of waste and guidance they have received from their regulator. I am aware of numerous instances where regulators in England and Wales have issued judgments on CAR forms that are confusing and if detailed guidance was available to them it would be easier to obtain clarification, particularly in the case of screened soils, for example, being classified as trommel fines. As we are dealing with criminal law and proceeds of crime legislation, disagreement in waste coding can be the difference between compliance and financial ruin. More to follow, I think!
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