WASTE EXEMPTION REFORM: WHAT BUSINESSES NEED TO KNOW

Waste exemption rules are changing in England with new charges, tighter conditions, increased record-keeping, and wider waste reforms being introduced.

For businesses, this means waste exemptions need regular attention.

Food manufacturers, public sector organisations, and waste and environmental businesses should review their current arrangements, including:

• Registered exemptions
• Waste types and volumes
• Record-keeping processes
• Storage and treatment activities
• Future registration and compliance costs

With further changes being phased in, understanding the current requirements is important for businesses managing waste today.

Luckily, you’re in the right place! Read on to understand what’s changing and how your business may be affected.

WHY ARE WASTE EXEMPTION RULES CHANGING?

Waste exemptions allow certain lower-risk waste activities without requiring a full environmental permit.

However, the Government says some exemptions have been misused, creating environmental risks and making illegal waste activity harder to control.

The scale of waste crime across the UK is significant.

Around 20% of waste is estimated to be illegally managed, costing the English economy around £1 billion each year.

Fly-tipping also remains a major concern. Local authorities recorded 1.26 million incidents in England during 2024/25, up 9% from the previous year.

There were also 749 new illegal waste sites recorded in 2024/25.

The reforms aim to strengthen oversight, improve accountability, and make it harder for waste exemptions to be misused.

WHAT IS A WASTE EXEMPTION?

A waste exemption allows certain lower-risk waste activities to take place without an environmental permit.

To qualify, the activity must meet specific conditions covering:

• How waste is stored
• How the activity is managed
• What treatment can take place
• The type and amount of waste handled

It’s important to remember that an exemption does not remove an organisation's environmental responsibilities.

If activities no longer meet the conditions, the business may need to change its operation or apply for an environmental permit.

That’s why it’s important to consider waste activities across the whole site, not just individual exemptions.

WASTE EXEMPTION CHARGES

Most businesses now need to pay to register for waste exemptions.

The upper band applies to T8, T9, and U16 exemptions.

Discounted compliance charges can apply where multiple Upper, Band 1, or Band 2 exemptions are registered together. Band 3 is excluded.

Exemptions are valid for three years, so remember to factor renewal charges into future budgets.

Charges can also change over time, with the latest update taking effect in April 2026 in line with the Consumer Prices Index (CPI).

Organisations working exclusively for charitable purposes don’t have to pay waste exemption charges.

SOME EXEMPTIONS ARE BEING REMOVED

Three exemptions are being removed as part of the reforms:

• T9 - recovering scrap metal
• T8 - mechanically treating end-of-life tyres
• U16 - using depolluted end-of-life vehicles for parts

Conditions are also changing for seven other exemptions:

• T12 - manual treatment
• S1 - storage in containers
• T4 - preparatory treatments
• T6 - treatment of waste wood
• U1 - use of waste in construction
• S2 – storing waste at a secure site
• D7 - burning vegetation at the place of production

Businesses should always check the latest GOV.UK guidance for each exemption they use.

USING MULTIPLE EXEMPTIONS? REVIEW THE WHOLE SITE

A business may have several exemptions registered for different waste activities.

Looking at each separately may not give a complete picture of the site's overall waste activity.

That’s why it’s important to review:

• Storage and treatment activities
• The total waste activity at the site
• Whether site operations have changed
• Whether a permit may now be required
• How exemptions are being used together

The reforms will also introduce tighter rules on how multiple exemptions can be used at the same site. This includes restrictions on combining exemptions.

This is particularly important for larger sites, manufacturers, waste operators, and organisations with several waste-related activities.

KEEPING ACCURATE RECORDS IS BECOMING MORE IMPORTANT

The reforms also introduce new record-keeping requirements for waste exemption activities.

Businesses should make sure their records accurately reflect current waste activities, volumes, and how exemptions are being used.

Regular reviews are increasingly important to ensure that exemptions still reflect how your site operates.

DIGITAL WASTE TRACKING IS NOW UNDERWAY

Digital waste tracking is another major part of the wider waste reform programme.

The system is designed to improve visibility of waste movements and strengthen the information available to regulators.

From 1st October 2026, permitted and licensed sites receiving waste in England and Wales must report digitally.

Records must be submitted within two working days, starting from the day after the waste is received.

The first phase applies to permitted and licensed sites receiving waste. Waste exemptions are not included in this first phase and are planned for a later stage.

The wider reforms will also change how carriers, brokers, and dealers are regulated, with these businesses moving into the environmental permitting regime.

WHO DOES THE REFORM AFFECT?

The changes are particularly relevant to businesses that store, treat, recover, use, or receive waste.

This includes:

• Food manufacturing businesses
• Waste transfer and recycling facilities
• Construction and demolition businesses
• Waste and environmental service providers
• Land remediation and soil treatment operations
• Public sector organisations managing multiple sites
• Businesses using several waste exemptions at one location

Businesses using third-party waste contractors should also check their arrangements and make sure suitable records are maintained.

WHAT SHOULD BUSINESSES DO NOW?

Organisations shouldn’t wait until an exemption reaches its renewal date before reviewing their arrangements.

Here's what to do:

1. Review your exemptions - Check every exemption registered at each site and confirm it still reflects the activity being carried out.
2. Check the conditions - Review waste types, volumes, storage requirements, treatment activities, and other conditions.
3. Look at the whole site - Consider how exemptions and waste activities operate together. Don't assess each exemption in isolation.
4. Check what has changed - Review changes to: Waste types, site layouts, contractors, storage areas, production volumes, treatment processes, and waste destinations.
5. Remove exemptions you no longer need - Consider deregistering exemptions that are no longer required. This can reduce unnecessary administration and avoid future charges
6. Review your records - Make sure waste records are accurate, current, and easy to access.
7. Prepare your digital records - Businesses receiving controlled waste at permitted or licensed sites should check whether the new reporting requirements apply. With requirements now in force, make sure responsible teams understand what needs to be recorded and reported.
8. Budget for ongoing compliance - Allow for registration charges, compliance charges, renewals, and any operational changes resulting from the reforms.

KEEPING WASTE COMPLIANCE ON TRACK

Managing waste exemptions isn’t a one-off task.

The key questions are simple:

• What is registered?
• What happens on site?
• Do the two still match?

Regular reviews can highlight unnecessary exemptions, changing requirements, record-keeping gaps, and potential permitting needs.

Waste tracking and reporting are also becoming increasingly important across the wider waste chain.

For the latest requirements, always check current Environment Agency and GOV.UK guidance.

HOW SMI CAN SUPPORT YOUR WORKPLACE

Waste compliance is only one part of keeping workplaces safe, organised, and running smoothly.

SMI supplies workplace essentials, including waste management products, cleaning and hygiene supplies, and PPE.

From everyday waste handling to cleaning and site safety, we can help keep essential workplace supplies simple.

Ready to get started? Speak to our team!