There was a strange requirement in the Waste Management Licencing Regulations 1994. Regulation 18 covered registration in connection with exempt activities. 18(1) stated that "it shall be an offence to have an exempt activity involving the recovery or disposal of waste without being registered with the appropriate registation authority." The strange part is the combination of "exempt" and "registration".

What this meant was, that if you had anything like a compactor for, say, your own paper waste, then you were committing an offence if you didn't register it with the Environment Agency. Most people were understandably ignorant of this requirement and I don't know of any examples of the EA taking action against anybody. A moment's consideration shows this to be a requirement which would drive behaviour in the opposite direction to that of good environmental practice; depositing uncompacted paper in skips would mean more frequent lorry journies to remove the waste paper, even if it was being recycled.

In the Permitting Regs., Schedule 21, Part 2 Subordinate Legislation of the Permitting Regulations, paragraph 34 specifically states that "the Waste Management Licencing Regulations 1994 are ammended to ......(3) Omit regulations 1(4) and 2 to 19." Therefore this part of the Waste Management Licencing Regulations has been revoked.

The Permitting Regs., now specifically cover exemption registration.

Schedule 2, para 27 specifies:
(1) Baling, compacting, crushing, shredding or pulverising waste at the place where it is produced
(2) Storage at the place where it is produced where it is to be submitted to such an operation.

Schedule 2 Para. 2 specifies who is the Exemption Registration Authority for a specific list of operations which does not include paragraph 27.

Schedule 2 Para. 3 specifies Registration, Notification and Consent Requirements for Exempt Waste Operations for a specific list of operations which does not include paragraph 27.

In my opinion, the fact that:

would  be interpreted to mean that compactors, balers, etc., do not require exemption registration.

I believe that whoever drafted these regulations realised that it was daft to require everybody who had a compactor for their own waste, or even a bin for their own waste which is subsequently compacted, to be registered for exemption; it would be a bureaucratic nightmare for no benefit.  However, I don’t believe that the Environment Agency understand this yet and there are some who still believe it necessary.

This is an opinion and may be used for reference should the EA suggest that a compactor or anything else which is exempt needs to be registered. It is not a guarantee that they will accept this argument.

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Health & Safety, Environmental and QA Services and Systems


Operation of a waste compactor - a considered view

By Phil Chambers