Hazardous waste collection

Hazardous waste obligations for businesses

In the UK, all businesses and organisations that produce, handle or receive hazardous waste must ensure it is safely managed in such a way that it causes no harm or damage.

💡 It’s their duty of care and any business that is found non-compliant with regulations will be subject to hefty fines and in extreme cases, legal prosecution.

Essentially, you must not mix:

• a hazardous waste with non-hazardous waste
• a hazardous waste with a non-waste
• different types (categories) of hazardous waste with each other*
• waste oils with different characteristics*

*Doing this is possible only if stipulated on your environmental permit and in special circumstances.

What exactly you need to do depends on the type of waste, the context in which it was generated and any special local regulations.

💡 There are extra duty of care requirements whether your business is a waste producer (most businesses that generate waste), carrier (collect or transport waste) or consignee (recycling or disposal centers), and depending on each home country.

Source: ¹UK Gov guidance – hazardous waste; ²segregation and mixing

What is hazardous waste?

Hazardous waste is the proportion of waste that may be harmful to humans or the environment. Some classic examples include:

• asbestos
• chemicals, such as brake fluid or print toner
• batteries (overlap with WEEE)
• solvents
• pesticides and herbicides
• oils (except edible ones), such as car oil
• equipment containing ozone depleting substances, like fridges
• hazardous waste containers
• aerosol cans, paints and solvents.
• medicines and beauty products

Each of these fits in a different hazardous waste sub-category and a different portion of regulations applies to each.

Source: UK Gov Guidance – hazardous waste

Sectors that generate hazardous waste

While all businesses and organisations in the UK will generate hazardous waste in some way (e.g., batteries, fridges), there are sectors that generate it on a regular basis.

Examples include:

Source: UK Gov – Official statistics on waste (2023)

Categorising hazardous waste

⚠️Categorising hazardous waste is crucial because mixing between types can increase corrosiveness and dangerous properties and even ruin its recyclability or re-processing. See where this fits into a business’s workflow here.

It requires staff that has the technical know-how of your business/industrial processes. We recommend familiarising yourself with the up-to-date technical guidance that applies to England, Wales and Scotland:

• UK Technical Guidance on Waste Classification (Last update: Oct 2021)

Here are the key categories:

By chemical reaction potential:

Hazardous wastes that can react when mixed should be carefully separated. For instance, hazardous alkaline waste and acid waste must be handled and stored separately.

By removal, reduction or dilution potential:

Hazardous wastes that can remove, reduce or dilute one another should remain separate. Not doing so makes it difficult for waste contractors and processing facilities to identify them (i.e. costly and dangerous!).

By changes in recyclability or processing:

Hazardous wastes with a specific recyclability or processing potential should not be mixed with others, as it may make these options unviable.

By oil content:

Mineral oils, cooking oils, halogenated oils, brake fluids, antifreeze, washer fluids and oily waters are different categories and must not be mixed by producers or carriers collecting them.

Note that the same oil and water mixes from different sources and concentrations can be mixed together, as long as the oils are of similar composition.

Important notes:

💡 These are non-exclusive categories; each waste item will likely be in multiple categories simultaneously.

💡 Businesses who accidentally mix waste products have the duty to separate it, as long as it’s technically feasible to do so.

💡 Businesses working in residential properties are prohibited from mixing their hazardous waste with the mixed municipal waste stream.

Source: UK Gov guidance – Segregation and mixing

Filling out hazardous waste consignment notes

Consignment Notes are mandatory paperwork required when moving hazardous waste within a business, from one site to another or when transferring it to your waste disposal provider.

⚠️ Consignment Notes can be used as evidence of non-compliance and the original must be stored for three years.

The  consignment note that is co-signed with the contractor must include the following:

• the waste classification code
• whether it’s hazardous or POPs waste
• the type of premises or business where the waste was produced
• the name of the substance or substances
• the process that produced the waste
• a chemical and physical analysis of the waste and its components
• any special problems, requirements or knowledge related to the waste

Consignment note templates

Use these official templates to fill in your consignment notes:

• England (Environmental Agency): Template for hazardous waste consignment note and their supplementary guidance.
• Wales (Natural Resources Wales): Template for hazardous waste consignment note and their supplementary guidance.
• Scotland (SEPA): Special waste guidance and templates.
• Northern Ireland (NIEA): Guide to consigning hazardous waste

💡 There are small regulatory differences between each home nation so make sure to use the correct consignment note template (e.g. Scotland calls is Special Waste Consignment Note).

💡 You will find all pertinent details in the UK Technical Guidance on Waste Management, including the LoW (List of Waste) or EWC (European Waste Catalogue) classification codes for hazardous waste.

Source: ¹UK Gov guidance – Classify different types of waste, ²UK Gov guidance – Consignment Notes