3R Technology UK was fined more £80,000 plus costs in March 2026 after pleading guilty to attempting to illegally export contaminated plastic waste to Malaysia.
Last month, they were listed as the first of 25 software companies that Defra had identified as meeting the digital waste tracking requirements.
The addition brings into question the robustness of the verification process, and whether it included checks for previous misdemeanours.
The first phase of Digital Waste Tracking is set to go live in October 2026 when it will apply to 12,000 permitted waste receiving sites.
From October 2027, phase two will extend the regulations to those who are responsible for arranging waste movements and transporting waste, including carriers, brokers and dealers, as well as waste exporters.
A voluntary compliance period for the second phase will run from April 2027 to the mandatory rollout in October.
Companies will have the option to use third-party reporting software to meet the requirements, with Defra releasing a “non-exhaustive” list of potential providers, on which 3R Technology UK was listed.
The list included a disclaimer that the government department is not responsible for “any liability arising from the use of commercial software that you buy from a software provider on the list below”.
When approached for comment on the matter, a Defra spokesperson said: “There are already strict controls in place on the export of waste set out in UK legislation.
“Businesses involved in the export of waste from the UK are required to ensure that the waste they ship is managed in an environmentally sound manner, and we have already taken action to further reduce our need to export plastic waste.
“Schemes like Extended Producer Responsibility encourage businesses to shift to more recyclable materials while Simpler Recycling – our new streamlined approach to separate waste collection – aims to boost recycling rates at home and at the workplace.”
3R Technology UK waste shipment offences
In March 2026, Lancashire-based 3R Technology UK was fined £80,000 and ordered to pay £45,000 in costs alongside a £2,000 victim surcharge.
Its director received a community order of 120 hours’ unpaid work and was ordered to pay £15,000 in costs and a £114 victim surcharge.
The court heard that the company had consigned for export waste falsely described as clean plastic, when in fact it was contaminated with electrical waste such as wiring, circuit boards and mixed materials.
The case followed a lengthy investigation by the EA which ran between April 2022 and February 2025.
Prosecutors told the court that 14 of the offences related to attempted shipments of contaminated plastic waste during that period, while two further offences concerned breaches of prohibition notices issued in August 2024.
The shipments included nine containers consigned for export in April 2022, three more in May and July 2024, and a further two in February 2025.
In 2024, while the investigation was ongoing, another contaminated container was intercepted at Liverpool.
Following these findings, the EA served one prohibition notices on the company in August 2024, requiring it to cease exporting contaminated plastic waste unless it complied fully with regulations.
However, the court heard that two further containers were consigned for export after the notices were issued, both of which were found to contain contaminated waste.
All containers were intercepted within the UK and were not exported to Malaysia. The company has been subject to no further regulatory enforcement action since the offending.
Digital Waste Tracking software
Companies will have the option to use third-party reporting software which must:
- Record and submit the legally required waste movement data
- Send the data via the report receipt of waste application programming interface (API)
- Be integrated with the receipt of waste service API
- Have passed the production approval tests (PATs), proving that it can successfully manage 14 scenarios
An API allows two applications to share data and services securely.
Defra advised that companies enquire if prospective products have been granted and PAT exemptions, for example hazardous waste.
Companies will have until 1 October 2026 to ensure that they are able to submit digital waste records.
Correction: This article was updated on 21 July 2026 to state that the company “pleaded guilty” and was not “found guilty” as stated in the original copy.
Correction: This article was updated on 21 July 2026 to make clear that the total fine to the company was £80,000, with £47,000 incurred in additional costs.
Interested in finding out more about Digital Waste Tracking? Join us at the Digital Waste Tracking Conference in London on 20 October 2026. Find out more and buy tickets here.
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