The letter, written by ESA chairman Gavin Graveson, highlights that the 2023 National Waste Crime Survey found nearly a fifth of all waste in the UK, amounting to 34 million tonnes annually, is being illegally managed. Furthermore, it says that 20% of those involved in commercial waste handling are engaged in criminal activities, often linked to organised crime.
Expressing disappointment in the lack of progress in combatting waste crime, Mr Graveson emphasised that “despite the Agency’s on-the-ground knowledge and the insights from the waste crime report, the situation has not improved and has, in fact, deteriorated.”
Target
The letter highlights that the ESA believes the government’s target of eliminating waste crime by 2043, outlined in the Environmental Improvement Plan, is “unattainable without a significant change in approach and allocation of resources”.

To this end, the ESA assures its readiness to support the Environment Agency in improving its strategies and calls for increased dedicated resources to meet this critical target.
The letter explains that the value of waste has soared in recent years due to policies and legislation aimed at diverting waste from inexpensive landfill sites, moving it up the waste hierarchy. Today, a truckload of waste is worth at least £2,000, compared to a mere £200 three decades ago, according to Mr Graveson. Therefore, “it is crucial that enforcement actions consistently succeed in reducing the potential for economic gain associated with waste crime, and that they do so promptly”.
In light of these challenges, the ESA presents a “call to action to address waste crime effectively”:
- Allocation of adequate resources to tackle waste crime
- Implementation of more effective enforcement measures
- Fast-tracking regulatory reform
- Improvement of waste crime measurement methodologies
Crossroads
The ESA warns that the industry is at a crossroads, and failure to act will allow it to further fall into the hands of criminals. Collaboration between the ESA and the Environment Agency is sought to “eradicate illegal activities from the sector, enabling ESA members and other legitimate operators to contribute to a circular economy in England while safeguarding the natural environment”.
In the closing statement of the letter, Gavin Graveson said he “welcomes an early meeting with Philip Duffy to delve deeper into this pressing issue.”
Agency
Mr Duffy will replace sir James Bevan, who came in for some criticism from parts of the industry for his record on waste crime.
The executive director of the ESA, Jacob Hayler, previously said the new leadership team will have “their work cut out for them, as far as our industry is concerned, to reverse a legacy of dismal performance across the vital enforcement and regulation” (see letsrecycle.com story).
Mr Bevan also irked the former Recycling Association chief Simon Ellin with his comments on waste exports see letsrecycle.com story) . When Mr Bevan said the existing guidance is “clear”, this led to a strongly worded statement from the outgoing Mr Ellin in March. He said: “Perhaps we are fortunate that Sir James is stepping down from his role at the end of this month, as this isn’t the first time he has overstepped the mark as a civil servant by giving his inaccurate personal opinion”.
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