29 July 2019 by Joshua Doherty

Agency changes aimed at tackling illegal waste exports

The Environment Agency has intensified its work to prevent illegal exports of packaging waste, industry representatives have been told.

Steps being implemented by the Agency to address illegal exports were outlined in a three-page document last week (July 22), circulated via the Advisory Committee on Packaging.


Environment Agency officers inspect a consignment of waste

The document explained that since April, a new structure at the Agency has meant that waste shipments and producer responsibility activity are managed by a single national team.

“This means that officers are able to focus solely on this work, with associated improvements in levels of expertise and resilience, flexibility to target our resources nationally where there is highest risk,” the Agency said.

This has been supplemented by the formation of a ‘Producer Responsibility Investigation (PRI) team’ set up in 2018, which is carrying out investigations around producer responsibility, material recovery facilities, separate collections and international waste shipments offences.


And, the Agency said that the process for assessing applications for accreditation of packaging exporters has been improved, by “increasing the level of information required to demonstrate that exported waste is high quality with minimal contamination”.

Any applications that can’t demonstrate they comply with the regulatory requirements are not accredited – with a total of 11 applications having been rejected for 2019. Another six operators withdrew their applications for accreditation as the updated process highlighted they would be unable to comply with the Regulations without significant business change, the Agency said.

“Waste exports are a potential environmental risk since we have limited regulatory control once the waste arrives overseas.”

Environment Agency

Additional resources are also being used to tackle illegal exports taking place via Roll on – Roll off (RoRo) lorries on ferries, with inspections taking place on 1,012 shipping containers of waste at English ports, resulting in the return of 367 containers to waste sites since 2017/18.

The Agency says that it is also undertaking a review of HRMC waste export data, compared to that recorded on the National Packaging Waste Database (NPWD) to identify any inconsistencies between the two datasets, and to understand why these may occur.

Annex VII

Other ongoing initiatives include an Annex VII trial, whereby exporters are asked to provide returned Annex VII forms three days prior to export to identify any potential anomalies within the paper work.

The Annex VII trial, which began in January, has so far assessed 3,096 forms, which has resulted in nine stop notices to prevent the export of unsuitable waste.

The Agency noted: “The information from Annex VIIs has led to a joint investigation with an overseas Competent Authority to tackle concerns identified with an overseas recycling facility. This approach has also disrupted illegal activity (we have seen a reduction in the volume of waste exported by some operators since starting the trial).”

In January the Agency revealed that it would be increasing the focus on the monitoring of sites issuing packaging waste recovery notes (PRNs) in 2019.

This came following criticism of government and the Agency over a lack of oversight over sites issuing PRNs – particularly those exporting material overseas for recycling.


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