21 September 2018 by Joshua Doherty

Agency to extend RPS on waste wood classification

EXCLUSIVE: The Environment Agency will extend an interim measure to allow wood recyclers to continue using current methods for handling waste wood including potentially hazardous material.

ca site

The Agency has indicated that early signs are that CA site waste wood is on balance non-hazardous, if the German approach is considered

With a crackdown likely on how hazardous waste wood is classified, the Agency has put any changes on hold for a further nine months while it continues investigations.

And, the Agency is believed to have supported the Wood Recyclers Association (WRA) in setting up a technical working group to look at classifications of waste wood, including a ‘German type model’, in further detail.


The Agency issued a regulatory position statement (RPS) in November 2017, which said that current practices can continue for 12 months while an investigation is launched into hazardous waste wood.

This meant that the current assessment for hazardous wood, which consists of a simple visual assessment, can continue on the condition that the material must be destined for Industrial Emissions Directive (IED) Chapter IV compliant boilers and the board manufacturing industry.

While this was scheduled to be withdrawn on November 1 2018, it has now been extended until September 2019, meaning that the current method will continue for the time being.

Commenting on the extension, Julia Turner, executive director of the WRA said: “The WRA has been leading this project at the request of the EA and has been working with a number of colleagues from other trade bodies to gain a better understanding of the issues.

“The EA has congratulated us on the work so far and has told us they are happy to extend the RPS which will mean low grade waste wood can continue to be sent to panel board and Chapter IV biomass boilers while we complete the project. “


The European Commission had instructed the Environment Agency to investigate why just 2% of UK waste wood is hazardous

The RPS was prompted by the European Commission, which had asked why just 2% of wood in the UK is deemed as hazardous, while in other countries in the EU this figure is as high as 15%.

Previously, the Agency has made no secret that it has based its investigation on the model used in Germany.

Speaking at the North East Recycling Forum quarterly conference in Gateshead in May this year, Howard Leberman, senior advisor for waste treatment & storage at the Agency, said the German model allows greater detail for a visual assessment (see letsrecycle.com story).


The Agency official added, at the May meeting, that in Germany, his counterparts – the Umweltbundesamt – had come up with a waste wood type approach, which allowed the industry there to visually determine what was or was not hazardous.

This would allow the industry to say, according to Mr Leberman, that “if it looks like a door, it’s a door, and if it’s a door, on balance it will be non-hazardous. If it looks like fence post, it is, and so on.”

He also said that the EA investigation has so far found that, on balance, waste wood at civic amenity sites under this method is likely to be non-hazardous, except for very small quantities which won’t affect the classification.

German model

Another aspect of the German model sees all wood split into four sections, ranging from A1 to A4.

A1 is waste wood in its natural state or only mechanically worked which hasn’t come into contact with contaminated substances, ranging to A4, which is waste wood treated with preservatives.

Under the German model, all A4 waste wood, which makes up around 15%, is deemed as hazardous, and must be treated accordingly.

Window frames are considered hazardous wood under the German model

Each type of wood is also given a code, which means workers can simply see a type of wood, for example an outdoor window frame, and immediately know it is classed as hazardous. This is why a higher amount – 15% – of waste wood in Germany is hazardous.

While the Agency’s investigations are based on the German model, it has not necessarily indicated that it will be implementing them exactly once the RPS has finished.

Discussions have been ongoing the exact method the UK takes, as the German model itself could take various forms. For example, the UK could only implement the item grading element of the German model, and not split everything into four sections but already there is some talk of the German four category system being adopted in the UK.

‘Good policy’

Commenting on his country’s hazardous waste wood classification in an interview earlier this year, Simon Obert, managing director of the German wood recycling association, the BAV, explained what he saw as some of the benefits of the country’s system.

Mr Obert said: “This system has been in place for more than 15 years and makes life a lot easier. It means that particularly for construction workers, who are not expected to be experts in hazardous wood classification, it is easy for them to tell what is hazardous or not, even before they start the work,”

In Germany, the equivalent to CA sites there sees wood split into hazardous and non-hazardous, with an expert on hand to separate. However, there has been no indication that this would be introduced in the UK.


To post your comment, please login or signup.

Login Sign up