OPINION: As the leaves fall and the nights draw in, recycling companies and exporters across the UK are once again reflecting on the annual ritual of Environment Agency accreditation. But this year, the process has felt markedly different not just in tone, but in substance, cost and consequence.
2025 has brought some of the most significant changes to the accreditation framework in recent memory. For many, it’s been a year of recalibration of systems, budgets and expectations. For some it will be a year of surrender where they decide the regulatory burden simply isn’t worth the ticket price to enter an uncertain market.
The question now is whether these reforms will genuinely elevate standards across the industry, or whether they risk deepening the divide between compliant operators and those who continue to flout the rules. Plus, there remains the ongoing question of where the money is being spent.
The 2025 requirements have brought with them four key areas of change which recyclers and exporters have needed to navigate.
1.Introduction of a new registration process
A formal registration step was added for each grade requiring accreditation, increasing the complexity and length of the overall process. What was once a relatively streamlined procedure now requires greater attention to each material stream.
1. Transition to the new RPD system
The rollout of the EA’s new digital portal, RPD system that users needed to navigate to submit their accreditation application demanded time to learn, navigate and adapt. Initial unfamiliarity added delays during data entry and submission, with many users reporting technical issues and unclear guidance. With the service going live in August and with the deadline for submissions (if you hope to be accredited on 1 January 2026) being 1 October, limited time was available to adapt to the new system.
2. Higher administrative burden
While the increased robustness of the process is welcomed from a compliance and integrity perspective, the administrative workload has grown significantly. For example, to add end users to the platform navigation coordinates for the plant were required. Gathering this detailed data and other documentation has placed additional strain on internal teams. Compounded by the fact the time available to complete the submission, or time the regulator will take to assess the application, remained unchanged.
3. Compliance work-hours more than tripled
Due to increased complexity and manual data requirements, the time required from compliance teams has more than tripled compared to the previous year. A lack of clarity and support from the authorities has made the application process extremely challenging to navigate. For a well-staffed and experienced team this created challenges, for small operators or brokers the time required would have seriously impeded their ability to operate their business during the process.
The burden of direct costs
While Clearpoint remain advocates of a more rigorous and robust accreditation process it does raise the concerns as to how diligent people are in adhering to what they agree to. If there is a box that needs ticking smaller organisations will generally tick it, but will they change the way they operate to reflect it and with audits for this upcoming compliance year fourteen months away, how will anyone know.
However, the administrative burden is a minor issue when compared to the direct costs now involved in accreditation.
Speaking from personal, Clearpoint Recycling have faced a more than 2200% increase in accreditation fees year on year. Rather than a single registration fee of £2,616 each grade brings with it a registration fee of £2,921. On top of this is an Accreditation Cost which is based on the volume of material covered for each grade. Before lastly adding a £216 fee for all end users, an increase of £131 from last year. Added to this was the clarification that additional end users, added after accreditation may not be approved for up to 12 weeks and unlike previous years, PERNs generated prior to registration could not be back dated. There was even suggestion the export to an unregistered end user would be seen an illegal waste shipment.
At a time when the work required to comply with an accreditation has increased significantly for a business to shoulder such a significant cost in one go limits its ability to invest in the people and infrastructure to manage it, once achieved.
For responsible operators, these changes represent a double-edged sword. On one hand, they reinforce the importance of doing things properly, of maintaining robust systems and demonstrating accountability. On the other, they limit the scope of the business to invest in the people and systems to remain compliant. The Environment Agency is about to receive a huge boost in funding from this year’s accreditation process. We can only hope this money goes into more proactive enforcement of those who tick the box but don’t change their behaviour and those that don’t bother to tick the box at all.
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