Issued on Tuesday (16 December 2025), RPS 361 replaced the previous waste wood RPS and allows sites in England to temporarily exceed their permitted storage limits where they have been affected by unplanned downtime at end destinations such as biomass plants, incinerators and panel board manufacturing facilities.
The new RPS extended its scope to include sites storing waste wood destined for panel board manufacture, marking the first time these operations have been explicitly covered.
Such sites were excluded from the previous RPS 352, which was introduced in June 2025, despite repeated calls from the Wood Recyclers’ Association (WRA) for the omission to be addressed.
Vicki Hughes, Technical Lead on the WRA Board, commented: “At what is a very challenging time in the market, this RPS gives permitted sites storing waste wood in England the opportunity to apply for additional storage and help ensure this material is not sent to landfill or incineration.
“We are also delighted that the EA has listened to our feedback about the details of the RPS and has included sites which handle wood destined for panel board manufacture in its scope and also promised to take into account past issues with plants, as we have made them aware that the problem isn’t just arising now, it’s the impact of the previous six months.”
What does RPS 361 allow?
Under RPS 361, permitted waste wood sites that are experiencing a backlog of material due to disruption at downstream outlets can apply to store volumes above their existing permit limits on a temporary basis.
Operators wishing to rely on the RPS must notify the EA and receive confirmation that they can use it. They will also need to justify:
- Why they need to exceed storage limits
- By how much and for how long
- How they will manage the additional environmental and fire risks associated with increased stockpiling
The RPS is due to be reviewed by 31 July 2026.
The replacement of RPS 352 was first flagged earlier this month at the WRA’s members’ meeting in Birmingham.
Speaking at the event, Howard Leberman, Senior Advisor and Team Leader at the EA, said: “We are going to replace RPS 352 with another Regulatory Position Statement specifically for waste wood, so if there are pressures through your end destination – incinerator or panel board manufacturing – you can take advantage of the RPS.”
Sustained pressure in the waste wood market
The introduction of RPS 361 comes against the backdrop of what the WRA has described as unprecedented pressure in the waste wood market.
The association raised concerns in early November 2025, warning that the sector was “under significant pressure” as stockpiles continued to grow across the country.
Many operators have been forced to pause or restrict intake, with limited outlets available for material.
According to the WRA, the situation began in March 2025, when several of the UK’s largest waste wood users – including biomass plants and panel board manufacturers – were impacted by a combination of planned maintenance shutdowns and unexpected outages.
These disruptions significantly reduced demand for waste wood, leaving recyclers with few options to move material on.
Subscribe for free