Environment Agency and waste transfer notes
The Environment Agency has regulations for waste collection, handling and storage.
This page is intended as guidance only, and as such the site disclaimer applies - use this information at your own risk. Please check with the Environment Agency directly for the current regulations.
So long as oil collection is for personal use and not for profit, the Environment Agency does not regulate collectors under Schedule 1 of the Environmental Permitting Regulations.
You do not need to register as a waste carrier - although you still need to complete Waste Transfer Notes (see below).
Processing and storage
Although non-commercial collectors are usually not regulated, the Environment Agency advise that T19 key limits and conditions should still be complied with.
T19 key limits:
- You can physically treat or store up to 5,000 litres at any one time.
- You can chemically treat up to 250 litres at any one time.
- You can store waste for up to three months.
T19 key conditions:
- The treatment and storage is in a container with secondary containment.
- The operation is solely for the recovery and reuse of the waste as fuel.
“secondary containment” means a bund or any other system for preventing waste which has leaked from the primary container from escaping from the place where it is stored or treated. Where a bund is used as secondary containment:
- (a) the bund must:
- (i) have a capacity of not less than 110% of the original container’s storage capacity, or
- (ii) if there is more than one container within the containment system, have a capacity of not less than 110% of the largest container’s storage capacity or 25% of their aggregate storage capacity, whichever is the greater, and
- (iii) have an impermeable lining; and
- (b) reasonable precautions must be taken to ensure that the capacities specified in paragraph (a) are maintained at all times.
Waste Transfer Notes
The Environment Agency expects restaurants, as producers of waste, to prove their Duty of Care - that is, that they are appropriately disposing of their waste. Failure to dispose of waste correctly can result in large fines - especially if oil waste is placed into skips or poured down the drain, so it is in the best interests of restaurants to have an oil collector.
Collectors are required by the Environment Agency to provide an audit trail for waste transferred from the producer to the collector. This document takes the form of a Waste Transfer Note, which must be signed by both the restaurant and the collector and retained for at least two years.
Filling in a Waste Transfer Note
Download one of these example templates:
- Simple pdf version from EA website. This can be saved, printed and filled in by hand.
- Electronic version. Compile on screen, printable and saveable. Located on the EA website and suitable for single transfers.
- Edited electronic version better suited to WVO collections on a small scale. Includes a drop down menu for SIC codes. To save as a printable form suitable for completion by hand, click "print", "Adobe PDF", then "Save".
- Excel/OpenOffice format Waste Transfer Note suitable for single transfers or regular 'season ticket' collections.
Two copies should be made, both signed, the transferor and transferee retaining one each.
Season tickets can be issued to cover a period up to 12 months, but only where there are no changes to the parties involved in the transfer or the place where the oil is transferred over that period. It is advisable for the collector to maintain a record of individual collections separately to assist with producing totals between specified dates.
Waste Regulation Codes
In the Waste Regulation Codes section, enter 20 01 25.
This is an EU wide code as defined by List of Wastes (2000/532/EC) corresponding to "edible oil and fat".
SIC stands for Standard Industrial Classification (of Economic Activities). These codes are required to comply with Regulation 12 of the Waste (England and Wales) Regulations 2011 waste hierarchy.
The Office for National Statistics sets these codes, and the 2007 codes are required for this section of the Waste Transfer Note.
The codes relevant to us are:
- 10.71 Manufacture of bread; manufacture of fresh pastry goods and cakes
- 55.10 Hotels and similar accomodation
- 56.10/1 Licenced restaurants
- 56.10/2 Unlicenced restaurants and cafes
- 56.10/3 Take away food shops and mobile food stands
- 56.21 Event catering activities
- 56.29 Other food service activities (school, university, staff canteens)
- 56.30/1 Licenced clubs
- 56.30/2 Public houses and bars
- 87.20 Residential care - mental health
- 87.30 Residential care - elderly, disabled, retirement and handicapped children
More detail on which establishments these codes cover (and additional codes for special cases) are available on the ONS website. The Environment Agency maintain a similar list and Companies House offer a list with a useful search facility.
In this section, you would tick the box for 'Exempt from requirement to register as a carrier' and explain that you are collecting the oil or fat to make biodiesel for your own personal use.
A waste transfer note is not needed if waste oil or fat is being transported between private individuals making biodiesel for their own personal use.