Environment Agency and waste transfer notes

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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 EA and HMRC directly for the current regulations.

Introduction

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.

Although commercial regulation does not apply, you should still make sure that you are complying with the key limits and conditions where possible, and duty of care requirements must also be met.

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.

Collection

If the oil is for your own personal use, you do not need to register as a waste carrier - although you still need to complete Waste Transfer Notes.

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:

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".

Collection Authority

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.

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