Waste Carrier, Broker and Dealer registration renewals due after 25 March 2018

Business Benefits, Compliance, Environment Agency, Environmental Management, Hazardous Waste, Waste Leave a comment

Most business collecting and handling waste will be aware that there is a legal requirement for Waste Carriers, Brokers and Dealers to register with the Environment Agency (for England) & with the other Environment Agencies in the devolved administrations.

The Environment Agency has identified an issue in relation to their current online registration system, which does not allow customers who have registered since March 2015 to renew online.

The Environment Agency is working to upgrade their system so customers can renew online, but it may not be ready until after April 2018.

Accordingly, the Environment Agency has issued a Regulatory Position Statement (RPS 208), so that Waste Carrier, Brokers and Dealers can operate lawfully in the interim period.

If you need to renew after 25 March 2018, the Environment Agency will:

  • tell you what you need to do if the extension applies to you when they send you your renewals reminder
  • extend your current registration by 3 months at no extra cost – you will not need to renew until the upgraded online registration system is ready
  • extend the registrations of affected customers in stages until the upgraded online registration system is ready – starting with those due between 25 March and 25 April 2018
  • put a notice on the renewals page of the online registration system telling those affected about the automatic extension
  • make sure your business is still registered and visible on the public register during the extension period

Enforcement
The Environment Agency will not take enforcement action against you if you do not register during the 3 month extension period.

They will take enforcement action against you if you do not register after the 3 month extension period.

Time Expiry of RPS
RPS 208 is time-limited to a further review on 31 March 2018, when it will either be withdrawn due to the resolution of the on-line registration issue or extended at that time for a further period.

A copy of the Environment Agency’s Regulatory Position Statement 208 is freely available here

ACTION POINTS

  1. Review your current activities as a business that is required to re-registered as a Waste Carrier, Broker or Dealer to understand whether the Environment Agency’s RPS 208 applies to your organisation and activities as a compliance obligation.
  2. If RPS 208 applies to your activities to ensure that you comply with its conditions during the interim period: 25 March – 25 April 2018.
  3. Check back with the Environment Agency on 31 March 2018 to review whether RPS 208 still applies as this is their review date for this RPS.
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