Guidance

Burning dunnage under a Plant Health Notice: RPS 342

Published 2 July 2025

Applies to England

This regulatory position statement (RPS) does not change your legal requirement to have an environmental permit for the burning of dunnage under a Plant Health Notice at the place the goods are delivered.

However, the Environment Agency will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • your activity meets the description set out in this RPS

  • you comply with the conditions set out in this RPS

In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

  • cause a risk to water, air, soil, plants or animals

  • cause a nuisance through noise or odours

  • adversely affect the countryside or places of special interest

1. Activity this RPS applies to

This RPS applies to the burning of wood or plant tissue dunnage at the place where goods are first unpacked. This may not necessarily be at the port, but where the goods are delivered.

2. Conditions you must comply with

You must:

  • only burn dunnage required under a Plant Health Notice

  • only burn plant tissue or wooden dunnage

  • burn dunnage as soon as possible after you’ve removed the product from its packaging

  • store dunnage securely before burning

  • store dunnage under a cover before you burn it so that it does not get wet

You must not burn more than 10 tonnes of dunnage in any 24-hour period

3. Things to note

Dunnage is wood or plant tissue used to wedge or support parts of cargo, including use as packing, spacers and pallets.

Storing securely means members of the public cannot gain access to it. This RPS relates to a waste activity that the Environment Agency considers is potentially suitable to be an exemption under the Environmental Permitting (England and Wales) Regulations 2016. A change in law would be required for this.

The D8 waste exemption allows burning dunnage at a port under a Plant Health Notice.

4. When you must check back

The Environment Agency will review this RPS by 1 April 2028.  

The Environment Agency can withdraw or amend this regulatory position before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn.

5. If you cannot comply with this RPS

If you operate under this RPS but can no longer comply with it, you must:

6. Contact the Environment Agency

If you have any questions about this RPS, email enquiries@environment-agency.gov.uk with RPS 342 in the subject.