Guidance

Recovering silver from waste developer and fixer solutions: RPS 360

Published 13 January 2026

Applies to England

© Crown copyright 2026

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This publication is available at https://www.gov.uk/government/publications/recovering-silver-from-waste-developer-and-fixer-solutions-rps-360/recovering-silver-from-waste-developer-and-fixer-solutions-rps-360

This regulatory position statement (RPS) does not change your legal requirement to have an environmental permit where one is required.

However, the Environment Agency will not normally take enforcement action against you if you do not comply with these legal requirements 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 recovering silver from waste developer and fixer solutions used in photographic and X-ray processing machines. 

2. Conditions you must comply with

You must:

  • only treat up to one litre of solution per minute

  • treat the solution in a sealed unit

  • keep records for 3 years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the Environment Agency on request

3. Things to note

This RPS relates to an 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 Environment Agency propose amending the T30 exemption to include the following waste codes for developer and fixer chemicals:

  • 09 01 01* water-based developer and activator solutions

  • 09 01 02* water-based offset plate developer solutions

  • 09 01 03* solvent-based developer solutions

  • 09 01 04* fixer solutions

  • 09 01 05* bleach solutions and bleach fixer solutions

T30 allows you to store and treat up to 1000 litres of waste at any one time. This would reduce the maximum treatment throughput currently permitted under this RPS from 1,440 litres per day.

4. When you must check back

The Environment Agency intends to review this RPS by 31 December 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. Use the ‘Get emails about this page’ feature on the RPS publication page.

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 360 in the subject.

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