Guidance

Storing and treating waste clothes hangers: RPS 285

Published 14 September 2023

Applies to England

This regulatory position statement (RPS) does not change your legal requirement to have an environmental permit for a waste operation when you:

• store and mechanically treat plastic and metal waste clothes hangers under a T4 waste exemption

• store and manually treat additional types of waste clothes hangers to those allowed under a T12 waste exemption

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 storing and manually or mechanically treating single and mixed material waste clothes hangers.

The T4 exemption allows you to store and mechanically treat plastic packaging (including plastic clothes hangers), but does not include the composite packaging waste code for clothes hangers consisting of plastic and metal.

This RPS allows you to store and mechanically treat plastic packaging (including plastic clothes hangers) consisting of plastic and metal (waste code 15 01 05) under a T4 exemption.

The T12 exemption allows you to store and manually treat coat hangers, but does not include the relevant packaging waste codes.

This RPS allows you to store and manually treat waste clothes hangers under the T12 exemption, with waste codes:

• 15 01 02 - plastic packaging

• 15 01 03 - wooden packaging

• 15 01 04 - metallic packaging

• 15 01 05 - composite packaging

2. Conditions you must comply with

To store and mechanically treat waste clothes hangers consisting of plastic and metal under a T4 exemption you must:

• register the T4 exemption

• store and treat the waste clothes hangers within a building

• comply with all other conditions and limitations in the T4 exemption

• keep records for 2 years to show that you have complied with this RPS and make these records available to the Environment Agency on request

You must not:

• store more than 200 tonnes of waste clothes hangers at any one time

• treat more than 100 tonnes of waste clothes hangers over any 7 day period

• accept more than 5,000 tonnes of waste clothes hangers per year

To store and manually treat waste clothes hangers classified as packaging waste under a T12 exemption you must:

• register a T12 exemption if you are relying on a T12 exemption

• comply with all other conditions and limitations in the T12 exemption

• keep records for 2 years 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.

If you follow the conditions in this RPS, you will be treated as if you hold an environmental permit when you apply for accreditation as a reprocessor of packaging waste under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended).

4. When you must check back

The Environment Agency will review this RPS by 31 December 2025.

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.

5. If you cannot comply with this RPS

If you operate under this RPS but can no longer comply with it, you must stop the activity to which this RPS relates and must tell the Environment Agency immediately.

6. Contact the Environment Agency

If you have any questions about this RPS email enquiries@environment-agency.gov.uk and put Storing and treating waste clothes hangers: RPS 285 in the subject.