Guidance

Storing PAS 100 or PAS 110 compliant material at site of production: RPS 358

Published 20 October 2025

Applies to England

This regulatory position statement (RPS) does not change your legal requirement to have an environmental permit for storing BSI certified PAS 100 compost or PAS 110 digestate made from waste on the site of production before dispatch to a customer, when you do not have the records to meet the requirements of the:

• anaerobic digestate: resource framework
• compost: resource framework

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 and the circumstances meet 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

Activity this RPS applies to

This RPS applies to the storage of BSI certified PAS 100 compost or PAS 110 digestate at the site of production or a storage site under your control.

Conditions you must comply with

You must:

• comply with all requirements of the resource framework that applies to you – for compost or anaerobic digestate
• comply with all requirements of BSI PAS 100 for compost or BSI PAS 110 for digestate, and their associated certification schemes
• apply for a new permit for the storage of BSI PAS 100 or BSI PAS 110 materials by 31 March 2026

You must email resourcesframeworks@environment-agency.gov.uk before you use this RPS. You must do this by 31 December 2025. Include:

• ‘RPS 358’ in the subject line
• your name
• your company name
• your contact details
• the address of the site where the material is being stored

You cannot register use of this RPS after 31 December 2025. Instead, you will need to comply with the resource framework requirements in full.

You can continue to use this RPS until a permit has been issued or your permit application has been refused.

If your permit application is refused, you must:

• stop storing PAS 100 or PAS 110 material
• remove all stocks of PAS 100 or PAS 110 from the site within 4 weeks of the date of refusal

Things to note

This RPS only applies to material which has been produced to comply with BSI PAS 100 or BSI PAS 110 under the:

• anaerobic digestate resource framework
• compost resource framework

We only consider the PAS compliant digestate or compost to have met the ‘end of waste’ test when it’s dispatched, or stored when it’s certain it will be used, in line with section 3 of these resource frameworks.

This RPS is to give time for operators to apply for permits or permit variations to store PAS compliant digestate or compost before dispatch to the customer.

When you must check back

This RPS will expire on 20 October 2026.

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

You will need to check back from time to time, including at and before the expiry 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.

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
• tell the Environment Agency immediately by emailing resourcesframeworks@environment-agency.gov.uk with ‘RPS 358’ in the subject line

Contact the Environment Agency

If you have any questions about this RPS, email resourcesframeworks@environment-agency.gov.uk with ‘RPS 358’ in the subject line.