Dispose of waste to landfill
What you need to do before you send waste to a landfill site.
Applies to England
This guide is for businesses and waste treatment operators that send waste to a landfill site. You must also follow the rules for how to dispose of business waste.
Before you dispose of waste to landfill you must:
- treat the waste, with some exceptions - see the section on ‘Treat waste for landfill’
- classify it as hazardous or non-hazardous
- characterise it so you can decide which class of landfill site to send it to
You must complete the:
- waste information (formerly a transfer note) or hazardous waste consignment note
- waste description including the basic characterisation of the waste – see the section on ‘Characterise your waste: level 1 waste assessment’
Landfill operators must pay landfill tax on the waste they dispose of. They will normally pass that cost on to you. Read Excise Notice LFT1: a general guide to landfill tax.
Businesses that produce waste
A waste treatment operator or haulage contractor will usually take your waste to the landfill site. As the original producer of the waste, you must provide them with information so they can decide what treatment is needed. Read the waste duty of care code of practice.
If you treat your own waste and send it to landfill, you must follow this guide. You must also comply with the waste duty of care.
Banned waste
You cannot send some waste to landfill. This includes:
- any liquid waste including waste water but excluding sludge – liquid waste is defined in environmental permitting guidance: the landfill directive, section 4.14
- waste that would be explosive, corrosive, oxidising, flammable or highly flammable in the landfill
- infectious medical or veterinary waste
- chemical substances from research and development whose effects are not known
- whole or shredded used tyres – apart from bicycle tyres and tyres with a diameter of more than 1,400mm
- waste paper, metal, plastic or glass that has been separately collected to prepare it for reuse or recycling
- textiles and foam from waste upholstered domestic seating that contain persistent organic pollutants
Where you have treated separately collected waste paper, metal, plastic or glass, you may send residual waste from that treatment to a landfill permitted to accept it. You must use the waste hierarchy to make your decision.
Find out about separately collected waste.
Textiles and foam from waste upholstered domestic seating are likely to contain persistent organic pollutants and other hazardous chemicals. You must not send these for disposal in any class of landfill. Read manage waste upholstered domestic seating containing persistent organic pollutants (POPs).
If you cannot send your waste to landfill you must find another way to recover or dispose of it. You must comply with the waste hierarchy.
Treat waste for landfill
You must usually treat waste before you send it to landfill. Your proposed treatment must both:
- be a physical, thermal, chemical or biological process including sorting
- change the characteristics of the waste to reduce its volume or hazards or make it easier to handle or recover
The Environment Agency does not consider compaction to be treatment, as it does not change the characteristics of the waste.
You do not need to treat:
- inert waste where treatment is not technically feasible
- non-hazardous or hazardous waste where treatment would not reduce its quantity or the risk to people’s health or the environment
The Landfill Directive defines inert waste. You can find that definition at the start of landfills for inert waste.
You can treat waste by sorting different components from mixed waste and sending some of it for recycling, reuse or recovery.
You must confirm in writing to the landfill operator, either:
- that you have treated your waste
- why you did not need to treat your waste
You must describe the output of the treatment as part of the waste’s basic characterisation and to comply with your waste duty of care.
If the producer classified their waste as hazardous before treatment, follow the procedures for reclassifying the treated waste in the waste classification technical guidance WM3.
You must show that the treatment has made the waste acceptable for disposal at the class of landfill you’re sending it to.
Contact the landfill operator to find out the types of waste they are allowed to accept.
Classify your waste
You must assess and describe all waste you produce before sending it for recovery or disposal. You must decide if it’s hazardous or non-hazardous. Non-hazardous waste includes inert waste. Read the guide for how to classify different types of waste. The laboratory you use will use different tests to classify your waste to the ones they must use to characterise your waste.
You must classify mirror-entry wastes as hazardous or non-hazardous. This normally requires you to test it. These include wastes typically sent to landfill, for example:
- 17 05 03* soils and stones containing hazardous substances
- 17 05 04 soils and stones other than those mentioned in 19 05 03
- 19 12 11* other wastes (including mixtures of materials) from mechanical treatment of waste containing hazardous substances
- 19 12 12 other wastes (including mixtures of materials) from mechanical treatment of waste other than those mentioned in 19 12 11
- 19 13 01* solid wastes from soil remediation containing hazardous substances
- 19 13 02 solid wastes from soil remediation other than those mentioned in 19 13 01
Characterise your waste: level 1 waste assessment
For disposal to landfill you must carry out a basic characterisation.
Once you have classified your waste, the basic characterisation will help you decide which class of landfill site you can send your waste to. The waste must meet the waste acceptance criteria (WAC) and waste acceptance procedures (WAP).
You cannot use basic characterisation to classify your waste. It is a separate process. You can ask the laboratory to do both at the same time.
Basic characterisation
The basic characterisation of your waste must include:
- the source and origin of the waste
- confirmation that the waste cannot be recycled or recovered
- the standard industry classification (SIC) code for the process that produced the waste – including a description and characteristics of raw materials and products
- a description of the waste treatment – or a statement explaining why you do not need to treat
- testing data on the composition of the waste and its leaching behaviour, where relevant
- a description of the appearance of the waste – including smell, colour, and physical form
- the European Waste Catalogue (EWC) code – find the codes in appendix A of WM3
- for hazardous waste, the hazard properties code – find the code in appendix C of WM3
- confirmation that the waste is not a banned waste – see the section on ‘Banned wastes’
- the landfill class that can accept your waste – landfill for hazardous, non-hazardous or inert waste
- if necessary, additional precautions the landfill operator must take
Basic characterisation following treatment
If a waste treatment operator keeps waste separate and does not mix it with other wastes before they send it off site for disposal, they can use the classification and basic characterisation provided by the producer.
If you send mixed waste to landfill, you must classify and describe each component separately. You must use the basic characterisation to decide what treatment to use before you send mixed waste to landfill.
Where a waste treatment operator needs to send one or more components to landfill, they must classify the treatment output and produce a new basic characterisation after they:
- mix wastes
- sort components from mixed waste
Testing for basic characterisation
You must normally test your waste to confirm its composition. You can use the results from waste classification testing. You must include tests for the contaminants most likely to be in your waste. You can base this on the inputs to the treatment or production process.
You must normally test the waste’s leaching behaviour where you send it to a landfill or cell for:
- inert waste
- hazardous waste
- stable non-reactive hazardous waste
- gypsum-based material
You must use the up-flow percolation test (EN 14405) in the Council Decision annex, section 3. This is a WAC leaching behaviour test.
When you do not need to test for basic characterisation
You do not need to test for basic characterisation when:
- the waste is listed in section 2.1.1 of the Council Decision annex
- the waste is treated, non-hazardous municipal waste uncontaminated by other substances or objects, listed in Chapter 20 of the European waste catalogue, including separately collected fractions of non-hazardous household waste and the same non-hazardous waste from other sources, for example shops and offices
- the Environment Agency has confirmed it in writing based on evidence that you have all the necessary information for the basic characterisation – this may apply for example to a consistent, regularly generated waste
- testing is impractical or appropriate testing procedures and acceptance criteria are unavailable – you must record this and explain why you have not tested your waste and why you consider the waste is acceptable at a particular landfill class
- it is asbestos waste that you send to landfill for hazardous waste or a separate cell of a landfill for non-hazardous waste
Regularly generated wastes
Regularly generated means it is an individual, consistent waste. It is generated by the same well-defined process and you know its inputs.
If your waste is regularly generated, your basic characterisation must include:
- the range of its composition
- the range and variability of its properties
- its leaching behaviour
- its main variables for periodic testing
Once characterised you can apply periodic compliance testing unless you change the process. See the section on ‘Compliance testing: level 2 assessment’.
You must tell the landfill operator if you change your process, including the input materials.
Wastes that are not regularly generated
Wastes are not regularly generated where they are not:
- part of a well characterised waste stream, for example they are mixed or inconsistent
- generated by the same process at the same facility
You must characterise each batch of waste you produce. A batch is an amount of waste produced at one time. As you must characterise each batch, you cannot apply compliance testing
Compliance testing: level 2 assessment
Where your waste is regularly generated, you can apply compliance testing. For compliance testing you can assess the waste against fewer parameters. From your basic characterisation, you can identify the range and variability of the waste. You can then sample and test the waste against those values.
You will need to develop new parameters if you:
- change the production process
- change the input materials
- think any of the basic characteristics have changed
- are told by the landfill operator that your waste has failed their on-site verification (level 3) testing
For compliance testing, the laboratory must follow the leaching test method British Standard BS EN 12457- 2 to 12457-4. This method requires a 2kg sample.
You only need to take larger samples where there is a high physical variability and you cannot obtain smaller, representative samples (for example, stones or brick waste). Before you take any samples find out if the laboratory can crush the waste to below 4mm or 10mm.
Sample your waste
When you sample your waste, read appendix 4 of WM3.
Waste sampling and testing may be carried out by the:
- waste producer (primary producer)
- waste producer following treatment (secondary producer)
- landfill operator
For waste you must sample and test, you must provide the other basic characterisation information to the landfill operator. See the section on ‘Basic characterisation: level 1 waste assessment’.
Read the guidance in appendix 4 of WM3 to develop your sampling plan.
All samples you send to the laboratory for analysis must be representative of the waste.
The testing laboratory must confirm that they can test your samples to an accredited standard. Contact them for advice on how to prepare the sample before you take any samples.
The laboratory must use the test methods in the Council Decision annex, section 3.
You must screen or sort the waste when you take samples to remove any materials unsuitable for laboratory testing. You must re-classify any screened or sorted wastes unsuitable for laboratory testing so you can decide if you can recover or dispose of it without testing.
You must justify and document your approach in your basic characterisation.
You must separately identify components that need a specific classification and specific disposal requirements. These include gypsum, asbestos and organic matter.
Remove organic material
You must separate all visible organic matter and deal with it as a separate waste stream where you plan to send your waste to landfill cells for:
- hazardous waste
- inert waste
- stable non-reactive hazardous waste
- gypsum-based material
You can only send hazardous waste to a landfill where the total organic carbon content is less than:
- 6% ( or 10% loss on ignition) for hazardous waste
- 5% for a stable non-reactive hazardous waste cell at a landfill for non-hazardous waste
If the organic carbon content is above those limits, you will not be able to dispose of it to landfill unless you treat the waste to remove the hazardous properties.
Where you plan to send non-hazardous waste to a landfill cell for stable non-reactive hazardous waste, that waste must contain less than either:
- 5% total organic carbon
- 800mg/kg dissolved organic carbon
The waste must also meet the other leaching limit values in the Council Decision annex, paragraph 2.2.2.
You can only send waste to a landfill for inert waste where the total organic carbon content is less than 3% (30,000 mg/kg).
Sample frequency
The number of samples that you need to test depends on the size of the batch of waste and whether the batch is homogenous or heterogeneous. Read appendix 4 of WM3.
Homogenous means the waste generally contains the same or similar components. Heterogeneous means the waste generally contains a wide range of different components.
Where you have classified a single waste type, for example 170504 – soil and stones, you can apply the sample frequencies in the basic characterisation table.
Sample frequency: basic characterisation - minimum laboratory testing where you can classify a single waste type
| Amount of waste (tonnes) | Homogeneous waste (number of samples) | Heterogeneous and new waste (number of samples) |
|---|---|---|
| Less than 100 t | 2 | 5 |
| 100 to 500 t | 3 | 8 |
| 500 to 1,000 t | 5 | 14 |
| 1,000 to 10,000 t | 11 | 22 |
| Plus (per additional) 10,000 t | +5 (pro rata) | +10 (pro rata) |
Sample frequency: compliance testing for regularly generated wastes
You must carry out total concentration (waste composition) and leaching tests for specific parameters at least once a year. You must use the parameters you identified from your basic characterisation.
For homogeneous waste, carry out one sample per defined waste sub-sample.
For heterogeneous and new wastes, carry out 3 samples per defined waste sub-sample.
You can apply different test rates if you agree them with the landfill operator. You will need to tell them the wastes’ physical and chemical properties and basic characterisation.
Test failures
If sample results exceed the WAC leaching limit value, you must treat the waste to below the limits or find another route for disposal before you send the waste off site.
The Environment Agency accepts the use of statistical techniques using all available data as part of your decision making process for waste acceptance. The Environment Agency’s waste classification technical guidance WM3 includes statistical methods you can use.
Dispose of problematic waste
Hazardous waste must meet the waste acceptance criteria for a landfill for hazardous waste. Any hazardous waste that must be landfilled and cannot meet them is ‘problematic waste’.
Non-hazardous waste may be problematic waste where landfill is the only available waste management option. For example, where it cannot meet the leaching limits for a separate cell. You must consider the other management options available before you define the waste as problematic. These may include:
- treatment
- incineration with energy recovery
If you want to dispose of problematic waste to landfill you must complete a problematic waste stream request form. Contact the Environment Agency to request this form. You must return the completed form to the local Environment Agency officer in the area where the waste is produced.
Dispose of gypsum-based and other high sulphate bearing material
You must not send gypsum-based waste (for example, plasterboard) to a landfill cell that accepts biodegradable waste. You must separate it for re-use or recovery to comply with the waste hierarchy. Where you must send gypsum-based waste to a landfill, you must confirm with the landfill operator that their landfill has a separate cell that does not accept biodegradable waste. The organic content limits for wastes acceptable in the same cell as gypsum-based waste are either:
- 5% total organic carbon
- 800mg/kg dissolved organic carbon
Where your waste is high sulphate bearing, you must send it to a separate landfill cell that does not accept biodegradable waste.
Where you expect your waste is contaminated with sulphate, you must include it in your waste composition testing.
Dispose of asbestos waste
You must send construction materials containing asbestos and other suitable materials to a:
- landfill for hazardous waste
- separate cell at a landfill for non-hazardous waste
You must confirm the waste classification. You do not need to test the waste for disposal.
Where you send asbestos contaminated waste to separate cell at a landfill for non-hazardous waste, the waste deposited with the asbestos must meet the criteria in the Council Decision annex, paragraph 2.3.
Last updated 29 June 2023 + show all updates
-
Restructured this guidance to simplify the flow. Added information to reflect the ban on upholstered domestic seating containing persistent organic pollutants (POPs). Added information on asbestos waste disposal. Clarified information on waste clarification and characterisation, limits on organic matter content and problematic wastes (and gypsum-based and other high sulphate material).
-
Updated the section on banned waste. Clarified the rules for waste holders who intend to send gypsum-based waste to landfill.
-
First published.