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:
- classify your waste as hazardous or non-hazardous
- treat the waste
- make sure the landfill site can accept your waste
You must complete the following:
- waste information (formerly a transfer note) or hazardous waste consignment note
- waste description, including the basic characterisation of the waste
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 need to provide information to them so that they can decide what treatment is needed.
If you treat your own waste and send the waste to landfill you must follow the rules in this guide.
There is some waste you cannot send to landfill. This includes:
- any liquid waste, including waste water but excluding sludge
- waste that would be explosive, corrosive, oxidising, flammable or highly flammable
- infectious medical or veterinary waste
- chemical substances from research and development whose effects are not known
- whole or shredded used tyres, except for 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
Where you have treated separately collected waste paper, metal, plastic or glass, you may send residual waste from that treatment to a landfill that is permitted to accept it. You must use the waste hierarchy to make your decision.
Find out about separately collected waste.
If you cannot send your waste to landfill you must find another way to recover or dispose of it with reference to the waste hierarchy, for example incineration with energy recovery.
Dispose of gypsum-based wastes
You must not send gypsum-based waste (for example, plasterboard) to a landfill cell that accepts biodegradable waste. You must separate it for reuse or recovery to comply with the waste hierarchy. Where you cannot separate it, you must send mixed waste that contains gypsum to a landfill cell that contains no biodegradable waste, for example a stable non-reactive hazardous waste cell.
Test it to confirm it meets waste acceptance criteria leaching limits in the Council Decision annex for a separate cell (see section 2.3 of the Council Decision annex) or landfill for hazardous waste (see section 2.4 of the Council Decision annex).
Read more about mixed waste.
Classify your waste
Before you recover or dispose of your waste you must decide whether it’s hazardous or non-hazardous. Non-hazardous waste includes inert waste.
Treat waste for landfill
You must normally treat waste before you send it to landfill. For example, reducing the hazard from highly flammable to flammable, or removing polluting substances from non-hazardous 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
You can treat waste by separating different types of waste and sending some of it for recycling, reuse or recovery.
Your proposed treatment must do both of the following:
- 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 because this does not change the characteristics of the waste.
You must confirm in writing to the landfill operator that you have treated your waste. You must describe the product of the treatment as part of the waste’s basic characterisation.
If the waste was classified as hazardous before treatment, follow the procedures for reclassifying the treated waste in the waste classification technical guidance.
You need to show that the treatment has made the waste acceptable for disposal at the class of landfill you are sending it to.
Contact the landfill site to find out what types of waste they are allowed to accept.
You must assess and describe all waste that you produce before sending it for recovery or disposal. For disposal to landfill you must also carry out a basic characterisation or level 1 waste assessment.
The basic characterisation will help you decide which class of landfill site you must send your waste to. The waste must meet the waste acceptance criteria (WAC) and waste acceptance procedures.
Dispose of hazardous and problematic waste
Hazardous waste must meet the WAC for landfill for hazardous waste before it can be accepted at a landfill. Any hazardous waste that must be landfilled and cannot meet WAC is ‘problematic waste’.
If you want to dispose of problematic waste to landfill you must complete a problematic waste stream request proforma. Contact the Environment Agency to request this form. You must return the completed form to the local Environment Agency office in the area where the waste is produced.
Basic characterisation: level 1 waste assessment
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 – include a description and the characteristics of raw materials and products
- a description of the waste treatment – or a statement explaining why treatment is not needed
- 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 EWC codes in appendix A of the waste classification technical guidance
- for hazardous and mirror entry hazardous waste, the hazardous property code – find the hazard code in appendix C of the waste classification technical guidance
- confirmation that the waste is not a banned waste
- the landfill class at which the waste may be accepted – a landfill for hazardous, non-hazardous or inert waste
- if necessary, additional precautions to be taken at the landfill
Cases where testing is not needed
You do not need to carry out testing for basic characterisation when:
- the waste is on a list of waste that does not require testing – see section 2.1.1 of the Council Decision annex
- the waste is treated, non-hazardous municipal waste, including separately collected fractions of non-hazardous household waste and the same non-hazardous waste from other sources, for example shops and offices
- you have satisfied the Environment Agency that you know and can justify all the necessary information for basic characterisation
- 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 think the waste is acceptable at a particular class of landfill
- it is asbestos waste that you send to a landfill for hazardous waste or a separate cell of a landfill for non-hazardous waste
Testing to confirm characterisation
If you cannot meet the cases where testing is not needed, you must test your waste to confirm the composition. For inert waste, hazardous waste and any waste you send to a stable non-reactive hazardous waste cell, you must also assess its leaching behaviour.
When you sample your waste you must follow the British Standard BS EN14899:2005 Characterisation of waste – sampling of waste materials.
Waste sampling and testing may be carried out by the:
- waste producer (primary producer)
- waste producer following treatment (secondary producer)
- landfill operator
For waste that needs sampling and testing, you must also provide other basic characterisation information.
If you are disposing of mixed waste, you must classify and describe each component separately. You need to carry out more detailed characterisation to decide what pre-treatment is required before disposing of mixed waste to landfill.
Characterisation for regularly generated waste: level 2 waste assessment
If your waste is regularly generated you can apply compliance testing based on a full basic characterisation of the waste.
Regularly generated means the waste is of consistent quality and generated by the same process.
For compliance testing you only need to assess the waste against a limited number of parameters. Based on the basic characterisation, identify the main parameters of the waste to understand its variability. You can then sample and test the waste against those parameters.
You will need to develop new parameters if you:
- change the production process
- think any of the basic characteristics have changed
- are told by the landfill operator that your waste has failed their onsite verification (level 3)
Basic classification following treatment
If a waste treatment operator keeps waste separate and does not mix it with other wastes before sending it off site for disposal, they can use the basic characterisation provided by the original producer.
The waste treatment operator must produce a new basic characterisation before disposal when they:
- mix individual wastes that they receive under separate basic characterisations
- separate mixed waste and need to send one or more of the components to landfill
You must develop your sampling plan in accordance with British Standard BS EN 14899:2005 Characterisation of waste – sampling of waste materials and the associated technical reports – see Characterization of waste. Sampling of waste materials. Guidance on selection and application of criteria for sampling under various conditions. The British Standard provides guidance on how to sample.
All samples you send to the laboratory for analysis must be representative of the source 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 section 3 of the Council Decision annex, ‘sampling and test methods’.
You must screen or sort the waste when you take samples to remove any materials that are unsuitable for laboratory testing. You must re-classify any screened or sorted wastes unsuitable for laboratory testing so you can decide whether it can be recovered or disposed of without testing.
You must justify and document your approach in your basic characterisation information.
You must separately identify components that need a specific, individual classification and specific disposal requirements. These include gypsum, asbestos and organic matter.
Test for total organic carbon
You must separate all visible organic matter from waste destined for disposal at landfill cells for hazardous or inert waste and deal with it as a separate waste stream.
Where you cannot separate visible organic matter by treatment and the waste remains hazardous, you will probably not be able to dispose of it to landfill unless you treat the waste to remove the hazardous properties.
You must follow the leaching test method British Standard BS EN 12457-1. This method requires a 2kg sample where the sample particle size is less than 10mm.
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, discuss this with the laboratory to find out if they can crush the waste to below 10mm.
The number of samples you need to test depends on the size of the batch of waste and whether the batch is homogenous or heterogeneous.
Homogenous means the waste generally contains the same or similar components. Heterogeneous means the waste generally contains a range of different components.
From your basic characterisation, if you do not expect the waste to be contaminated above any WAC leaching limit value, you can apply the sampling frequencies in the following table. If you suspect the waste is contaminated above any WAC leaching limit value, you must consider further waste treatment.
Level 1 characterisation: table showing minimum laboratory sample frequency for testing where waste can be classified as 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)|
Level 2 compliance testing for regularly generated wastes: sample frequency
You must carry out total concentration and leaching tests to a targeted suite at least once a year as identified from the 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 alternative rates of testing if you can justify them to the landfill operator. You will need to provide detailed knowledge of the physical and chemical properties and basic characterisation of the waste.
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 the decision making process for waste acceptance. The Environment Agency’s waste classification technical guidance has details of the statistical methods you can use.