Navigating the UK’s waste regulations with Recofloor

When it comes to disposing of vinyl flooring waste, flooring contractors need to know what is required under the UK’s waste regulations to comply with the law. Carla Eslava, Recofloor’s Scheme Manager, explains the options for participants using the take-back collection service…

“Recofloor was founded in 2009 by flooring manufacturers Altro and Polyflor to offer a reliable and practical solution to reduce and recycle the vinyl flooring waste generated from project sites. The UK-wide scheme collects a range of flooring types, such as Luxury Vinyl Tiles (LVT), smooth, safety and loose lay vinyl offcuts, roll-ends as well as uplifted smooth and loose lay vinyl.

Any waste that comes from a commercial activity is business waste. Business waste also includes any waste that comes from construction, demolition or industry activities. Different rules apply in England, Wales, Scotland and Northern Ireland, so you need to check the rules depending on where your business is located. However, there are exemptions.

Recofloor members are encouraged to consider the waste regulations and assign someone to ensure that disposal documentation is covered for their activities and that disposal costs are included in the quote, or their client’s quote.

As a waste vinyl flooring collection service provider, the regulations apply to Recofloor as well as to our participants.

Here we explain how the waste permit, waste carrier license and waste transfer notes apply to Recofloor and to our participants.

Waste permit

Recofloor provides participants with copies of Altro and Polyflor waste permit/exemptions upon request. Altro and Polyflor, as the scheme funders, receive the vinyl flooring waste collected across the UK. They store the material and pre-sort it for processing and recycling.

In England, you may need to apply to the Environment Agency for an environmental permit if your business uses, recycles, treats, stores or disposes of waste or mining waste. This permit can be for activities at one site or for mobile plant that can be used at many sites.

Businesses in Wales that use, recycle, treat, store or dispose of waste need a permit from Natural Resources Wales to legally operate.

In Scotland, waste permits are regulated by the Scottish Environment Protection Agency (SEPA). Depending on their location, some participants may need a waste permit so that they can trace the waste is going to a permitted site.

The good news for floor fitters, contractors, construction companies and flooring distributors participating in the Recofloor scheme is that we understand that the majority of them are not required by law to have a waste permit for their own activities. However, we advise our members that it is their responsibility to check if they need to obtain a waste permit.

NWFD 4

The provision of Recofloor collection containers at flooring distributors and project sites for the collection of vinyl flooring falls under the Non-Waste Framework Directive exemption NWFD 4 category for temporary storage at a collection point. This means that the waste is considered low risk, and as long as you meet the exemption conditions you do not need to register with the Environment Agency. 

The exemption conditions are that the waste must be collected in a secure container at a collection point, no more than 50 cubic meters can be stored at any one time, and waste can only be stored temporarily, and for no longer than three months. 

However, waste exemptions are changing, and this will affect anyone who carries out a waste exemption activity. In February 2023, the Department for Environment, Food and Rural Affairs published details of changes to the waste exemptions regime for England and Wales following a five-year consultation period. The changes apply to England and will also be applied in Wales via the Welsh regulator NRW.

Explaining the changes, Defra said that the current rules in England and Wales allow certain low-risk, small-scale waste activities to be carried out under a registration scheme, exempt from the need to hold an environmental permit, providing a light-touch but valuable form of regulation. Changes to the exemptions are expected to roll out during 2024 and continue into 2025, but timescales have not been finalised yet.

The Recofloor team will continue to monitor any changes and inform participants if they are likely to be affected.

Waste Carrier Licence

Waste carrier licences are a mandatory requirement for anyone in the UK who moves waste from one point to another. Here we will explain how the rules apply from a Recofloor and scheme participant perspective.

Recofloor’s collection service uses Altro and Polyflor vehicles where possible, or alternatively, a third-party transport company to collect waste vinyl flooring. We make sure that all the companies for transporting the waste from collection points to Altro and Polyflor, or the recycler, has a waste carrier licence.

Complex

For participants, it is a little more complex as it depends on their activity as to whether they need to apply or not.

If you wish to carry waste in Scotland, England or Wales you must register as a waste carrier in one of these countries. Usually that will be the country where you do the most work. This will allow you to carry waste anywhere in Great Britain (Scotland, England and Wales).

If you are based in England or Wales, you should register with the Environment Agency or Natural Resources Wales (NRW) respectively. In Scotland, you must register with the Scottish Environment Protection Agency (SEPA). In Northern Ireland, you will need to apply for a waste carrier’s licence from the Northern Ireland Environment Agency (NIEA).

As for England, there are two licence tiers – Lower Tier and Upper Tier – and each have different conditions. Contractors transporting waste vinyl flooring to premises for collection must by law obtain a lower-tier Waste Carrier’s Licence, which is free. If they leave the waste at site, they don’t need to apply.

Flooring distributors, if they only accept waste from their customers for Recofloor to collect, don’t need to register. If they want to collect from their customer and bring waste back to their premises, they will need an Upper Tier licence as they are transporting someone else’s construction waste. You can check for the latest information on waste regulations via the Recofloor website.

Waste transfer notes and season tickets

For each load of non-hazardous waste you move off your premises, you need a waste transfer note or a document with the same information, such as an invoice. For each collection, Recofloor provides a waste transfer note (WTN) or season ticket for participants.

A season ticket covers multiple transfers of non-hazardous waste over a period of up to a year. This is sometimes called an ‘annual waste transfer note’.

Although navigating the UK’s waste regulations can appear a somewhat daunting task, Recofloor can support and steer you in the right direction. If you are a scheme participant or would like to start collecting waste vinyl flooring for recycling, get in touch for advice.”

Richard Catt, CEO of the Contract Flooring Association, comments: “One of my favourite quotes from our industry in recent times was from Carl Harper (Southern MD of Westcotes Flooring and the current CFA president) in an article for the Contract Flooring Journal – ‘laying the floor – that’s the easy bit’ – never could a truer word have been spoken in the modern era when there are a whole host of considerations and hoops that you have to jump through to provide a full service to a client.

“Waste is now a huge consideration. Dealing with waste legally, responsibly and sustainably is hugely important and can easily trip companies up if you don’t know the rules. The CFA would always recommend finding partners to support and there are a number of very good schemes offered by CFA manufacturer members.

“Recofloor, through Polyflor and Altro, is one of those and can offer both guidance as well as a credible way to manage and recycle vinyl flooring. It allows contractors to concentrate on the easy bit!”