CIWM supports the concept of a Digital Waste Tracking service (DWT) because it will make life easier and simpler for legitimate operators.
CIWM says DWT will provide legitimate operators with more accurate and timely data and relieve the data reporting burden of some of the current regulatory regimes. By modernising the way all waste is tracked from cradle-to-grave, and allowing all regulators access to the data held in the system, it should help to further eradicate illegal waste activity.
CIWM supports the mandatory nature of the Digital Waste Tracking service and welcomes the inclusion of data from exempt sites, which we believe should create a more coherent picture of waste movements throughout the UK, and make it easier to identify illegal activity.
CIWM believes there is still a place for the ‘season ticket’ and further thought is needed here, to alleviate some of the potential regulatory and cost burdens, which could affect the collection of small regular movements of waste, especially by SME waste operators.
CIWM also believes that these proposals should be combined with a modernisation of the carriers, brokers, and dealers regimes throughout the UK, in particular the introduction of competence, as this will help to further clamp down on waste crime.
What is digital waste tracking?
Legislation across the UK requires that on the transfer of waste, a written description is transferred to enable other people to appropriately manage the waste. This is commonly known as the ‘duty of care’ requirements. For non-hazardous waste, this is completed using waste transfer notes (WTNs), and for hazardous/ special waste the records are called ‘consignment notes’.
The ultimate aim of a DWT service is to be able to provide a seamless digital record of transactions for the movement of waste from cradle to grave, eventually in real-time, throughout the economy simply and effectively, providing value for all users.
The DWT service is still under development and so the details about what exactly it will provide are not known for certain. However, it is likely to encompass all types of controlled waste and may be extended to include extractive waste at a later date.
What we do know with some degree of certainty is that the DWT service will be mandatory, that the data required will be standardised, and more data will be required for certain types of waste, such as hazardous/ special waste, than others.
Waste activities that are likely to be included within the record-keeping duties of a DWT service are:
- Waste transferred to another person or company (on the same site or different site and for the first time will include exempt sites).
- Waste is transferred from households to registered waste carriers, but not where household waste is collected by the local authority.
- Waste imported or exported under Green List Waste controls.
- Waste moved between sites managed by the same person.
- Waste is treated on-site by the waste holder.
- Waste that has undergone treatment to ensure that it is subsequently suitable for reuse, recycling, recovery, or disposal.
- Waste that has been discharged, disposed of, or recovered including through reuse or recycling.
- The first transfer of end of waste products or materials that are produced from waste and subsequently transferred.
Waste activities that are likely to be excluded from the record-keeping duties of a DWT service are:
- Non-hazardous waste is treated at the site of production by the waste holder.
- Non-hazardous waste that has undergone treatment at the site of production to ensure that it is subsequently suitable for reuse, recycling, recovery, or disposal by the waste holder.
- Non-hazardous waste that has been discharged, disposed of, or recovered including through reuse or recycling at the site of production by the waste holder.
Exclusions are also likely to apply to several exempt activities, in particular those that do not involve the transfer of waste in or out of the place where the exemption is registered, for example, the burning of plant tissue and untreated wood (D2, England & Wales) from joinery activities or the burning of plant tissue waste on land in the open (Paragraph 30, Scotland and Northern Ireland).
The Digital Waste Tracking service is likely to replace several established reporting requirements, such as quarterly site returns from permitted sites, hazardous waste quarterly returns and local authority waste data reporting (WasteDataFlow).
It is likely to work in a way which is flexible to all users, but with the provision of certain mandatory information before a transfer can be initiated, such as an accurate description, a list of waste codes, and producer and destination data.
The Digital Waste Tracking service will provide unparalleled amounts of data about the movement of waste, which will ultimately help regulators crack down on waste crime and provide insights on waste flows for government strategic and planning purposes. It will also make it easier and simpler for all actors to know where their waste is going, thus satisfying their obligations under the duty of care.
Interaction with the Digital Waste Tracking service could be by way of an App on a digital handheld device, GOV.UK web portal (either direct input or bulk uploads via spreadsheets) or an API interface with a corporate IT system.
All actors will be provided with unique login credentials and bespoke dashboards, so that they have total visibility of their transactions only, and can analyse trends and performance of their waste production. Regulators too will be provided with unique login credentials and a range of dashboards and systems, which will alert them to any suspicious activity.
The regulatory regime and DWT service will be designed in parallel, with users playing a central role in their development. The new system will be designed to be interoperable with other regulator systems, such as carrier, broker and dealer permitting and registration, site-based permitting and licencing, and extended producer responsibility regimes.
What are the issues with digital waste tracking?
The introduction of a Digital Waste Tracking service will of course come with its issues. In particular, it is likely to end the practice of ‘season ticket’ WTNs, which have been used to reduce the paperwork burden on operators since the Duty of Care was established over three decades ago.
There are also data privacy and security issues yet to be resolved, and there are concerns from some quarters about the commercial confidentiality of customer data.
There are also some practical difficulties to overcome especially carrier rounds, where multiple ‘lifts’ are collected by a single compaction vehicle, and how the DWT service will easily and accurately record them.
The Digital Waste Tracking service is also likely to bring in fees and charges for regimes that have previously been free, this will especially be the case for WTNs and green list waste Annex VII’s; how much these fees and charges will be is unknown at present, but will be subject to a future regulator consultation.
However, all these things are solvable and with give-and-take on all sides, the benefits that a DWT service will bring will in the end far outweigh the disbenefits.
There is the perception that the DWT service is something of a silver bullet for waste crime, and although it may shine a light on transactions and actors that are missing from the system, it is highly unlikely that illegal operators will engage with the system; in much the same way as they do not engage with the current systems and processes. It’s just going to make it harder for them to hide, at least initially.
The background to the digital waste tracking service
Over 200 million tonnes of waste is produced in the UK each year, but there is currently no single or comprehensive way of tracking it, with legislation relating to the transport, management and description of waste being introduced separately over the last 30 or so years.
Large amounts of waste data are either not collected (e.g. waste transfers to exempt sites) or not collated centrally, and where it is collected the systems are various and disparate. Some of these systems are paper-based (e.g. WTNs and Green List (Annex VII) exports), others digital (e.g. spreadsheets); some are run by private contractors (e.g. integrated Sales Order Processing systems), others by the government (e.g. WasteDataFlow).
Where the use of existing centralise digital systems is non-mandatory, take up is usually very low. As a result, it is very difficult to determine what happens to waste and to have a comprehensive understanding of whether it has been recycled, recovered, or disposed of.
Joining these fragmented systems up and replacing paper-based record-keeping will make it much easier and less time-consuming for legitimate waste companies to comply with regulatory reporting requirements.
It should also make it much harder for rogue operators to compete in the industry and commit waste crimes, such as fly tipping, deliberate misclassification of waste, illegal waste exports and the operation of illegal waste sites.
The UK government are committed to implementing a mandatory Digital Waste Tracking service and published a consultation in January 2022; a government response is expected in 2023.
In 2020 as part of the GovTech Catalyst Challenge fund, prototypes of a Digital Waste Tracking service were developed with two technology suppliers. This work has provided the basis for the agile development of the Digital Waste Tracking service, which began with the private beta development of a system in 2023 and should go live sometime in 2024.
CIWM Position Statements represent the Institution’s views at a particular point in time. They remain under constant review, in the light of new experience and research.
