Guidance

Carrying out research or trials with waste at sites without an environmental permit

What you need to provide to the Environment Agency if you want them to consider allowing your proposed research or trial.

From:
Environment Agency
Published
8 December 2023
Last updated
13 March 2024 — See all updates

Applies to England

This guidance explains when the Environment Agency will not normally take enforcement action if you do not hold a permit for research or trials using waste. 

If you are proposing research or trials at a site with an environmental permit, follow the guidance on carrying out research or trials at a regulated site instead. 

Research and trials covered by this guidance 

The Environment Agency will consider creating a local enforcement position (LEP), or in limited cases a regulatory position statement (RPS), for research or trials with waste that:   

  • involve the development of new ideas, techniques and processes to recover waste  
  • are not repeating information and research available elsewhere, such as previous trials carried out in the UK or abroad  
  • should not continue for more than 6 months 
  • are not part of multiple or repeat trials 
  • will not distort the market 

You must not begin your research or trial until the Environment Agency has approved the details and scope of your proposed research or trial and created a LEP or RPS. 

Information you must provide when you request a LEP or RPS for research or trials with waste 

Email [email protected] with ‘waste trial proposal’ in the subject line. You must include:   

  • your name or company name and number 
  • your address  
  • a contact name, email address and telephone number 
  • the address or location of the site where the research or trial will take place 
  • details of any environmental permits issued on the site or exemptions registered at the site  
  • details of any previous research or trials carried out on the site 
  • a non-technical summary of the research or trial, including the purpose and intended outcome 
  • the intended environmental or commercial benefits of the trial 
  • the timescale for the research or trial, which should normally be less than 6 months (you will need to justify why the research or trial needs more than 6 months) 
  • details of any known relevant research and previous trials carried out elsewhere 
  • information confirming the research or trial will not distort the market 

You must also send the Environment Agency a method statement for the trial. This must include:  

  • the proposed waste inputs and outputs in the trial, including the total quantities overall and at any one time  
  • the waste codes and description  
  • where you intend to source the waste from   
  • the amount of waste you want to process and store at any one time and how you will store the waste 
  • all predicted emissions from the trial and how you will manage them 
  • an explanation of why the waste you will use is the minimum amount that you can use 
  • details on how waste will be removed and the steps you’ll take to return the site to its original state once the trial or research is complete 
  • whether you plan to apply for an environmental permit to continue the waste operation when the research or trial is complete 
  • an assessment of the risks to people and the environment that the trial creates and how you will mitigate the risks  

Guidance to help you do this includes:  

Research or trials using contaminated land or groundwater that you will treat on site  

Check RPS 215 if you’re planning a small scale remediation scheme or trial to treat contaminated soils and groundwater.  

If you are planning research or a trial that’s not covered by RPS 215, email [email protected] with ‘waste trial proposal’ in the subject line. You must include:   

  • your name or company name and number 
  • your address  
  • a contact name, email and telephone number 
  • the address or location of the site where the research or trial will take place 
  • details of any environmental permits issued on the site or exemptions registered at the site  
  • details of any previous research or trials carried out on the site 
  • a non-technical summary of the trial including the purpose and intended outcome 
  • details of the type of contamination and method statement for the trial treatment process 
  • the total quantities of waste being treated in the trial  
  • all predicted emissions from the trial and how you will manage them 
  • the timescale for the research or trial, which should normally be less than 6 months (you will need to justify why the research or trial needs more than 6 months) 
  • details of any known relevant research and previous trials carried out elsewhere 
  • details on how waste will be removed and the steps you’ll take to return the site to its original state once the trial or research is complete 

When your research or trial is complete 

You must have an appropriate environmental permit if you want to continue the waste operation or carry out more trials. 

The Environment Agency will not create an RPS for multiple or repeat trials, even if the waste type and trial parameters have changed.  

There is a proposal to change the current D5 exemption to define ‘research’. This will include research associated with waste trials but will exclude field research. When these changes take effect, it will allow up to 10 tonnes of waste to be used for trials consisting of testing and analysis at laboratories, educational establishments and workplaces.

Updates to this page

Published 8 December 2023
Last updated 13 March 2024 + show all updates

  1. Sections ‘Information you must provide…’ and ‘Research or trials using contaminated land or groundwater…’ changed email address to [email protected].

  2. First published.

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