Customer Alert – Reclassification Of Unclean Packaging


Recent changes to Environment Agency guidance on the classification of packaging waste could see large amounts of used containers classified as hazardous waste.


Packaging waste includes paint cans, mastic tubes, plastic bottles and Tetrapak. If the used containers have materials or residues in them, they would need to be dealt with at licensed hazardous waste facilities.

The new rules were due to come into force on January 1 2014 but have now been put on hold until April 1 2014.

Previously, hazardous classification was calculated on the basis of the weight of the empty, uncleansed packaging, with consideration also given to the concentration of the hazardous substance left in the packaging and compared to relevant thresholds.

However, this weight-based classification has been removed from the Agencys official guidance after it was updated. This means that packaging – such as empty mineral oil drums and used sacks which contained liquids – will have to be reclassified as hazardous unless it can be proved that the packaging has been fully cleansed with the hazard removed – regardless of the weight of the contents. Reclassified packaging will also incur an Agency fee of £38 per collection.

The change means any packaging which has contained a hazardous product but has not been cleansed or decontaminated is to be automatically considered a hazardous waste, regardless of its weight or the concentration of the potentially hazardous substance originally contained in the packaging.

JWS Waste believe that if the guidance comes into force in April it will have a significant impact on our MRF operations in terms of segregating unclean packaging from our incoming waste streams. This will inevitably lead to additional costs for our customers in terms of charging for non-conforming waste however we are looking to engage with our customers to help them better understand the new and impending legislation and offer a bespoke service for customers with these requirements.

ontact Tim Andrew, our Operations Manager, to discuss this in more detail on 0161 737 4545