Waste duty of care and producer responsibility (UK)
A list of checks and obligations with their cadence, ready to add to your agenda.
For any business or organisation in England and Wales that produces, holds or transfers waste, including offices and shops. Covers the Environmental Protection Act 1990 duty of care, waste transfer notes, hazardous waste consignment notes, checking the carrier is registered, the mandatory Simpler Recycling separation duty, packaging EPR obligations and the WEEE regime. Does NOT cover operating a permitted facility (see the environmental permits kit), specialist clinical waste, or transfrontier shipments of waste.
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Ask what is in the manuals, how often the maintenance is due and what it takes to do it.
What it already has at hand
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- 12 planned checks, the most frequent every year by 1 October
Planned checks
Informative summary verified on 12/09/2026. It does not replace legal advice: the regulation cited prevails. If you spot an error, report it.
Some checks are only mandatory in certain countries: pick yours and the list follows.
In Italy this product has no planned checks: the ones listed apply to other countries.
In France this product has no planned checks: the ones listed apply to other countries.
In Germany this product has no planned checks: the ones listed apply to other countries.
In Switzerland this product has no planned checks: the ones listed apply to other countries.
In Austria this product has no planned checks: the ones listed apply to other countries.
- 01
Submit first-half packaging EPR data by 1 October
Large producers must submit data on packaging placed on the market from 1 January to 30 June of the same year by 1 October, and complete their annual registration with the environmental regulator and pay the fees by the same date. Evidence is the submission receipt together with the registration confirmation. Applies to large producers only, over 50 tonnes of packaging and over 2 million pounds of worldwide annual turnover; small producers report once a year, by 1 April.
every year by 1 OctoberLegal obligationProducer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)United Kingdom onlySourceverified on 11/09/2026 - 02
Disposing of decommissioned fire extinguishers
What triggers this rule is the removal or replacement of an extinguisher. A scrapped unit is waste like any other and stays within the duty of care: it must go to a registered carrier and a permitted site, with a written description of the waste. Pressure cylinders holding residues of dangerous substances, such as old halon extinguishers, may need handling as hazardous waste with the matching consignment note: agree the classification with the operator before collection. The burden sits with the business holding the waste, not with the maintainer who drives the unit away.
continuous checkLegal obligationEnvironmental Protection Act 1990 s.34; Hazardous Waste (England and Wales) Regulations 2005 (SI 2005/894)United Kingdom only - 03
Separate recyclable waste under Simpler Recycling
From 31 March 2025 all workplaces in England must have the core recyclable streams collected separately from residual waste: glass, metal, plastic, paper and card, and food waste, which may never be mixed with the other recyclables. There is no minimum weight threshold and evidence is the collection contract detailing the separated streams together with the contractor's documentation. Applies to all non-domestic premises in England (businesses, schools, universities, hospitals, care homes); micro-firms with fewer than 10 full-time equivalent employees are exempt until 31 March 2027, and paper and card must be kept separate unless separation is not technically or economically practicable.
continuous check, confirm every 12 monthsLegal obligationEnvironmental Protection Act 1990 s.45AZA and s.45AZB (inserted by Environment Act 2021)United Kingdom onlySourceverified on 11/09/2026 - 04
Asbestos in older fire doors
What triggers this rule is the replacement or demolition of fire doors installed before 2000: the infill panels may contain asbestos insulation board, and the material removed is hazardous waste. The materials must be surveyed before the work starts; where the job counts as licensable work with asbestos only a licensed contractor may carry it out, notifying the enforcing authority at least 14 days in advance. Exposure and health surveillance records must be kept for up to 40 years. The duty rests with the employer commissioning the work and with the contractor doing it.
continuous checkLegal obligationControl of Asbestos Regulations 2012 (SI 2012/632)United Kingdom onlySourceverified on 12/09/2026 - 05
Submit packaging EPR data by 1 April
Obligated producers must submit packaging data by 1 April: large producers for the period 1 July to 31 December of the previous year, small producers for the whole previous calendar year. Small producers must also register with their environmental regulator and pay the fee by the same date; evidence is the submission receipt from the Report packaging data service. Applies to UK-established businesses that in the previous year supplied or imported more than 25 tonnes of packaging with worldwide turnover of at least 1 million pounds: small producers 25-50 tonnes or turnover between 1 and 2 million, large producers over 50 tonnes and over 2 million; charities are excluded.
every year by 1 AprilLegal obligationProducer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 (SI 2024/1332)United Kingdom onlySourceverified on 11/09/2026 - 06
Provide free WEEE take-back and keep the records
Distributors of electrical equipment must offer free like-for-like take-back of household WEEE, including where delivery is to the customer's home; stores with an EEE sales area over 400 square metres must also accept small WEEE under 25 cm without a purchase. The record of all WEEE taken back must be kept for at least 4 years and, alternatively, retailers selling under 100,000 pounds of EEE a year or trading only online may join the Distributor Takeback Scheme. Applies to all distributors of electrical and electronic equipment to household users, including online sellers; the 400 square metre threshold concerns only the additional duty to take back small WEEE without a purchase.
continuous check, confirm every 12 monthsLegal obligationWaste Electrical and Electronic Equipment Regulations 2013 (SI 2013/3113) Part 5United Kingdom onlySourceverified on 11/09/2026 - 07
Register annually as a WEEE producer
Anyone placing electrical and electronic equipment on the UK market must register each year with a producer compliance scheme, directly or through an association. No tonnage threshold exempting small producers from registration appears in the text of Regulations 25-26: what varies with the volume placed on the market is the reporting burden, not the duty to register. Products must also carry the crossed-out wheeled bin symbol and documentation must be kept for at least 4 years. Applies to producers and importers of electrical and electronic equipment, including own-brand sellers of goods made by others and distance sellers into the UK.
continuous check, confirm every 12 monthsLegal obligationWaste Electrical and Electronic Equipment Regulations 2013 (SI 2013/3113)United Kingdom onlySourceverified on 11/09/2026 - 08
Check the waste carrier is registered
Before handing over waste, and periodically afterwards, the producer must check that the carrier, broker or dealer is on the Environment Agency public register and that the receiving site holds a valid permit or exemption. The check is made online on the public register or by phone and the evidence is a dated print-out or screenshot. Applies to every business that passes waste to a third party and also to those carrying their own waste, who must register as a waste carrier (upper or lower tier).
continuous check, confirm every 12 monthsLegal obligationEnvironmental Protection Act 1990 s.34(1)(c); Waste (England and Wales) Regulations 2011 (SI 2011/988)United Kingdom onlySourceverified on 11/09/2026 - 09
Free take-back of waste portable batteries
Portable batteries at end of life — including those from defibrillators, detectors and emergency lighting units — go to a collection point and never into general waste. Distributors must take them back at no charge, while producers fund collection and recycling through the compliance schemes; small distributors supplying less than 32 kg of portable batteries a year are exempt from the take-back duty. The annual check exists to confirm the collection points in use are still operating and that no department is quietly accumulating batteries in a drawer.
continuous check, confirm every 12 monthsLegal obligationWaste Batteries and Accumulators Regulations 2009 (SI 2009/890) reg. 31United Kingdom onlySourceverified on 12/09/2026 - 10
Complete and keep waste transfer notes for 2 years
Every transfer of non-hazardous waste must be accompanied by a written description (waste transfer note) with the LoW/EWC code, the activity that produced the waste, quantity, container and the parties' details. A paper or electronic copy must be kept for 2 years, and season tickets for 2 years after the last transfer; evidence is the complete set of transfer notes. Applies to every transfer of non-hazardous controlled waste between two parties; it is not needed for hazardous waste, which follows the consignment note.
continuous check, confirm every 12 monthsLegal obligationEnvironmental Protection Act 1990 s.34(5); Environmental Protection (Duty of Care) Regulations 1991 (SI 1991/2839) reg. 2-4United Kingdom onlySourceverified on 11/09/2026 - 11
Comply with the waste duty of care
Anyone who produces, imports, carries, keeps, treats or disposes of controlled waste must take all reasonable measures to prevent its escape, store it securely and transfer it only to authorised persons, with an adequate written description. An annual review of collection contracts, suppliers and storage arrangements evidences the diligence required; evidence is the waste file with contracts, supplier authorisations and transfer notes. Applies to everyone holding controlled waste in the course of business: occupiers of domestic property are outside the main duty of care for household waste produced at home, but in England they have a separate duty to pass it to authorised persons.
continuous check, confirm every 12 monthsLegal obligationEnvironmental Protection Act 1990 s.34United Kingdom onlySourceverified on 11/09/2026 - 12
Hazardous waste consignment notes and 3-year register
Producers and holders of hazardous waste must classify it correctly, complete their part of the consignment note (one copy kept, two given to the carrier) and keep a register for 3 years at the premises that produced or stored the waste, including consignment notes, consignee returns and related documents. Evidence is the complete hazardous waste register. Applies to businesses producing or storing hazardous waste in England and Wales (waste oils, solvents, batteries, equipment containing refrigerant gases, fluorescent tubes, laboratory chemicals); in Wales the site must still be notified to Natural Resources Wales, while in England premises registration was abolished in 2016.
continuous check, confirm every 12 monthsLegal obligationHazardous Waste (England and Wales) Regulations 2005 (SI 2005/894) reg. 35-49United Kingdom onlySourceverified on 11/09/2026
In Spain this product has no planned checks: the ones listed apply to other countries.
In Portugal this product has no planned checks: the ones listed apply to other countries.
In United States this product has no planned checks: the ones listed apply to other countries.
In Other country this product has no planned checks: the ones listed apply to other countries.
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