Consultation outcome

Annex 2: Full summary of consultation responses to Environment Agency charge proposals for notified international waste shipments

Updated 2 April 2024

1. Introduction

This annex sets out the responses received to our consultation on ‘Environment Agency charge proposals for notified international waste shipments’ which ran from 4 October 2023 to 29 November 2023. 

Within the consultation, each question asked for a specific choice as well as providing a free text box for comment. The consultation questions were also split into several topics: 

• about you and consultation feedback 
• shipments 
• proposed charging scheme 
• refunds 
• economic context 
• additional comments about the charging proposals 

There were 31 responses to the consultation. This included 28 through the our Citizen Space consultation website and 2 using the consultation response form. We also received one email with comments relating to the consultation.

We have considered all the feedback we received, and the total number of responses and comments are reflected in this document. 

1.1 About you 

We included an ‘about you’ section to provide us with an understanding of who responded and to help us better analyse the consultation.

For the 28 responses online and 2 using the consultation response form, we asked if you were responding as an individual or giving a personal response or a response on behalf of an organisation and you said:

• responding as an individual – 2
• responding on behalf of an organisation or group – 28
• other – 0

We asked you the number of employees within your business and you said:

• fewer than 10 – 4
• 10 to 49 – 7
• 50 to 249 – 7
• 250 to 499 – 3
• 500 to 999 – 2
• more than 1,000 – 5
• sole trader – 0
• left blank – 2

We asked your main area of business is and you said:

• waste management: RDF – 6
• waste management: chemicals – 1
• waste management: batteries – 3
• waste management: oils – 1
• waste management: non-ferrous metals – 3
• waste management: other – 6
• other, non-waste management – 5
• consultants or brokers or trade associations – 5

We asked if your business has a recognised address and telephone number in the UK, and you said:

• yes – 29
• no – 1
• not applicable – 0

And if you answered no, we asked where your main operation is based, and you said:

• in the EU and import to the UK – 1

1.2 Consultation feedback

For the 28 respondents who completed the consultation through our Citizen Space consultation website, we asked how satisfied they were with the online tool. We received the following responses:

• very satisfied – 6
• satisfied – 20
• neither satisfied nor dissatisfied – 2
• dissatisfied – 0
• very dissatisfied – 0
• not answered – 0

Of the 28 responses, 26 did not answer or had no opinion.

We received 2 comments about the Citizen Space consultation tool:

• clear, contextualized and reflecting the actual business cases
• it seems to have been easy and straightforward to use, and we have no particular proposals as to how it could be improved

We asked how you found out about this consultation, and you said:

• from us – 25
• from another organisation – 0
• through an organisation, group, or trade association you are a member of – 3
• press article – 1
• social media, for example, Facebook, Twitter – 0
• through a meeting you attended – 1
• other – 0

2. Shipments 

This included 3 questions, each with an additional comments box.

2.1 Shipment definition 

Question 1:  Do you think our refined definition of a single shipment is clear for the purposes of this charging scheme? 

You said:  

• yes – 25  
• no – 5  

Of the 30 responses to the additional comments box, 12 did not answer or had no opinion.

On analysing the remaining 18 comments we have listed the main themes, then grouped the remaining themes based on the number of times the theme was identified. Within these comments there was one comment which was not relevant to this question. 

The main theme and number of times identified was: 

• no issues with the definition (11) 

Remaining themes and number of times identified were: 

• bulk shipment definition not clear (2) 
• unclear – not all types of transport covered (2) 
• increase in bulk shipment (1) 
• agree, with some issues around offshore installations (1) 
• further clarity needed where waste moves with non-waste (1)  

Question 2:  To what extent do you agree or disagree with the proposal to include the refined definition of a single shipment in this charging scheme? 

You said: 

• strongly agree – 8 
• agree – 13 
• neither agree nor disagree – 5 
• disagree – 3 
• strongly disagree – 1 
• do not know – 0 
• not applicable – 0 

Of the 30 responses to the additional comments box,12 did not answer or had no opinion. 

On analysing the remaining 18 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. 

The main theme and number of times identified was: 

• brings consistency and/or fairness (9) 

Remaining themes and number of times identified were: 

• no impact (4) 
• costs too high or operators cannot afford increase (3) 
• increased costs with overseas authorities (2) 
• not in line with other non-UK competent authorities (1) 
• unfair advantage for bulk shipments (1) 
• will lead to higher costs, but acceptable to receive better service (1) 
• will lead to more paperwork and admin (1) 

2.2 Shipment charging bands 

Question 3: To what extent do you agree or disagree with the proposed changes to the shipment charging bands for international waste shipments? 

You said: 

• strongly agree – 2 
• agree – 18 
• neither agree nor disagree – 7 
• disagree – 3 
• strongly disagree – 0 
• do not know – 0 
• not applicable – 0 

Of the 30 responses to the additional comments box, 11 did not answer or had no opinion. 

On analysing the remaining 19 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. 

The main themes and number of times identified were: 

• narrower bands better- no longer paying for shipments not using (6) 
• agree – benefit to adding additional bands (5) 
• not impacted by the suggestion (5) 

Remaining themes and number of times identified were: 

• agree – fairly reflects the work associated with more shipments (1) 
• consultation is unclear if the fees are proportionate to the work (1) 
• disagree – small scale notifications more expensive (1) 
• disagree with removing distinction between interim and non-interim shipments (2) 
• extra charges above 1,000 shipments will make shipping more expensive (1) 

• suggested other model:  

• basic fee plus fee per shipment (1)
• flat per tonnage fee or bands by tonnage (1)

3. Proposed charging scheme 

There are 5 questions with additional comment boxes in this section. 

Question 4: To what extent do you agree or disagree with the proposed changes to the costs of the shipment charging bands for international waste shipments? 

You said: 

• strongly agree – 1 
• agree – 11 
• neither agree nor disagree – 7 
• disagree – 9 
• strongly disagree – 2 
• do not know – 0 
• not applicable – 0 

Of the 30 responses to the additional comments box, 8 did not answer or had no opinion. 

On analysing the remaining 22 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. 

The main themes and number of times identified were: 

• too expensive at lower bands (7) 
• important that increases are linked to improved service (4) 
• it is wrong that it is cheaper to import for disposal than to recover (4) 
• agree that fees are proportionate to cover the work needed (3) 

Remaining themes and number of times identified were: 

• disagree because fees will be higher (1) 
• an impact assessment should be provided for transparency purposes (1) 
• bigger difference between containers and bulk shipments (1) 

• disagree that disposal allowed at all or should be more expensive (1) 

• disagree that the costs can be passed onto producers (1) 
• Environment Agency needs to provide transparent reporting on container stops (1) 
• increased waste to landfill (1) 
• lack of transparency in how fees are calculated (1) 
• lack of understanding on what fees will pay for (2) 
• neutral (2) 
• new charges benefit larger exporters (1) 
• new charges penalise larger exporters (1) 
• new model may drive behaviour change and overall income reduction (1) 
• proposals should include performance-based refund provision (1) 
• proposing that higher bands go up and lower bands go down in price (1) 
• the way the fees have been calculated are not credible (1) 
• unconvinced that existing fees are insufficient to cover costs (1) 
• unfair that some bands have gone down in price (1) 

Question 5: To what extent do you agree or disagree with the proposed additional charges for notifications involving mercury, ozone-depleting substances (ODS), fluorinated-gases (F-gases) or naturally-occurring radioactive materials (NORM)? 

You said: 

• strongly agree – 2 
• agree – 6 

• neither agree nor disagree – 7 

• disagree – 2 
• strongly disagree – 3 
• do not know – 4 
• not applicable – 6 

Of the 30 responses to the additional comments box,12 did not answer or had no opinion. 

On analysing the remaining 18 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. Within these comments there was one comment which was not relevant to the question. 

The main theme and number of times identified was: 

• no impact (5) 
• agree that more hazardous materials should have higher cost (3) 

Remaining themes and number of times identified were: 

• do not know what activity the extra fee is paying for (2) 
• good to see ‘polluter pays’ principles in use (1) 
• more clarity required on when this would apply such as for trace amounts (1) 
• no objections (2) 
• penalises sending waste to appropriate overseas facilities (1) 
• reference to £287 being trivial (especially in comparison with admin fee of £328) (1) 
• unnecessary when considering the other charge increases as well (2) 

Question 6: To what extent do you agree or disagree with the proposed standalone fixed charge for notifications of import or export of ships or offshore installations?

You said: 

• strongly agree – 1 
• agree – 5 
• neither agree nor disagree – 7 
• disagree – 0 
• strongly disagree – 0 
• do not know – 2 
• not applicable – 15 

Of the 30 responses to the additional comments box, 20 did not answer or had no opinion. 

On analysing the remaining 10 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. Within these comments there were 2 comments which were unclear or not relevant to the question 

The main theme and number of times identified was: 

• no impact (5) 

Remaining themes and number of times identified were: 

• extra costs are not significant compared with other costs in ship recycling (2) 
• overly expensive for shipments of ‘parts’ of installations (1) 

Question 7: To what extent do you agree or disagree with the proposed standalone fee for the assessment for pre-consented status? 

You said: 

• strongly agree – 0 

• agree – 10 

• neither agree nor disagree – 7 
• disagree – 3 
• strongly disagree – 2 
• do not know – 1 
• not applicable – 7 

Of the 30 responses to the additional comments box, 19 did not answer or had no opinion. One comment was not relevant to the question. 

On analysing the remaining 11 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. 

The main theme and number of times identified was: 

• no impact (3) 
• the Environment Agency should charge for the work they do (3) 

Remaining themes and number of times identified were: 

• agree- the financial benefits are higher than the cost (1) 
• dis-incentive to apply for pre-consented (1) 
• double regulation- should already be covered via Permit fees (1) 
• fee is excessive (1) 
• request clarity on timescales of pre-consented status (1) 
• uncertain due to lack of knowledge about pre-consented facilities (1) 
• unfair to multiple charges for notifications to a pre-consented site (has misunderstood the proposal) (2) 

Question 8: To what extent do you agree or disagree with the proposed administrative charge for amendments to notifications and associated documents including financial guarantees? 

You said: 

• strongly agree – 0 
• agree – 8 
• neither agree nor disagree – 4 
• disagree – 8 
• strongly disagree – 8 
• do not know – 2 
• not applicable – 0 

Of the 30 responses to the additional comments box, 4 did not answer or had no opinion. 

On analysing the remaining 26 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. 

The main themes and number of times identified were: 

• excessive for a minor amendment (7) 

• unfair to charge 

• for changes beyond your control (4)
• after transmission but before consent from all authorities (3)

• when receiving authorities request changes (8)

• why don’t youdo you not charge differently for different changes (4) 

• agree in principle, but the amount is too high (4) 

• unclear 

• question: is the charge per change? (2)
• what changes it relates to (2)

Remaining themes and number of times identified were: 

• no impact (1) 
• a small number of changes should be included in the base fee (1) 
• agree – other non-UK competent authorities do this (2) 
• agree in principle- applicability needs clarity (1) 
• charging ‘per change’ lead to excessive fees (1) 
• no objections (2) 
• questions around payments of the fee (1) 
• some changes should not be charged for (2) 

4. Refunds 

There is one question with an additional comments box in this section. 

Question 9: To what extent do you agree or disagree with the proposed approach to refunds? 

You said: 

• strongly agree – 3 

• agree – 4 

• neither agree nor disagree – 9 
• disagree – 8 
• strongly disagree – 6 
• do not know – 0 
• not applicable – 0 

Of the 30 responses to the additional comments box,11 did not answer or had no opinion. or the comment was not relevant to the question. 

On analysing the remaining 19 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. 

The main themes and number of times identified were: 

• does not work with the way the industry works (6) 
• prefer existing refund policy (6) 
• one month timescale too short (5) 
• not fair to not get money back when we have not done the work (3) 

Remaining themes and number of times identified were: 

• agree (2) 
• customer has nothing to add (1) 
• increase waste to landfill (2) 
• more info requested- will we allow fees to be transferred to another notification (1) 
• prefer a different charging scheme which would make refunds more transparent (1) 
• questions on transitional arrangements between old and new scheme (1) 

• refund policy is a fair balance between regulators and customers (1) 

• refunded amount is not high enough (1) 
• suggest 1 one month from consent date or start date (1) 
• suggest refunds available based on delays (1) 
• the admin fee is too excessive (1) 
• would prefer a different system (1) 

5. Economic context 

There is one question with an additional comments box in this section. 

Question 10: To what extent do you agree or disagree with our assessment of the economic context? 

You said: 

• strongly agree – 1 
• agree – 10 
• neither agree nor disagree – 7 
• disagree – 7 
• strongly disagree – 3 
• do not know – 2 
• not applicable – 0 

Of the 30 responses to the additional comments box, 13 did not answer or had no opinion. 

On analysing the remaining 17 comments we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. Within these comments, there were 4 comments that were not relevant to this question. 

The main theme and number of times identified was: 

• agree to certain extent (6) 
• disagree that it does not have a material impact (5) 
• disagree that costs passed back to producers (3) 

Remaining themes and number of times identified were: 

• agree (2) 
• benefits big business unfairly (1) 
• disagree that customers can make behavioural changes to improve applications (they are already doing that) (1) 
• does not account for other pressures especially on small businesses (1) 
• may cause exports for recovery to be diverted to domestic disposal (1) 
• may cause rise in crime due to expense (1) 
• not enough analysis to work out impact on business (1) 
• post-COVID (1) 

6. Additional comments about charge proposals 

There is one additional comments box in this section.

Question 11: Please share any additional comments that you think may help us improve our current proposals. 

Of the 30 responses to this comments box, 17 did not answer or had no opinion.

On analysing the remaining 13 comments, we have listed the main themes, then grouped the remaining based on the number of times the theme was identified. Within these comments there were 9 that asked questions which were not relevant to this question. 

The main theme and number of times identified was: 

• other ideas for doing things better, including modular fees (3) 

Remaining themes and number of times identified were: 

• a level playing field (1) 
• link to Defra’s consultation: why do we not reduce fees if they need to input digitally (2) 
• agree with principle of paying more as long as there’s value for it (1) 
• unfair to charge more on those working legally, and not prosecuting those operating illegally (2) 
• expensive compared to green list waste (1) 
• extra costs because of Environment Agency inefficiency and mistakes – includes examples of inefficiencies (1) 
• it is unfair to small operators when compared to large ones (1) 
• how will this address waste crime (1) 

7. Email responses to consultation 

We received one email response to the consultation. This response did not answer all the consultation questions as set out in the consultation document but did give comments which loosely aligned with 2 consultation questions. We have considered the comments from this respondent and summarised here. 

The main theme identified was: 

• the proposed definition for shipment is unfair 

The remaining themes identified were: 

• encourages bulk shipments 

• creates an unlevel playing field 

• unfair to solid recovered fuel operators