Guidance

Food and drink: pollution inventory reporting

Updated 21 August 2024

Applies to England

• Publication for Northern Ireland
• Publication for Scotland
• Publication for Wales

If you operate an A1 installation, you will need to submit data to the pollution inventory.

The ‘general guidance’ for pollution inventory reporting gives information that applies to all business and industries. It explains what the pollution inventory is and how to report.

This guidance gives information specific to food and drink manufacturing and processing activities.

Emissions to air

Relevant pollutants

The most common air emissions from food and drink activities, and their sources, are:

• ammonia (NH₃) and hydrofluorocarbons (HFCs), from topping up and fugitive losses in refrigeration systems
• carbon dioxide (CO₂), from fermentation, carbonatation, or carbonation – emissions may also arise from flaring, venting or burning of biogas from anaerobic digestion plant where part of the permitted installation
• methane (CH₄), from cooking and drying – emissions may also arise from flaring, venting or burning of biogas from anaerobic digestion plant where part of the permitted installation
• non-methane volatile organic compounds (NMVOCs) – this includes specific chemicals such as hexane used in solvent extraction in vegetable oil processing, or mixtures of VOCs from brewing, baking, frying or roasting and so on
• particulates (total particulate matter, PM10, PM2.5), from activities such as material handling, milling, grinding, pelletising and drying
• sulfur dioxide (SO₂), from sulfitation

Combustion process releases may include oxides of nitrogen, sulfur dioxide, particulates and carbon dioxide. These releases depend on the fuel type.

For more information, check the ‘combustion activities’ pollution inventory reporting guidance.

You should make sure to include relevant releases from direct fired dryers and ovens in your return.

You must check that there are no other pollutants emitted from your activities.

Emissions to water

The ‘general guidance’ for pollution inventory reporting explains what an emission or transfer to water is.

Relevant pollutants and emission sources

The most common pollutants emitted to water from food and drink activities, and their sources, are:

• chlorides, from use of salt or brine solution, or in on-site effluent treatment
• nitrogen, from nutrient addition for on-site effluent treatment, or a component of food or drink
• phosphorus, from use of phosphoric acid in cleaning activities, or nutrient addition for on-site effluent treatment or a component of raw material (for example, milk)
• suspended solids, associated with cleaning activities and effluent treatment
• total organic carbon or chemical oxygen demand from raw materials, intermediates and finished products – these are often associated with cleaning activities

Check that there are no other reportable substances emitted from your processes or required to be monitored by a permit condition.

Off-site waste transfers

You must classify wastes using the:

• European Waste Catalogue 6-digit codes
• relevant Waste Framework Directive disposal and recovery codes

Check the ‘reporting codes list’ in the pollution inventory reporting guidance.

Relevant wastes

List of Waste sub-chapters 02 02, 02 03, 02 04, 02 05, 02 06 and 02 07 contain the codes that cover the majority of process wastes generated by food and drink activities.

List of Waste codes applicable to food and drink activities are also included in other sub-chapters. For example, 15 01 packaging materials.

You should report only wastes generated from your installation itself, and not associated wastes from areas outside the installation boundary such as offices or canteens.

Take care to properly classify materials. You should only report waste to the pollution inventory. Certain wastes are now classified as by-products or non-wastes. This is proven by recent case law or the application of waste protocols.

If you are uncertain of the status of materials, you should get advice from your local inspector.

The Waste Framework Directive makes special provision for animal by-products. This is relevant when deciding if your waste needs to be reported to the pollution inventory.

Animal by-products covered by the Animal By-Product Regulations are excluded from the scope of the Waste Framework Directive, except where destined for:

• landfill
• incineration (including co-incineration)
• biogas
• composting

This means that, where the regulations require animal by-products to be sent for incineration, landfill, biogas, or composting:

• they will continue to be considered as waste
• you must report them to the pollution inventory

In contrast, for animal by-products sent to other routes (such as rendering):

• they will not normally be considered as waste at the point of production
• you should not report them to the pollution inventory

The status of outputs from rendering activities will be determined by the fate of the material.

You should report animal by-products as waste when they’re sent from renderers to:

• landfill
• anaerobic digestion
• composting
• incineration
• landspreading

Animal by-products may sometimes be sent from slaughterhouses to intermediate transfer stations. At this point, a decision will be made on the final outlet route. In these cases, you should report the animal by-products as waste at the point of production unless there is certainty of use as a non-waste animal by-product.

You should report animals recorded as dead on arrival at slaughterhouses and sent for incineration as waste.

Category 3 animal by-products sent for pet food manufacture are a by-product and not waste.

Landspreading animal by-products is under waste controls under national legislation and so you should report this as a waste.

Digestive tract content sent for landspreading is a waste and you should report this to the pollution inventory.

Abattoir lairage material, including slurry and natural bedding, is considered a by-product and not a waste, as long as it has been landspread lawfully. That is, it has not:

• caused pollution
• been deliberately overapplied
• breached any nitrogen sensitive zone requirements

Tallow used as a fuel is considered as a waste unless the Environment Agency has accepted an ‘end of waste’ application.

Relevant Waste Framework Directive codes you might use for various disposal or recovery activities include:

• D2: treatment of sludges or liquids on sacrificial land
• D5: disposal to engineered landfills (including animal by-products where required by animal by-product legislation)
• D8: anaerobic digestion where digestate is landfilled
• D10: incineration in dedicated facility (including incineration of animal by-products where required by Animal By-Product legislation)
• R1: use of biomass as a fuel to generate energy, for example, tallow or MBM (meat and bone meal)
• R3: anaerobic digestion where digestate is to be landspread (except where anaerobic digestion waste protocol compliant)
• R3: composting
• R10: landspreading for agricultural benefit of sludges, liquids, and solid wastes