Guidance

Heat treating waste plastics for reuse: RPS 112

Updated 7 August 2024

Applies to England

This regulatory position statement (RPS) does not change your legal requirement to comply with the conditions in a T4 or U9 waste exemption when you undertake preparatory treatments or use waste to manufacture finished goods under those exemptions.    

However, the Environment Agency will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • your activity meets the description set out in this RPS

  • you comply with the conditions set out in this RPS

In addition your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:

  • cause a risk to water, air, soil, plants or animals

  • cause a nuisance through noise or odours

  • adversely affect the countryside or places of special interest

Activity this RPS applies to

This RPS applies to heat treating waste plastic under the waste exemption:

Conditions you must comply with

You must:

  • register a  T4 or U9 waste exemption

  • comply with all other conditions in the T4 or U9 exemption except for the restriction relating to heat

  • only heat waste plastic as part of an extrusion process

  • only treat non-brominated and non-hazardous plastics, or plastics that have been treated to remove brominated and hazardous plastics before being accepted on site

  • keep records for 2 years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the Environment Agency on request

You must not:

  • heat more than 100 tonnes of waste plastic a week

Things to note

If you follow the conditions in this RPS, you will be treated as if you hold an environmental permit when you apply for accreditation as a reprocessor of packaging waste under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007 (as amended).

When you must check back

The Environment Agency will review this RPS by 31 December 2025. You will need to check back then to see if it still applies or if you need to apply for a permit.

The Environment Agency can withdraw or amend this regulatory position before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

You can subscribe to email updates about this RPS. These will tell you if the RPS has changed and when it has been withdrawn.

If you cannot comply with this RPS

If you operate under this RPS but can no longer comply with it, you must:

Contact the Environment Agency

If you have any questions about this RPS email enquiries@environment-agency.gov.uk and put ‘RPS 112’ in the subject.