Regulation of Plastic Window Frame Recycling

Environmental Permits and Exemptions are necessary for waste recycling facilities to comply with waste regulation. Plastic window frames are defined as a waste material once they are collected for recycling. The treatment of window frames is therefore subject to either control under an Environmental Permit or an Exemption from permitting. The difference in operating under an Environmental Permit or an Exemption is massive. Not only in financial terms but also in on going management and operation of the recycling facility.

Sites that recycle plastic window frames typically do so under a T4 Waste Exemption (preparatory treatment, such as, baling, sorting, shredding). This exemption allows an operator to treat up to 100 tonnes of plastic waste (or 3000 tonnes if within a building) in any seven-day period and store up to 500 tonnes on site. These are significant tonnages which allow a reasonable sized site to operate under the exemption. A much lighter regulatory touch than for many other types of waste recycling activities of this scale.

However, the exemption relies on the fact that the plastic window frame waste is identified as one of the following waste codes 17 02 03, 19 12 04 or 20 01 39.Until recently this has been the case, however, I am seeing instances of the Environment Agency enforcing the identification of waste window frames with the code 17 09 04 or 19 12 12.This is due to the inclusion of other materials such as metal in the window frames, making this a mixed waste!

Since the T4 Exemption does not include for waste coded as 19 12 04 or 19 12 12 sites operating under the T4 will now have to obtain an environmental permit. This represents a massive step-up in terms of the regulation of this waste treatment activity. Not only will this cause a significant cost but may also cause a disruption to the business if the Environment Agency do not allow the activity to continue while the permit is sorted out.

This remains a contentious point since elsewhere in regulatory guidance plastic window frames have been associated with the code 17 02 03 (withdrawn LRW 484).

It appears that the other environmental Regulators (Natural Resource Wales and SEPA) are, for now, not taking the same approach regarding the coding of plastic window frames.

Waste materials are assigned a code (List of Waste Regulations 2005) and these codes appear in Environmental Permits and Exemptions. Codes that can be used to describe waste window frames are:   17 02 03 Construction and Demolition waste – wood – glass and plastic, plastic 17 09 04 Construction and Demolition waste – mixed construction and demolition wastes 19 12 04 Materials from waste and water treatment – Mechanical treatment of waste – plastic and rubber 19 12 12 Materials from waste and water treatment – Mechanical treatment of waste – other wastes (including mixtures of materials)… 20 01 39 Municipal waste and similar materials from commerce and industry – separately collected fractions - plastics.

What Should I Do?

If you are recycling plastic window frames under a T4 Exemption, then do take advice on how to obtain an Environmental Permit. Make sure you are aware of the potential costs and timescales involved. Have a business continuity plan in place should the Environment Agency revoke your Exemption.

Westbury Environmental Limited can provide advice on all aspects of Environmental Permitting. We have experience of helping many clients throughout the waste industry to obtain permits. We start by explaining the whole process to you, identify the costs and once you have your permit, we continue to help your business to remain compliant. Contact us for more information here.