Essential information for end of life vehicle dismantling, depollution and recycling

AutoDrain L

RPS C2: Exceeding waste storage limits at permitted sites because of COVID-19

The Environment Agency released the following guidance on a Regulatory Position Statement (RPS) on exceeding waste storage limits at permitted sites because of COVID-19 on a temporary basis. 


RPS exceeding wast storage

You must usually comply with the waste storage limits in your environmental permit. However, this COVID-19 regulatory position statement (RPS) allows you to temporarily exceed those limits if you cannot remove waste from your site because of COVID-19 restrictions.

You must notify the Environment Agency by email before using this COVID-19 RPS.

1. When this COVID-19 RPS applies


This COVID-19 RPS only applies:

  • if you can demonstrate that you need to temporarily store more waste than your permit allows because of COVID-19 restrictions
  • to wastes you are authorised to store under your permit

This COVID-19 RPS does not apply to any other activity, even if it is under the same legislation. You may still need other permits or licences for other activities you carry out.

You must be able to demonstrate that you have taken all reasonable steps to comply with your permit. Reasonable steps include:

  • contingency planning to avoid or minimise disruption to your business because of COVID-19
  • COVID-19 response planning to minimise the impact and duration of not being able to comply with your permit or licence
  • minimising how far you exceed your waste storage limits

2. Conditions you must comply with


You must:

  • comply with all the other requirements on your permit
  • stop accepting waste at your site if there is a risk to human health or the environment
  • have written agreement from the landowner before you increase the amount of waste you store if you are not the landowner
  • notify the Environment Agency in writing, in advance of the types and quantities of waste you want to store over your permitted limits
  • store all waste within the permitted site boundary
  • keep all storage areas secure to prevent unauthorised access
  • manage the waste you receive on site on a strict rotation basis so waste received on the site first is removed from the site first and that you separate waste of different storage age
  • make sure all waste above the limits in your permit is removed from site within 3 months unless we have agreed otherwise in writing – and in all cases by the expiry date on this COVID-19 RPS
  • do a written review of the risks of storing additional waste and how it will affect any plans, for example, your management system and fire prevention plan
  • make a record of any changes you make to your plans and comply with them – you must make the record of change available to all your staff and to the Environment Agency on request
  • keep records to show that you have complied with the conditions in this COVID-19 RPS for 24 months – these must be available to the Environment Agency on request

You must not:

  • store a type of waste that is not on your permit
  • store waste for more than 3 months unless we have agreed this in writing

You must make sure that temporarily increasing the amount of waste you store does not endanger human health or the environment. You 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

Places of Special Interest include but are not limited to:

  • European sites (Special Areas of Conservation and Special Protection Areas)
  • Ramsar sites
  • Sites of Special Scientific Interest
  • national and local nature reserves
  • Areas of Outstanding Natural Beauty
  • Marine Conservation Zones
  • National Parks

If you operate under this COVID-19 RPS but think you may no longer be able to comply with its conditions, you must tell the Environment Agency immediately.

3. Enforcement


A COVID-19 RPS means that the Environment Agency will not normally take enforcement action against you provided:

  • your activity meets the description set out in this COVID-19 RPS
  • you comply with the conditions set out in this COVID-19 RPS
  • your activity does not and is not likely to, cause environmental pollution or harm human health
  • you have taken all reasonable steps to comply with your permit

4. When to check back


This COVID-19 RPS will be withdrawn on 30 September 2020 unless we extend it. After this date, you must comply with your permit.

5. Contact the Environment Agency


You must notify the Environment Agency by email before using this COVID-19 RPS.

Put this wording in the title of your email: Waste COVID-19 RPS C2 – ‘For information’.

If you need us to respond to a query please add ‘For action’ at the end of the wording in the title of your email.




More News

Adam Hewitt

ATF Professional is produced by ARW- Group LTD, which is registered in England and Wales with Company Number 14914439

The views and opinions expressed on ATF Professional are solely those of the original authors and other contributors. These views and opinions do not necessarily represent those of the editor, publisher or staff of ATF Professional.


01432 355099

© All rights reserved

Owain Griffiths

Owain Griffiths

Head of Circular Economy at Volvo Cars

Owain joined Volvo Cars in June 2021 to lead Circular Economy in the Global Sustainability Team. The company has committed to being a circular business by 2040 and has financial, recycled content and CO2 based targets for 2025, all of which Owain is working across the company to make happen. Owain previously worked for circular economy consultancy Oakdene Hollins where he advised businesses on evidence led circular economy implementation. 

Turning into a circular business and the importance of vehicle reuse and recycling.

The presentation will cover the work Volvo Cars is doing to achieve 2025 but mainly focus on the transformational work towards 2040 and the business and value chain changes being considered. Attention will be paid to the way vehicles are being dealt with at the end of life and the complexities of closing material and component loops. Opportunities and challenges which Volvo Cars is facing will be presented including engagement with 3rd parties and increasing pressure from stakeholders.

e2e awards logo

e2e Total Loss Vehicle Management [e2e] is the UK’s only salvage and automotive recycling network with nationwide, environmentally compliant sites delivering performance resilience and service reliability to the insurance and fleet markets.  The network’s online salvage auction drives strong salvage resale values and faster sales.  e2e’s salvage clients have access to the network’s stocks of over 5 million quality graded, warranty assured reclaimed parts. 

The power of the network model means e2e has the ability to influence industry standards and is committed to continually raising the bar whilst redefining the role and perceived value of the salvage operator.  Network members adhere to robust service level agreements, against which they are audited, in order to ensure performance consistency and a market leading customer experience.  

The salvage and recycling operating environment is evolving rapidly, and e2e is anticipating, listening and responding to changing market needs.  Regulatory compliance, ESG, reclaimed parts, customer experience, EVs, new vehicle technologies, data and reputation risk are just some of many considerations linked to the procurement of salvage services.  e2e will drive further added value to clients and members through the adoption and application of emerging technologies, continuing to differentiate its proposition and position salvage services as a professional partnership. 

New Client Special Offer

20% Off

Aenean leo ligulaconsequat vitae, eleifend acer neque sed ipsum. Nam quam nunc, blandit vel, tempus.