Before any waste leaves your site, you have a legal duty to classify it. That means giving it the right waste code and deciding whether it’s hazardous. The code goes on every waste transfer note and consignment note. If it’s wrong, loads get rejected, costs go up and the liability lands on you.
Most businesses never need to read the Environment Agency’s 180 page technical guidance, known as WM3. This guide covers what most businesses need to know, and when to call in a specialist.
What are EWC codes?
Every type of waste has a six digit code from the List of Waste, still widely called the EWC code (European Waste Catalogue). The codes are grouped into 20 chapters by the industry or process the waste comes from. For example:
- Chapter 13: oil wastes and liquid fuel wastes
- Chapter 15: packaging, absorbents, wiping cloths and protective clothing
- Chapter 16: wastes not otherwise specified, including batteries, vehicles and electrical equipment
- Chapter 17: construction and demolition waste, including excavated soil
- Chapter 20: municipal wastes, including separately collected fractions from businesses
The code is written as three pairs of digits, such as 17 05 04.
How to spot a hazardous code
Any code with an asterisk (*) is a hazardous waste entry. For example, 17 06 05* is construction materials containing asbestos. If the correct code for your waste has an asterisk, it’s hazardous. That means consignment notes, a carrier licensed for hazardous waste and a permitted receiving site.
Codes fall into three types.
Absolute entries and mirror entries
Absolute hazardous. The waste is always hazardous, whatever is in it. Examples:
| Code | Description | Where you’ll see it |
|---|---|---|
| 17 06 05* | Construction materials containing asbestos | Asbestos cement, AIB, floor tiles (see asbestos disposal) |
| 13 02 05* | Mineral based non-chlorinated engine, gear and lubricating oils | Garages, plant, workshops (see oil and fuel disposal) |
| 16 06 01* | Lead batteries | Vehicle and forklift batteries (see battery and WEEE disposal) |
| 20 01 21* | Fluorescent tubes and other mercury containing waste | Office and warehouse lighting |
Absolute non-hazardous. The waste is never hazardous, as long as it really is what the code describes and hasn’t been contaminated. Examples include 17 02 01 (wood) and 20 03 01 (mixed municipal waste).
Mirror entries. These come in pairs, one hazardous and one not. Which one applies depends on what’s actually in your waste. This is where most classification mistakes happen.
| Hazardous entry | Non-hazardous mirror | Typical question |
|---|---|---|
| 17 05 03* Soil and stones containing hazardous substances | 17 05 04 Soil and stones other than 17 05 03 | Is the soil contaminated with hydrocarbons, metals or asbestos? |
| 17 03 01* Bituminous mixtures containing coal tar | 17 03 02 Bituminous mixtures other than 17 03 01 | Do the road planings contain coal tar? |
| 17 09 03* Other construction and demolition wastes containing hazardous substances | 17 09 04 Mixed construction and demolition waste other than 17 09 01, 17 09 02 and 17 09 03 | Is there anything hazardous in the mixed skip? |
| 08 01 11* Waste paint containing organic solvents or other hazardous substances | 08 01 12 Waste paint other than 08 01 11 | Is the paint solvent based or water based? |
With a mirror entry you can’t just pick the non-hazardous code because it’s cheaper. You have to show that the waste doesn’t have any hazardous properties, which usually means sampling and lab testing.
The 15 hazardous properties
Waste is hazardous if it has one or more of 15 hazardous properties, numbered HP1 to HP15. The ones that come up most often on sites and in workshops are:
- HP3 Flammable: fuels, solvents, some paints and adhesives
- HP4 Irritant and HP8 Corrosive: acids, alkalis, some cleaning chemicals, battery acid
- HP6 Acute toxicity: pesticides and some chemicals
- HP7 Carcinogenic: asbestos, coal tar, some oils
- HP14 Ecotoxic: oils, fuels and many metal compounds in contaminated soil
The full list also covers explosive, oxidising, infectious, mutagenic and sensitising properties, among others. For a product that’s become waste, the safety data sheet is the best place to start, because its hazard statements map to hazardous properties. Orange and black danger symbols or red and white hazard pictograms on the label are also a strong sign.
How to classify your waste in 4 steps
- Find the chapter. Start with the process or industry that produced the waste, then look for a specific code before falling back on a general one.
- Check for an asterisk. If it’s absolute hazardous, treat it as hazardous. If it’s absolute non-hazardous, make sure it isn’t contaminated.
- If it’s a mirror entry, assess the contents. Use safety data sheets, site history and, where needed, sampling and lab analysis against the hazardous properties.
- Record it. Put the code, description and any hazardous properties on your paperwork, and keep your evidence (test results, data sheets). That evidence protects you if the classification is ever questioned.
If you’re not sure, get advice from a specialist waste contractor. That’s the Environment Agency’s own advice too.
Classification testing and WAC testing
These are two different tests, and people often mix them up, especially with soil:
- Classification testing (WM3) tells you whether the waste is hazardous or non-hazardous.
- WAC testing (Waste Acceptance Criteria) tells you which type of landfill can accept it: inert, non-hazardous or hazardous.
For excavated soil you often need both. A soil can be non-hazardous and still fail inert WAC, which affects where it can go and what it costs. Our contaminated soil disposal team can arrange sampling and interpret the results.
POPs waste
Some wastes contain persistent organic pollutants (POPs), such as certain flame retardants. They have to be destroyed, usually by incineration, and can’t be landfilled or mixed with other waste. The best known example is upholstered domestic seating: sofas, armchairs and upholstered dining chairs. POPs waste isn’t always classed as hazardous, but it has its own disposal rules.
Never mix hazardous waste
It’s illegal to mix hazardous waste with non-hazardous waste, or to mix different hazardous wastes together. One tin of solvent paint or a few fluorescent tubes in a general skip can turn the whole load into hazardous waste, with the extra cost and paperwork that brings. Keep a separate, labelled container for each hazardous waste stream on site.
Need help classifying or collecting hazardous waste?
Select A Skip works with licensed hazardous waste carriers and treatment sites across the UK. We can help with the waste code, the container and the paperwork. See our hazardous waste services, get a quote or call 01743 341 000.
Sources: GOV.UK, Classify different types of waste: your legal responsibilities; Environment Agency Technical Guidance WM3, Waste classification.