In the second blog of this series, two more influential regulations currently shaping the UK’s commercial and industrial waste sector will be explored: Waste Tracking and Landfill Tax. This follows on from CIRQLR CEO David Palmer-Jones’ presentation at RWM, where he examined six key pieces of legislation reshaping the waste sector, and their impact on the C&I market. Respectively, both pieces of legislation are significant in helping to drive increased transparency, accountability, and circularity, with implications not only for CIRQLR, but for the wider industry.
In the UK, an estimated two-thirds of material is reported inaccurately, representing clear and enduring difficulties for the waste industry. As a result, it has become increasingly complex to plan and invest in waste infrastructure, or develop circular economy strategies at a national level, where accurate data of C&I volumes is critical.
The forthcoming waste tracking system, set to be deployed in October 2026, is expected to change this. By calling for greater transparency and consistency across the handling process, waste tracking will supply the level of granular detail that is seen already within the public sector. Crucially, this will grant producers, waste companies and policymakers an end-to-end view of material flows within the C&I system.
Importantly, improved accuracy from the system will be a key mechanism for combating waste crime. By linking data from points of collection through to points of disposal, waste tracking will help to close loopholes which facilitate unlicensed operators to exploit grey areas and take advantage of ambiguities in the system. As highlighted by David, this will ultimately “force waste criminals to be fully criminal, rather than hiding in the shadows as they do today.” Greater traceability and enhanced visibility will drive grey areas of the sector into clear spaces of compliance, preventing waste from simply disappearing into the system.
Moving past enforcement, the opportunities for waste tracking to support industrial symbiosis are considerable. Access to more granular data will help to unearth where valuable materials are being lost, driving forward measures and initiatives to maintain resource circulation. Having a strong, evidence-based framework will in turn empower industrial strategy growth in the UK, where material flows facilitate development while minimising reliance on virgin resources.
Tracking C&I waste is essential for circular economy planning, and will represent significant impacts for CIRQLR, along with other C&I waste businesses. With accurate data and transparent overviews of material flows, greater gateways open for recovering more resources, which in turn reduces the amount of residual waste. This opportunity was signalled by David, who said: “So much material within streams goes missing. The more we can unearth it, the more we can understand it.”
Landfill Tax is widely regarded as one of the UK’s most powerful pieces of waste legislation. Acting as a behavioural change agent, it has driven systematic reform by making landfill neither convenient nor cheap. During his presentation at RWM, David described it as “the greatest influencer we’ve ever had in the UK”, a view reinforced by the fact that in a “very cost-focused” market, its impact cannot be underestimated. As David noted: “you put the price up, things change. Behaviours change, and investment comes into the marketplace.”
In April of this year, the UK Government initiated a consultation on reforming Landfill Tax. The aim is to support the UK’s circular economy transition, reduce tax complications, minimise waste crime, and decrease opportunities for non-compliance. The proposals include:
The proposal to remove discounts for fines has generated “a lot of noise” , commented David, particularly from the construction industry and housebuilders, who continue to argue for the need to “tip cheaply.” David highlighted that this was not the answer. This opposition comes at a time when Landfill Tax is regarded as the worst collected tax in the UK, representing severe levels of waste crime that are, for the most part, hidden. Tackling this criminality has been one of the government’s key motivations for reform - not just to raise costs, but to put a stop to those exploiting the system.
The government intends to escalate qualifying fines from the lower rate of £3.30 per tonne up to the standard rate of £126 per tonne. The current system is open to abuse, with large volumes of material being classified as inert waste to gain discounts. Signs of change are already visible, however, with fines now more closely controlled and increased ignition testing taking place across the industry. As David noted, “water discounts are generally disappearing which is very positive, again I think that’s been a bit of a ruse over the years.” Dredgings, however, continue to be used by hazardous waste businesses, although this accounts for only 1% of all dredgings and is an exemption that could easily be removed in the future.
The impact of Landfill Tax has already been seen across Europe, where it has driven a move away from mixed skips towards much greater segregation. In the UK, David believes there will also “progressively be a reduction in mixed skips. That may be difficult in some areas, [including] London”, as the cost of unsegregated skips rises. Large C&D operators are likely to continue investing in infrastructure to extract more material, but smaller players in the marketplace may struggle, as “capital outlay may be too much for them to continue.”
David highlighted that the treatment of fines - referring to the small particles generated through waste processing - is improving, with washing technologies supporting increased material recovery through reduced contamination. Washing of fines is already happening on a very small scale, but it is expected there will now be rapid progress. Alongside this, greater regulatory control will help to make waste crime easier to detect: “you won’t be able to drive over the weighbridge and call it something else. You’ll drive past the weighbridge, and it’s up to the authorities then to identify and catch criminals.”
With the strengthening of regulation, opportunities also arise for progress and other changes across the industry. For the C&I market, rising costs are expected to propel innovative measures forward, driving the development of new materials and more efficient recovery methods. Greater segregation will support stronger circularity by ensuring higher-quality outputs of material and reducing reliance on residual disposal. Crucially, the reform offers the opportunity to create a fairer system, where legitimate businesses are protected rather than undermined by waste crime.
Waste Tracking and Landfill Tax signify how legislation can act as an impetus for tangible change, beyond serving as a tool of enforcement. Through more accurate data, stronger action against waste crime, and greater incentives for segregation, both frameworks are driving meaningful developments in the way that materials are managed and recovered.
Part Three of this blog series will explore the remaining measures from David’s RWM presentation - the Deposit Return Scheme and the Emissions Trading Scheme - alongside a future driver, the Circular Economy Taskforce, to examine how these initiatives will help accelerate the UK’s transition towards a more circular system.
Emily Nurse, CIRQLR