Recycled aggregates – “Product” or “Waste”?

QP Aggregates CoverAggregates manufactured from inert wastes remain waste unless the recycling process meets specific criteria to comply with the EU End of Waste Regulations. These give two options for determining whether a material has ceased to be waste:

  • Comply with a Quality Protocol, or
  • Establish that your process achieves product-equivalence by carrying out an “end of waste assessment” and agree it with the regulator, which, in the UK would be one of the Environment Agencies (EA / SEPA / NIEA / NRW)

Fortunately, in the UK, there is a Quality Protocol for aggregates (click on the image) and providing your supplier complies with it (and can, if challenged, demonstrate compliance), the aggregates you buy will be considered to be “product” rather than “waste”, and you need concern yourself no further. But needless to say, if your supplier does not, the material you receive is still legally “waste” and all the requirements of UK waste legislation apply to it, for example the Waste Duty of Care (Carriers Licences, WTNs, etc), and Waste Permitting (U1 Waste exemptions).

Checking is simple. In addition to a number of other delivery documentation requirements, Clause 3.3.2 of the Protocol states that:

“The delivery documentation must include: … a statement that the product was produced in compliance with this Quality Protocol”

and details further documentation that should be provided when requested by the purchaser such as test results to demonstrate compliance with specific criteria (detailed in Appendix B) depending upon the end use, the Factory Production Control manual, etc – in other words not only to say it complies, but also to be able to prove it if necessary.

So, what did you ask for when you bought the last load, and what did it say on your last delivery note? Oh, and the same requirements apply if you crush your own waste into aggregates for the piling mat, or haul road – did you turn it into a “product”, or was it “waste” you used on site?