Digital Waste Tracking: business regulatory impact assessment

4. Options

4.1 Outlining the options

56. In the initial stages of the Waste Tracking project, non-regulatory options for tracking waste were considered. These included communication campaigns and free training to promote the use of digitally recording waste movements/transfers in IT systems.

57. Non-regulatory options have not been presented in the options appraisal as we do not believe that they can meet the policy objectives, and would not offer the same net benefits. We expect voluntary digital tracking to have low uptake, and a majority of companies will continue to track in their current ways (non digital). Additionally, it will not provide any standardisation or full digitalisation so can give rise to additional costs to standardise data for use, which can increase the error rate of the data, and fail to meet policy objectives.

58. For example, communication campaigns have been disregarded as a suitable option given widespread non-compliance and the cost to some businesses of transitioning to digital recording of data. Communication campaigns alone are unlikely to have the desired impact of bringing all businesses into digitally recording their waste movements/transfers. Even in the case of a well-received communication campaign and high take up of training, we are unable to guarantee that everyone will submit their data through existing channels.

59. Effective non-regulatory options would rely on all businesses voluntarily recording their data in a digital format (and using unique ID codes to identify each movement of waste from producer to receiving site). As described above, there are already several voluntary IT systems that can be used to record waste data, but insufficient uptake of these systems has prevailed. Even if a significant number of businesses voluntarily complied with digital recording (and unique ID codes) but a relatively small number of operators did not voluntarily participate, then the whole system would be undermined and the potential benefits to businesses, governments and regulators would quickly diminish. This is because non-participation from a small number of operators would create ‘breaks’ in data which would hinder the utility of the dataset.

60. In addition, non-participation is more likely to be carried out by illegal operators that are motivated by the perceived private benefits of illegal activity such as avoiding legitimate disposal and treatment costs. Without these operators reporting data, voluntary initiatives will not be able to deliver a reduction in waste crime, which is one of the key objectives of tracking waste.

61. This highlights the underlying coordination failure in the sector, where voluntary participation depends on collective effort, but individual actors have limited incentive to comply unless others do the same. In the absence of mandatory requirements, legitimate operators bear the costs of participation while illegal or disengaged operators can exploit the systems weaknesses, benefiting from poor oversight without contributing data.

62. A long list of 11 potential options was created and considered against six critical success factors (delivers legislative & regulatory requirements, affordability, effectiveness of data collected, burden on industry, achievability, and supplier availability; see UK Impact Assessment for full details). Of the 11 options, a baseline and two regulatory proposals were shortlisted, and presented in this Impact Assessment. Table 3 below summarises the differences between the three options. These are:

• Option 1 (baseline): The baseline represents a ‘do minimum’ option. Waste operators will be mandated only to digitally record and submit data on movements of hazardous waste and Persistent and Organic Pollutants (POPs) waste.
• Option 2: Implement a mandatory digital Waste Tracking service that requires all permitted receiving sites to submit data on all waste received at their sites in near real time.
• Option 3 (Preferred Option): Implement a mandatory digital Waste Tracking service for all waste.

4.2 Description of Options

Option 1: Do minimum (baseline)

63. In the absence of a central Waste Tracking service for all waste, the four nations would be required to meet existing requirements to introduce measures to digitally track hazardous waste^[30] and waste containing persistent organic pollutants (POPs)^[31]. The four nations would therefore need to develop a new IT service to enable all records of hazardous waste movements and waste containing POPs to be made available to regulators via a coordinated digital registry. The costs and benefits associated with this POPs and hazardous waste digitalized waste tracking service have therefore been captured in the baseline scenario, and costs for other options are in addition to baseline cost.

64. It is necessary to capture the costs associated with building and running the new IT service to track hazardous waste and waste that contains POPs since these are measures which are required to be introduced.

65. A new Waste Tracking service for all waste would facilitate all of the functions that these services would be built for, and therefore these IT services would not need to be separately operated if a Waste Tracking service for all waste is implemented. The new service(s) must track hazardous waste (and materials and products produced from hazardous waste), and waste that contains POPs (that may be hazardous or non-hazardous waste).

66. These new IT systems are expected to be built over a 3-year period (2026-2028) in such a way that meets current, and potential future, regulatory requirements. The digital tracking of hazardous waste is expected to result in some benefits compared to the current services that are in use to capture hazardous waste data (typically Excel and xml documents sent via email).

67. However, a new Hazardous and POPs Waste Tracking service will not effectively track and monitor all waste from production to disposal, as there will be significant gaps in the types of waste covered by these services, most notably a large proportion of non-hazardous commercial and industrial waste and waste exported under green list controls^[32]. As a result, these new IT services will not deliver the benefits that we expect a centralised Waste Tracking service for all waste to deliver.

Option 2: Digital Waste Tracking service that requires all permitted receiving sites to submit data on all waste received at their sites in near real time

68. Under this option, all those involved in operating a permitted waste receiving site^[33] would be required to record individual movements and transfers of waste into their waste site using the digital service. Businesses would have two options for how to record waste movements, and would be required to record movements on the service within two working days of a waste movement taking place.

69. Businesses would be able to integrate directly with the API to upload data from their own waste data software. Following registration via the Digital Waste Tracking onboarding portal they will be provided their API credentials which will be added to their software to safely and securely authenticate them to send waste data (push) or update (put) waste records should change occur. This would mean that as soon as businesses recorded waste movements on their own internal systems it could immediately be transferred to the Waste Tracking service.

70. For businesses that don’t already have their own waste management software or chose not to initially invest in new software for compliance, there would also be a temporary 12-month fallback option that is based on a secondary data submission. Users of the fallback option would register via the online portal as above and receive their API credentials to use with their native spreadsheet software. They will be able to download a spreadsheet example based on their own spreadsheet software (GoogleDocs, Excel or other free options) which will demonstrate not only the data fields and format that they would need to submit but how they would use their own credentials to manage authentication when submitting their waste movements. They would input data directly into a secondary submission method (or copy across from their own records), then define their command so their waste data is then uploaded to the API.

71. Private beta started with waste software vendors & developers in November 2025 with waste receivers following on once those API connections in their software is in place. It is expected that registration for the public beta of the Waste Tracking service will commence in early 2026. Use of the new system will be mandatory for permitted receiving sites from October 2026 in England, Wales and Northern Ireland, and January 2027 in Scotland^[34]. Businesses will be required to pay a service charge to cover the maintenance and build costs of the service.

72. Option 2 would deliver only a partial version of the intended policy outcomes. By requiring data submission solely from permitted receiving site, it would improve the consistency of information at the end of the waste chain but would not provide full visibility of movements from producers through carriers to disposal.

73. As a result, Option 2 would not significantly reduce waste crime, address data gaps earlier in the chain, or deliver the wider resource efficiency and market fairness benefits expected under the preferred Option 3.

Option 3 (Preferred Option): Digital Waste Tracking service for all waste

74. Under Option 3 a mandatory Digital Waste Tracking service for all waste will be created^[35]. It will provide a means for businesses to record all waste movements and transfers in one central service and will enable the effective tracking of waste through the economy. All actors in the waste sector will be onboarded and required to submit information on waste movements, production and treatment.

75. The Waste Tracking service will be an IT service that will replace the current requirement for written waste transfer notes (for non-hazardous waste), consignee returns (for hazardous waste), waste site returns and Annex VII forms for green list waste imports and exports. The service will be developed with the requirement to record and submit information on hazardous waste and the requirement to trace waste containing POPs in mind, to ensure that these existing requirements are met.

76. For the purposes of this analysis we have assumed that there will be both a direct from software API option and a temporary backup option for 12 months that does not require businesses to have existing waste management software, per Option 2.

77. Businesses will be financially responsible for covering the costs of running the service. This includes ongoing costs of paying a service charge for the maintenance and running of the service, and the cost for new software for those that don’t have existing software.

78. In contrast to Option 2, Option 3 introduces a fully end to end digital tracking system covering all actors involved in the movement of the waste, enabling accessible oversight, more effective enforcement, and a comprehensive dataset to support circular economy objectives. We would also expect to realise a reduction in waste crime due to this. The distinction between waste receivers only (Option 2), and all waste companies (Option 3), explains why Option 2 delivers limited benefits and Option 3 is required to achieve the full set of policy outcomes.