Digital Waste Tracking: business regulatory impact assessment

9. Non-monetised costs (Options 2 and 3)

162. Not all costs associated with Digital Waste Tracking can be monetised, but should be considered alongside those that we have been able to monetise.

9.1 Compliance monitoring costs (chargeable to industry)

163. Currently, the costs of compliance monitoring of operators that handle hazardous waste is chargeable to operators through the payment of consignment fees. As part of the proposals for a Waste Tracking service for all waste types, regulators would also be able to recover the costs associated with monitoring the compliance of operators that handle non-hazardous waste. The functions that would be in-scope of cost recovery are yet to be confirmed. The Scottish Government is working closely with SEPA, the other nations and regulators to establish these functions and an associated cost estimate.

9.2 Transition costs to producers of waste

164. Transition costs for producers of waste could include the time cost of staff familiarising themselves with the new regulations and the time cost of training staff to effectively comply with the regulations. Transition costs have been monetised where producers also act as waste carriers, brokers or dealers (CBDs), as these businesses are required to create and submit DWT records as the arranger of waste movement. However, we have not separately monetised transition costs for producers who do not act as carriers, brokers or dealers, due to uncertainty over the total number of waste producers in scope, and uncertainty over how many producers would choose to enter DWT records themselves rather than relying on waste carrier or broker.

165. Under the DWT policy, the legal responsibility for creating the waste tracking record sits with the person arranging the waste movement, which will typically be the carrier or broker, not the waste producer. As a result, most producers are expected to incur minimal additional transition costs, limited primarily to understanding the requirements and receiving a DWT record reference from their waste contractor. Any additional transition costs faced by producers who voluntarily choose to enter data themselves are therefore expected to be small and case specific, and there is insufficient evidence to robustly quantify these at this stage.

9.3 Transition costs to exempt waste sites

166. Many exempt waste sites will incur transition costs to comply with the requirements to digitally record details about the waste they receive under Option 3. The transition costs are likely to be similar to those that we assume will be incurred by permitted waste sites in Option 2, and include staff training costs, familiarisation costs, customer engagement, changes to current IT services and the provision of any on-site technology. We have not been able to accurately estimate the costs to these businesses.

167. The transition costs to exempt waste sites will differ significantly between individual sites depending on how much waste they handle and their current use of IT services. Unlike permitted sites, exempt sites are not required to pay to register and we cannot reliably determine how many exempt sites are actually active. Without an accurate count of active sites, it is difficult to produce a defensible cost estimate.