Introduction of a UK - wide digital waste tracking system: partial business regulatory impact assessment

A business and regulatory impact assessment (BRIA) to assess the impact on Scotland of proposals to implement a UK-wide mandatory waste tracking system. This accompanies a UK-wide consultation on these proposals, available here:

5. Scottish firms impact test

71. The Waste Tracking User Panel has been used to engage with stakeholders to understand their requirements for a digital system, the potential impacts of a digital system and to test prototype digital services.

72. The user panel consists of around 1200 stakeholders, of which, 465 users operate in Scotland. The Scottish Stakeholders on the User Panel represent:

  • 91 businesses with 1-10 employees (micro-businesses),
  • 151 businesses with 11-250 (small and medium enterprises (SMEs), and
  • 201 with 250+ employees (macro-businesses)
  • SEPA
  • local authorities (17 of the 32 Scottish local authorities are represented)

73. The number of businesses affected by the policy will depend on the scope of the electronic waste tracking system (e.g. how exemptions are applied will change the scope), which will be informed by the consultation. These businesses will include waste producers (e.g. commercial and industrial businesses) and the waste industry (e.g. waste carriers, brokers and dealers and waste treatment sites).

74. The expected monetary impacts on these businesses is set out above. It is important to note that the costs of transitioning to an electronic waste tracking system are calculated only for waste sites. The expected transition costs for waste carriers, brokers and dealers, exempt waste sites and waste producers have not been monetised at this stage – please see section 8 of the UK impact assessment ( for a qualitative description of these costs. We will seek additional views on the likely impact on producers of waste from transitioning to using digital records and a centralised service through stakeholder engagement.

5.1 Competition assessment

75. The main impact on competition will be encouraging a more level playing field within the waste industry and supporting legitimate businesses. We expect that the waste tracking system will move a significant proportion of illegally handled waste to being handled legally. This shift will offer opportunities to legitimate businesses in terms of increased access to waste from which businesses can profit, and in turn improved opportunities to invest in their business (either through increased labour force or capital investments) as a result of having greater scope for profit. A more level playing field should also improve efficiency within the sector.

76. Only operators who can and do comply with digital waste tracking will stay in the market. As such, increased investment and running costs may be an economic barrier to entry to a small number of businesses. However, this intervention has been carefully designed to prevent illegal and non-compliant waste operators from entering/staying in the waste sector, whilst still enabling compliant businesses to operate by ensuring costs of compliance are set at a reasonable level.

77. We will welcome views on the competition implications of waste tracking through the consultation.

5.2 Consumer assessment

78. No impact on consumers is expected as a result of this policy. However, if any impacts are identified through further consultation, this BRIA will be updated.

5.3 Test run of business forms

79. This policy intends to mandate the use of a digital service to report waste movements. The development of a prototype service has been informed through regular user testing and feedback through the Waste Tracking User Panel (1200 members, 450 operating across Scotland). This iterative process will continue as services are developed further.

5.4 Digital impact test

80. While this policy intends to mandate the use of a digital service to track waste movements, we recognise that some individuals, either working within businesses or as sole traders may be digitally excluded, for example, due to religious beliefs or lack of digital connectivity. We intend to provide telephone and mail services to enable digitally excluded persons to report waste movements to the service. We intend to consult on these arrangements and this BRIA will be updated if any relevant information is collected.

5.5 Legal Aid impact test

81. No impact on Legal Aid is expected



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