Trommel Fines

In 2020 the Environment Agency (EA) undertook an investigation into trommel fines producers which claimed that of 50 samples taken; 54% of samples contained elevated hydrocarbons, 10% of samples contained elevated heavy metals, and 60% of samples exceeded the HMRC Loss on Ignition threshold. They also found that no producers had carried out WM3 compliant assessments (a legal requirement) prior to them classifying the waste as non-hazardous.

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The EA are subsequently contacting all waste operators that produce trommel fines emphasising the importance of correct classification and stating that “only when a waste assessment, carried out in line with WM3 guidance, shows the waste does not display any hazardous properties, can the non-hazardous mirror waste codes be assigned (19 12 12)”.

The EA, who are now working alongside HMRC, closed the letter by stating that they “will request to see copies of your waste assessments during future compliance visits”.

Waste Classification Sampling and Reporting / Landfill Tax

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Correct waste classification is vital in ensuring your waste is properly managed, and unless a hazardous property assessment has been carried out, mirror entry waste, such as trommel fines, cannot legally be classified as non-hazardous. If you cannot demonstrate that your fines are non-hazardous, then you also cannot demonstrate that they qualify for lower rate landfill tax. The disposal cost per load between lower and standard rate landfill tax can be well in excess of £1,000.

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accuWaste can independently sample and provide a waste classification report that can be provided to landfill operators, not only demonstrating compliance with your Duty of Care, but also that they qualify for lower rate landfill tax.