EMS is now rebranded as Cura Terrae.
11th August 2025

Management and Compliance Bulletin – 11th August 2025

Lisa Hawson Senior Environmental Consultant / Team Leader

Your monthly update on legislation, guidance, interesting news articles, and webinars from the environmental sector.

Guidance

Waste Exemption Charges

The Environment Agency (EA) has implemented charges for waste exemptions. Most businesses have to pay to register waste exemptions. Charges are made up of a registration charge and a compliance charge.

You pay £56 registration charge each time you register one or more exemptions on a site. This charge covers the EA’s costs for registering exemptions.

You pay a compliance charge for each exemption. The cost of the compliance charge depends on which band the exemption is in.

There are 4 bands:

  • Upper band – £1,236 (this band applies to T8, T9 and U16 exemptions only)
  • Band 1 – £420
  • Band 2 – £212
  • Band 3 – £30

The compliance charge covers the EA’s costs for checking that exemption conditions are followed.

Source: GOV.UK

For the full guidance, click here.

Monitoring Emissions from Back-up Generators: RPS 353

This Regulatory Position Statement (RPS) applies to when you do not need to monitor emissions from permitted Medium Combustion Plant (MCP) that are used for back-up generation.

The EA will not normally take enforcement action against you if you do not comply with the legal requirement provided the following:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
    • cause a risk to water, air, soil, plants or animals
    • cause a nuisance through noise or odours
    • adversely affect the countryside or places of special interest.

You must comply with the following conditions:

  • This RPS applies to operation of one or more MCP that are permitted to operate for on-site back-up power generation and are tested for no more than 50 hours per year.
  • This applies to an installation with aggregated back-up capacity greater than 20 MegaWatt thermal (MWth) input that are regulated by the EA.
  • This only applies when there is no existing permanent or safe means to monitor the emissions from your back-up generator.

You must:

  • get the EA’s agreement before you use this RPS by contacting your regulatory officer or enquiries@environment-agency.gov.uk with ‘RPS 353’ in the subject
  • confirm that you are not able to monitor emissions from the MCP safely or where there is no monitoring port
  • identify when safe and permanent monitoring ports and access will be installed, in line with any planned maintenance scheduled for the generator
  • maintain the MCP in line with the original equipment manufacturer’s instructions (or better)
  • keep records for two years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the EA.

You must not:

  • use this RPS to avoid monitoring emissions from back-up generators that have a safe and permanent means of access for monitoring
  • use this RPS to install new back-up generators without suitable monitoring access.

The EA will review this RPS by 9 July 2028 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

Source: GOV.UK

To read the full guidance, click here.

Operating a Mobile Boiler as a Medium Combustion Plant (MCP): RPS 354

This RPS applies to temporarily located steam and hot water boiler plant that are mobile MCP.

The EA will not normally take enforcement action against you if you do not comply with the legal requirement provided the following:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
    • cause a risk to water, air, soil, plants or animals,
    • cause a nuisance through noise or odours,
    • adversely affect the countryside or places of special interest.

You must:

  • maintain and operate the mobile boilers in accordance with the manufacturer’s instructions.
  • keep records for two years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the EA on request.

Where mobile boilers are used at regulated facilities, you must also notify the EA by contacting your local regulatory officer and including the:

  • capacity (MWth) of the boiler plant,
  • fuel used,
  • duration of plant on site.

You must not:

  • use mobile boilers at the same site for more than 12 months,
  • use mobile boilers to increase the operational thermal capacity where a regulated facility is undertaken.

The EA intends to review this RPS by 7 July 2027 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK

For the full guidance, click here.

Accepting E-bikes at Waste Treatment Sites: RPS 343

This RPS applies to operators of waste treatment sites who accept e-bikes under their Waste Electrical and Electronic Equipment (WEEE) permit or a registered T11 waste exemption, but don’t have the correct waste code (16 01 04*) to do so.

This RPS does not change your legal requirements to comply with your environmental permit.

However, the EA will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
    • cause a risk to water, air, soil, plants or animals,
    • cause a nuisance through noise or odours,
    • adversely affect the countryside or places of special interest.

You must:

  • hold a permit to treat WEEE or have registered a T11 waste exemption,
  • comply in full with your permit or T11 conditions and limitations to accept e-bikes with waste code 16 01 04* under this RPS,
  • keep records for three years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the EA on request.

You should allocate waste code 16 01 04* to scrapped e-bikes.

You should allocate waste code 20 01 35* to other Personal Light Electric Vehicles (PLEVs) such as, but not limited to, e-scooters, segways, and hoverboards.

This RPS clarifies the correct coding and appropriate disposal of PLEVs which are seized by the police and other enforcement agencies. These are typically electric motorbikes or PLEVs which are illegal to use on a road such as:

  • e-scooters
  • electric unicycles and e-bikes that do not conform with the Electrically Assisted Pedal Cycle (EAPC) Regulations (1983) and EAPC standards and legal requirements.

The EA will review this RPS by 01 September 2028 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK

For the full guidance, click here.

Burning Waste as a Fuel in a Small Appliance: RPS 340

This RPS applies to using waste particle board off-cuts (waste code 03 01 05) as a fuel in a small appliance by operators who have registered a U4 waste exemption: burning waste as fuel in a small appliance.

This RPS does not change your legal requirements to comply with your environmental permit or comply with a registered U4 waste exemption for the burning of waste as a fuel in a small appliance.

However, the EA will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
  • cause a risk to water, air, soil, plants or animals,
  • cause a nuisance through noise or odours,
  • adversely affect the countryside or places of special interest.

You must:

  • register a U4 waste exemption and comply with the limits and conditions in full,
  • store waste in a building or under cover,
  • only burn particle board off-cuts at the place where the waste was produced.

You must not:

  • burn particle board which has been chemically treated after manufacture, or has any veneers or facings,
  • store more waste for burning than you need,
  • store more than 10 tonnes of all waste for use as a fuel at any one time.

The EA will review this RPS by 01 April 2028 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK

For the full guidance, click here.

Retaining Shock Absorbers and Airbags in End of Life Vehicles (ELVs): RPS 195

This RPS applies to the storage of intact shock absorbers and undeployed airbags in otherwise fully depolluted ELVs on hardstanding. This is to enable the reuse of shock absorbers and airbags.

This RPS does not change your legal requirements to comply with your environmental permit for a waste operation when you store intact shock absorbers and undeployed airbags in otherwise fully depolluted ELVs on hardstanding.

However, the EA will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
  • cause a risk to water, air, soil, plants or animals,
  • cause a nuisance through noise or odours,
  • adversely affect the countryside or places of special interest.

You must make sure:

  • the ELVs are fully depolluted before they are stored on hardstanding, except for the intact shock absorbers or undeployed airbags (or both).
  • the ELVs are stored and treated in accordance with your environmental permit.
  • the shock absorbers or airbags are suitable for reuse.
  • the shock absorbers have not been damaged and are not leaking oil.
  • the airbags have not been damaged or deployed.
  • you keep records for three years to show that you have complied with this RPS and make these records available to the EA on request.

You must not:

  • send ELVs for crushing and shredding unless they have been fully depolluted,
  • damage or prevent the reuse of airbags or shock absorbers.

The EA will review this RPS by 01 July 2026 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK

For the full guidance, click here.

Storing and Handling Waste Glass Containing Other Wastes: RPS 292

This RPS applies to sites that were notified and have received our agreement to use this RPS before 21 June 2024.

It allows you to accept glass waste that has been processed but not properly sorted and still contains other non-hazardous wastes, such as plastic, paper, and metal. You must code this as 19 12 12.

You can continue to handle waste glass containing other non-hazardous wastes (waste code 19 12 12) until the EA has either:

  • sent your permit variation to you,
  • determined your application for a new permit.

This RPS does not change your legal requirements to have an environmental permit where one is required; nor to register an activity as exempt where you are required to do so.

However, the EA will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
  • cause a risk to water, air, soil, plants or animals,
  • cause a nuisance through noise or odours,
  • adversely affect the countryside or places of special interest.

You must:

  • have the EA’s written agreement to use this RPS,
  • store and treat the 19 12 12 waste glass mixed with other non-hazardous wastes on an impermeable surface with sealed drainage,
  • remove non-glass waste before using the glass to produce an aggregate,
  • have appropriate measures in place to prevent litter, odour, pests, and flies,
  • keep records for two years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the EA on request.

You must not:

  • continue to use this RPS if your permit application or variation is rejected.

The EA will review this RPS by 30 April 2026 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK For the full guidance, click here.

Storing and Treating Waste Oyster Shells: RPS 347

This RPS applies to operators who store and treat waste oyster shells (waste code 02 02 02) for use in new products.

This RPS does not change your legal requirement to:

  • have an environmental permit where one is required,
  • register an activity as exempt where you are required to do so.

However, the EA will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
  • cause a risk to water, air, soil, plants or animals,
  • cause a nuisance through noise or odours,
  • adversely affect the countryside or places of special interest.

You must only:

  • accept cleaned waste oyster shells (with the tissue or flesh removed) from aquaculture and the food industry, including restaurants,
  • store and treat up to 50 tonnes of waste oyster shells over any 12-month period,
  • treat the waste oyster shells by cleaning, boiling, steaming, baking, or milling,
  • store waste for no more than six months,
  • keep records for two years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available to the EA on request.

The EA will review this RPS by 01 May 2028 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK For the full guidance, click here.

Treating Food Waste Where Food is Served and Consumed: RPS 229

This RPS applies to storing and treating food waste arising from the preparation or consumption of food on the same premises where that food has been prepared and served.

This RPS does not apply to waste produced by the food manufacturing and processing industry.

This RPS does not change your legal requirement to get an environmental permit for a waste operation when you store and treat food waste on the same premises where food is prepared and served.

However, the EA will not normally take enforcement action against you if you do not comply with this legal requirement provided that:

  • Your activity meets the description set out in this RPS.
  • You comply with the conditions set out in this RPS.
  • Your activity must not cause (or be likely to cause) pollution of the environment or harm to human health, and must not:
  • cause a risk to water, air, soil, plants or animals,
  • cause a nuisance through noise or odours,
  • adversely affect the countryside or places of special interest.

You must:

  • only store and treat food waste with waste code 20 01 08 (biodegradable kitchen and canteen waste),
  • only store and treat food waste arising from the preparation of food or leftover food that is not sold or consumed,
  • store and treat the waste at the premises where the food was served, for example at a restaurant, cafe or canteen, including premises that serve food prepared off-site,
  • only treat the food waste using equipment which removes non-food waste contamination and then macerates, heats, grinds, liquefies, dewaters, separates, screens, digests, or composts the food waste,
  • follow the manufacturer’s instructions to operate and maintain the equipment,
  • store and treat the food waste in a secure place – one where you have taken all reasonable precautions to prevent waste escaping and where the public cannot access it,
  • store the waste in containers that are fully enclosed and leak-proof,
  • provide secondary containment for liquid waste stored outside, such as a bund or any other system that prevents waste escaping,
  • present food waste for separate waste collection,
  • keep records for two years from the date of the last use of the RPS to show that you have complied with this RPS and make these records available.

You must not:

  • treat more than 100 cubic metres of waste a day,
  • store more than 50 cubic metres of waste at any time,
  • store waste for more than seven days – unless it is treated solid waste which is stable and sanitised, in which case you can store it for up to 30 days.

The EA will review this RPS by 30 June 2028 and can withdraw or amend the RPS before the review date if they consider it necessary. This includes where the activity that this RPS relates to has not changed.

You will need to check back from time to time, including at and before the review date, to see if this RPS still applies.

This RPS remains in force until it is removed from GOV.UK or is otherwise identified as having been withdrawn.

Source: GOV.UK For the full guidance, click here.

Articles

Warning Issued Against Unauthorised Building Work in Bassetlaw

The EA is reminding residents, landowners and developers in Bassetlaw about the law for carrying out work near main rivers and flood defences.

Among the EA’s statutory duties are powers to manage flood risk from the sea and main rivers. These types of works, known as flood risk activities, may need an environmental permit before they can begin.

The warning comes after the EA has become aware of unauthorised works in the Bassetlaw district in north Nottinghamshire.

Source: GOV.UK

For the full article, click here.

Trio Detained in Recycling Fraud Investigation

Two men and a woman have been arrested for conspiracy to commit fraud and money laundering, the EA announced on Wednesday, 30 July 2025.

In raids this week, EA officers worked with ‘North West Regional Organised Crime Unit’ to apprehend the individuals as part of an investigation into illegal recycling paperwork, which is often used by organised criminal gangs to launder money.

The Packaging Producer Responsibility Regulations were introduced to oblige the producers of waste packaging made from materials such as plastic, glass and cardboard to contribute towards the financial cost of recycling and disposing the waste.

Businesses that meet the criteria are required to prove they have made a financial contribution by purchasing credits, known as Packaging Export Recovery Notes, from waste reprocessors or exporters. However, the credits have a monetary value which means organised criminal gangs can look to infiltrate the sector and engage in high value fraud and money laundering.

Source: GOV.UK

For the full article, click here.

Broads warns of potential impact of flea treatments

The organisation that manages The Broads National Park has called for better awareness of the “shocking” impact pet flea treatments have on waterways.

Powerful insecticides that are banned in farming due to their harm to the environment are contained in “spot-on” products used on cats and dogs. The chemicals pose “significant risks” to aquatic wildlife, whether from a dog swimming in the water or indirectly when washing hands or pet bedding, the Broads Authority said.

The insecticides persist on a pet’s coat for week and the chemicals can remain active for up to 90 days, even though they kill fleas within 24-36 hours.

At particular risk are insects such as dragonflies, damselflies and freshwater beetles – all essential species for a healthy wetland system, the Broads Authority said. They spend much of their life underwater and provide food for fish, birds, and other wildlife, and are “extremely sensitive” to pollution.

Source: BBC

For the full article, click here.

Cura Terrae Services

Rebranding Of Environmental Monitoring Solutions Ltd

Environmental Monitoring Solutions Ltd (EMS Ltd) has officially rebranded as Cura Terrae, effective from 7th July 2025. From this date, all services will be delivered under the Cura Terrae name.

This rebrand signifies the successful completion of our integration into the Cura Terrae group, a key moment in the evolution of our business. The aim is to provide a clearer, more cohesive alignment across the services offered within the Cura Terrae group. As we embrace this new chapter, we remain committed to delivering the same high-quality services you have come to expect.

While our name may be changing, our dedication to industrial wastewater solutions, water flow and quality surveys, smart wastewater solutions and environmental management and compliance support remains unchanged. These areas will continue to be integral to our offering, and clients can expect a seamless experience with no disruption to services.

Key changes:

  • The legal entity name will change to Cura Terrae Water Limited.
  • Email addresses will transition to the cura-terrae.com domain, with emails to the old addresses automatically forwarded.
  • The name on our bank account will change, although the bank details will remain the same.

Other aspects, such as the company registration number, VAT number, registered office, and telephone numbers, will remain unchanged. Our team and service levels will also remain consistent throughout this transition.

About Cura Terrae

The Cura Terrae group is a multidisciplinary environmental group operating across the UK with services including ambient air monitoring, water monitoring, environmental advisory services, emissions testing, occupational hygiene, heritage and archaeology, ecology, environmental assessments and consenting, landscape, arboriculture, and habitats.

With a team of 350 dedicated professionals across 14 sites, Cura Terrae is committed to driving sustainable outcomes and ensuring compliance with environmental standards.

For the full range of services, click here.

Environmental legal compliance support service

As legislation surrounding environmental management becomes more complex, our team of environmental experts can give you peace of mind that your environmental legal responsibilities are being met.

Our service offers:

  • A quarterly report, emailed to nominated personnel, containing information on new and amended legislation, as well as news, guidance, consultations, case law, prosecutions and expert commentary.
  • A set number of hours of consultancy support delivered in various formats – email, phone, site visit, etc.
  • Snapshot environmental audit to review site operations against legal requirements and an associated compliance action plan.
  • Quarterly legal register updates on new, amended or revoked legislation which will be made available in easily digestible summaries with explicit commentary on how to maintain compliance.
  • Discounts on accredited and non-accredited environmental training coursesprovided by our practicing environmental consultants.

Our subscription service is available in three different formats: bronze, silver and gold. However, if your business’ requirements do not perfectly align with one of our packages, we can amend the package to meet the needs of your business.

We review and update clients’ existing legal registers quarterly to ensure the legislation remains applicable to their operations. This proactive approach helps clients stay informed about current regulatory requirements and prepared for any pending legislation that may impact their business.

All our environmental consultants have extensive knowledge of various industry sectors and established relationships with regulatory bodies, providing assurance that the advice and guidance you receive is informed and up to date. By utilising our team of experts, your business will experience numerous benefits:

  • Maintaining environmental legal compliance and keeping an up-to-date legal register – What is environmental compliance and why is it so important?
  • Compliance with Clauses 6.1.3 and 9.1.2 of ISO 14001:2015 (where an accredited Environmental Management System is in place).
  • Consistent guidance and support from a dedicated environmental consultant, with access to the Environmental Management Team.
  • Continuous environmental improvement and proactive environmental management, leading to potential cost savings due to increased efficiency.
  • Knowledge and insight into industry best practice and environmental events (webinars, seminars, expos, etc.).

As practicing environmental consultants, we understand that it is not a one-size-fits-all approach when it comes to maintaining compliance, as each business will have different requirements. To ensure we are meeting the needs of your business, we have aimed to make this service as flexible as possible. If you think this service would better suit your business with one or two adjustments, let us know. For example, some of our existing customers utilise the time allotted for the snapshot environmental audit as extra consultancy support time, to help develop their Environmental Management System, or close-out actions from their own internal environmental audits.

For further information, click here

Events

Resource & Waste Management (RWM) Expo

17 – 18 September 2025 NEC Birmingham

The RWM Expo returns in 2025 as the premier event for professionals across the recycling, resource, and waste management sectors. Whether you’re a waste leader, sustainability expert, or an industry newcomer, RWM offers the perfect platform to connect with global innovators, discover the latest trends, and source groundbreaking solutions for sustainable resource management.

Source: CIWM

To register, click here.