SEPA sets out processes it uses to assess whether exported recycled material is illegal


The way the Scottish Environmental Protection Agency  (SEPA)decides whether recycled material destined for export is illegal has been explained at a seminar.

Organised by The Recycling Association, the seminar at Lancaster University was designed to help exporters not to fall foul of the Transfrontier Shipment regulations.


 SEPA waste shipment unit manager Colin Morrow explained that the organisation had changed its approach over the past two and a half years from random inspections at port to a cradle to grave approach that involved the entire supply chain.

He said that SEPA officials had visited all major waste companies in Scotland and were now targeting smaller facilities, which gives the organisation the ability to map out where waste is moving and where problems are arising.

This involved 150 materials recycling facility inspections, 25 waste broker audits, 20 council audits and the inspection of more than one hundred containers of paper, plastic and cardboard at sites and ports.

From this seven cases were referred to the Procurator Fiscal, three enforcement notices were issues, as were several final warning letters.

Currently, there are two ongoing investigations into illegal waste exports.

However, he said that 75 containers had been let go by inspectors and all of “had some level of contamination”.

He added that on assessing contamination, SEPA uses the following criteria:

  • Assess container on cases by cases basis including the quantity and type of contamination
  • Target worst cases for enforcement action
  • SEPA has never applied zero tolerance but uses same approach as other UK authorities
  • With most material exported to China, it applies its 1.5% contamination limit for paper and a lower tolerance for plastic to material that is sent there
  • With contracts specifying 2% contamination and listing prohibited wastes, this will also be seen as a guide as whether the material met the contracted contamination specification
  • It also wants to see that the material has been processed sufficiently prior to export to reduce the contamination levels.


In his presentation, he also gave examples where low levels of contamination had been allowed including small pieces of wood, calcium sulphate powder or plastic film in cardboard bales. But where SEPA had found kitchen sinks, wooden pallets or a guitar, this suggested the material had not been processed sufficiently and was therefore considered not fit for export.

Many of the exporters in the room wanted SEPA (and the other UK regulatory environment agencies) to set a contamination target for dry mixed recyclable materials and to have zero tolerance for items such as nappies, food waste, WEEE and other materials that do not appear on the allowed green list of materials.

But Colin Morrow rejected this idea. He said: “There is no prescribed limit in EU regulations and there is no consistency with other UK/majority EU/non-EU countries. Different countries have different percentages.

“If we did have a limit on contamination, it might not dovetail with other countries.”

Prior to the presentation from Colin Morrow, The Recycling Association chief executive Simon Ellin (pictured) said that the EN643 standard for recovered paper covers every paper grade and allows for an out-throw of 1.5% and this is used by UK recyclers and mils across Europe.

Therefore, he suggested this standard could be adopted for paper exports.

He added: “We know of companies that are exporting from Scotland out of England to avoid the regulation there.

“We want producers and regulators to work together and we can’t get away from the fact that quality has to be top of the agenda…

“… There needs to a sensible, pragmatic and consistent approach, with the resources of the enforcement agencies concentrated on hardened criminals.”