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Commercial hazardous waste disposal
Hazardous waste is not unique to industrial plants, garages, and hospitals. All businesses in all sectors in the UK are legally required to separate, categorise, and safely dispose of any hazardous waste. Read on to learn about the common categories of hazardous waste, best practices for commercial waste collection and your statutory obligations.
Contents
Hazardous waste obligations for businesses
In the UK, all businesses and organisations that produce, handle or receive hazardous waste must ensure it is safely managed in such a way that it causes no harm or damage.
💡 It’s their duty of care and any business that is found non-compliant with regulations will be subject to hefty fines and in extreme cases, legal prosecution.
Essentially, you must not mix:
- a hazardous waste with non-hazardous waste
- a hazardous waste with a non-waste
- different types (categories) of hazardous waste with each other*
- waste oils with different characteristics*
*Doing this is possible only if stipulated on your environmental permit and in special circumstances.
What exactly you need to do depends on the type of waste, the context in which it was generated and any special local regulations.
💡 There are extra duty of care requirements whether your business is a waste producer (most businesses that generate waste), waste carrier (collect or transport waste) or consignee (recycling or disposal centres), and depending on each home country.
Sources: UK Gov guidance – hazardous waste; segregation and mixing
What is hazardous waste?
Hazardous waste is the proportion of waste that may be harmful to humans or the environment. Some classic examples include:
- asbestos
- chemicals, such as brake fluid or print toner
- batteries (overlap with WEEE)
- solvents
- nuclear waste
- pesticides and herbicides
- oils (except edible ones), such as car oil
- equipment containing ozone depleting substances, like fridges
- hazardous waste containers
- aerosol cans, paints and solvents.
- medicines and beauty products
Each of these fits in a different hazardous waste sub-category and a different portion of regulations applies to each.
Source: UK Gov Guidance – hazardous waste
Sectors that generate hazardous waste
While all businesses and organisations in the UK will generate hazardous waste in some way (e.g., batteries, fridges), there are sectors that generate it on a regular basis.
Examples include:
| Sector | Typical hazardous waste |
|---|---|
| Healthcare | Medical sharps, pharmaceuticals, chemicals |
| Construction & Demolition | Asbestos, lead-based paint, contaminated soil |
| Manufacturing & Industry | Chemicals, solvents, paints, and metal waste |
| Automotive | Oil, batteries, brake fluid, and other chemicals |
| Research & Chemical labs | Hazardous chemicals, used solvents |
| Agricultural | Pesticides, fertilizers, and veterinary medicines |
| Beauty | Hair dyes, nail polish removers |
| Electronics & Tech | Lead, mercury, and cadmium |
| Cleaning and Maintenance | Cleaning agents, disinfectants, and solvents |
Hazardous waste management workflow for businesses
Ensuring your business remains compliant with hazardous waste management regulations is as simple as following this workflow:
1. Identify hazardous waste
The first step is to know what kinds of waste are hazardous wastes. The earlier this is identified, the easier it becomes for your business down the line.
See our list of typical hazardous wastes and hazardous labelling to help you.
⚠️ It’s best to refrain from mixing hazardous waste until it has been appropriately categorised!
💡 Remember that electronics and batteries contain hazardous materials but are treated as WEEE instead (Waste Electrical and Electronic Equipment).
2. Segregate and categorise hazardous waste
This is a crucial step, as different types of hazardous wastes should NOT be mixed under any circumstance as doing so may prove dangerous and costly down the line.
This step must be done by trained personnel who can use the technical guidance to understand the different kinds of hazardous waste.
Find all the resources you need on our categorising hazardous waste section.
3. Store hazardous waste
Hazardous waste must be stored separately and safely, waiting for collection by your hazardous waste disposal provider. A waste disposal provider will provide you with the appropriate commercial waste bin to rent during your hazardous waste disposal contract.
4. Filling paperwork
Waste transfer and consignment notes are the necessary paperwork that provides your waste collection contractor and any processing facilities with all the information pertaining to your hazardous waste.
See our guidance on how to fill these here.
5. Disposal
Your specialist hazardous waste collection contractor will periodically collect your waste and inspect and sign the consignment/waste transfer notes.
Bonus: Staff training
Training on waste management for all staff and in-house waste specialists can make things much easier down the line and ensure compliance with the duty of care.
If everyone at your business is able to identify, handle and segregate hazardous waste from the get-go, it makes it significantly easier for specialists to fill in forms and avoid costly non-compliance mistakes and potential accidents.
💡 Did you know that 56% of UK businesses remain non-compliant with duty of care and related regulations? Of these, 94% are SMEs with under 250-staff (i.e. small companies!).
Categorising hazardous waste
⚠️Categorising hazardous waste is crucial because mixing between types can increase corrosiveness and dangerous properties and even ruin its recyclability or re-processing. See where this fits into a business’s workflow here.
It requires staff that has the technical know-how of your business/industrial processes. We recommend familiarising yourself with the up-to-date technical guidance that applies to England, Wales and Scotland:
- UK Technical Guidance on Waste Classification (Last update: Oct 2021)
Here are the key categories:
By chemical reaction potential:
Hazardous wastes that can react when mixed should be carefully separated. For instance, hazardous alkaline waste and acid waste must be handled and stored separately.
By removal, reduction or dilution potential:
Hazardous wastes that can remove, reduce or dilute one another should remain separate. Not doing so makes it difficult for waste contractors and processing facilities to identify them (i.e. costly and dangerous!).
By changes in recyclability or processing:
Hazardous wastes with a specific recyclability or processing potential should not be mixed with others, as it may make these options unviable.
By oil content:
Mineral oils, cooking oils, halogenated oils, brake fluids, antifreeze, washer fluids and oily waters are different categories and must not be mixed by producers or carriers collecting them.
Note that the same oil and water mixes from different sources and concentrations can be mixed together, as long as the oils are of similar composition.
Important notes:
💡 These are non-exclusive categories; each waste item will likely be in multiple categories simultaneously.
💡 Businesses who accidentally mix waste products have the duty to separate it, as long as it’s technically feasible to do so.
💡 Businesses working in residential properties are prohibited from mixing their hazardous waste with general domestic waste.
Source: UK Gov guidance – Segregation and mixing
Filling out hazardous waste consignment notes
Consignment Notes are mandatory paperwork required when moving hazardous waste within a business, from one site to another or when transferring it to your waste disposal provider.
⚠️ Consignment Notes can be used as evidence of non-compliance and the original must be stored for three years.
The consignment note that is co-signed with the contractor must include the following:
- the waste classification code
- whether it’s hazardous or POPs waste
- the type of premises or business where the waste was produced
- the name of the substance or substances
- the process that produced the waste
- a chemical and physical analysis of the waste and its components
- any special problems, requirements or knowledge related to the waste
Consignment note templates
Use these official templates to fill in your consignment notes:
- England (Environmental Agency): Template for hazardous waste consignment note and their supplementary guidance.
- Wales (Natural Resources Wales): Template for hazardous waste consignment note and their supplementary guidance.
- Scotland (SEPA): Special waste guidance and templates.
- Northern Ireland (NIEA): Guide to consigning hazardous waste
💡 There are small regulatory differences between each home nation so make sure to use the correct consignment note template (e.g. Scotland calls is Special Waste Consignment Note).
💡 You will find all pertinent details in the UK Technical Guidance on Waste Management, including the LoW (List of Waste) or EWC (European Waste Catalogue) classification codes for hazardous waste.
Sources: UK Gov guidance – Classify different types of waste, UK Gov guidance – Consignment Notes
Hazardous waste signs and labels
These are the hazard pictograms that are typically associated with hazardous materials. They come in a range of colours, typically red and white or orange and black.
💡 Some everyday products (e.g. cosmetics, medicines, AA batteries) are not normally labelled with hazard symbols, so you must always check the product data sheet.
Sources: UK Gov – Waste classification technical guidance; UK Gov – Hazardous waste classification
Hazardous Waste
Acute Toxicity
Skin Corrosion
CMR, STOT, Aspiration Hazard
Skin Irritation
Ecotoxic
Compressed Gases
Flammable
Oxidising
Explosive
Radioactive
Biohazard
Hazardous waste – FAQs
Our waste experts answer your commonly answered questions below:
Can WEEE also be hazardous waste?
Waste Electrical and Electronic Equipment (WEEE) may or may not be hazardous, so a waste item may fall into one or both categories.
For example, batteries will fall under both waste categories due to their hazardous content (like heavy metals and toxic chemicals), while keyboards, cables, wires and motherboards fall solely under WEEE.
Items that are both WEEE and hazardous waste must comply with both sets of overlapping regulations. This dual compliance ensures that all aspects of electronic waste – both its electronic nature and its potential hazardousness – are appropriately addressed.
Are POPs hazardous waste?
Yes, Persistent Organic Pollutants (POPs) are considered hazardous waste due to their significant environmental and health risks.