Quick summary of the SR2022 POPs changes:
The team at AC Environmental are helping scrap metal, ELV and skip/transfer operators stay compliant after the 2024 permit changes.
- Many SR2008, SR2015, and other Standard Rules permits were consolidated into SR2022 in December 2024
- POPs‑affected waste streams were added to a large number of permits
- Sites may now be treated as handling hazardous waste, even if they were previously non-hazardous
- Operators with non‑hazardous TCM qualifications may no longer be compliant
- RPS 326 allows continued operation until 31 December 2026
- Operators must update their TMC qualifications or secure COTC cover before the deadline
If you operate a scrap metal, ELV or skip/transfer site and want to know whether your permit has changed, you can request a quick review from our team.
You can contact our team, Call 01782 308 444, and we’ll be happy to help.
Key facts about SR2022 POPs‑affected permits
- SR2022 replaced several older Standard Rules permits, including SR2008 and SR2015
- POPs‑affected waste streams were added to many permits during the 2024 consolidation
- Sites previously classed as non‑hazardous may now fall under hazardous waste controls
- Operators holding non‑hazardous TCM qualifications may no longer meet competence requirements
- RPS 326 allows continued operation until 31 December 2026
- After the deadline, operators must hold the correct hazardous TCM qualification or secure COTC cover
- Scrap metal, ELV and skip/transfer stations are the most commonly affected sectors
Key definitions for SR2022 and POPs‑affected permits
POPs (Persistent Organic Pollutants)
POPs are long‑lasting toxic chemicals that remain in the environment and do not break down easily. When POPs‑affected waste appears on a permit, the site may be treated as handling hazardous waste, which changes the TCM qualification required.
SR2022 Standard Rules Permits
SR2022 is the updated set of Standard Rules permits issued by the Environment Agency in December 2024. It consolidates several older permits (including SR2008 and SR2015) and introduces new classifications, including POPs‑affected waste streams. This means some sites previously classed as non‑hazardous may now fall under hazardous waste controls.
RPS 326
RPS 326 is the Environment Agency’s Regulatory Position Statement that allows operators to continue working under their existing non‑hazardous TCM qualification until 31 December 2026, even if their updated SR2022 permit now includes POPs‑affected waste.
TCM (Technically Competent Manager) Qualification
A TCM qualification demonstrates that an operator has the required technical competence to run a permitted waste site. When a permit includes POPs‑affected waste, the operator may need a hazardous waste TCM qualification instead of a non‑hazardous one.
COTC Cover
COTC cover provides a qualified, accredited technically competent manager to meet the site’s legal competence requirements. It is commonly used by operators whose SR2022 permit now includes POPs‑affected waste but who do not hold the required hazardous TCM qualification. It allows sites to remain compliant while operators retrain or update their competence.
What changed in the Standard Rules permits?
In December 2024, the Environment Agency consolidated a variety of older Standard Rules permits (including some of the SR2008, SR2015 and others) into new SR2022 permits. During this consolidation, many of the older permits were updated to include waste streams now classed as potentially hazardous because they contain persistent organic pollutants (POPs). These include upholstered furniture, WEEE plastics, cables, foams and mixed waste.
For many operators, these materials were never previously part of their permitted activities. But once they appear on the new consolidated SR2022 permit, the site may be treated as handling hazardous waste, even if the operator has never knowingly accepted hazardous waste before.
This is where the impact begins.
Why the SR2022 permit changes affect scrap metal, ELV and skip/transfer stations
These sectors are seeing the biggest shift. POPs‑affected materials often appear in mixed loads, end‑of‑life vehicles, skip waste and bulky items. When these were carried across into the new SR2022 permits during consolidation, the listed permit activities changed, and the technical competence qualification (TCM) required to run the site changes with it.
Many operators who have held a non‑hazardous qualification for years are now discovering that their updated permit requires a hazardous waste qualification instead. The work they have always done hasn’t changed, but the regulatory classification has.
Who is affected and what this means for operators
The POPs‑related changes affect a wide range of operators, but the impact is greatest for sites whose permits were consolidated into the new SR2022 rules. You may be affected if your updated permit now lists waste streams that contain POPs, even if you have never knowingly handled hazardous waste before.
Operators are most likely to be affected if:
- they hold one of the consolidated SR2022 permits
- their permit now includes POPs‑affected waste streams such as upholstered furniture, WEEE plastics, foams, textiles, cables or mixed waste
- their current TCM qualification is non‑hazardous
- they operate in sectors where POPs‑affected materials commonly appear in mixed loads
- they have not reviewed their permit since the December 2024 consolidation
For many operators, the day‑to‑day work on site has not changed, but the regulatory classification has. This means long‑standing, legally compliant operators may now require a hazardous qualification to continue operating under their updated SR2022 permit.
Which types of sites and operators may be affected?
- Scrap metal and ELV sites
- Skip hire and waste transfer stations
- WEEE recyclers
- Wood recyclers
- Local authorities and HWRCs
“If your permit includes POPs‑affected waste, you may now require a hazardous TCM qualification or COTC cover to remain compliant, and if you’re unsure whether your site is affected, our team can review your permit and confirm your position quickly and clearly.
How the 2026 RPS 326 deadline affects your site
To give operators time to adjust, the Environment Agency issued RPS 326, which allows sites to continue operating while they review their permit and ensure they have the correct technical competence in place. This RPS expires on 31 December 2026.
After that date:
- operating without the correct TCM qualification becomes a compliance failure
- enforcement action becomes more likely
- insurance and duty‑of‑care obligations may be affected
- operators must either retrain or secure COTC cover
The deadline will not be extended, so the sooner operators review their position, the easier it is to plan.
How to comply before the 31 December 2026 deadline
1 – Review your updated SR2022 permit
- Check the December 2024 consolidation changes to confirm whether POPs‑affected waste streams were added to your permit.
2 – Identify any POPs‑affected waste
- Look for waste codes linked to upholstered furniture, WEEE plastics, foams, textiles, cables or mixed waste that may now trigger hazardous classification.
3 – Check your current TCM qualification
- Confirm whether your existing non‑hazardous TCM qualification still meets the competence requirements for your updated permit.
4 – Choose retraining or COTC cover
- Decide whether to obtain the hazardous TCM qualification or secure COTC cover to meet the new competence requirements.
5 – Put arrangements in place before RPS 326 expires
- Ensure your competence solution is active before 31 December 2026, when RPS 326 ends and compliance becomes mandatory.
Why many operators are choosing COTC cover instead of retraining
For some operators, gaining the additional hazardous qualification is straightforward. For others, it’s not. Many tell us they don’t have the time to train, the qualification is difficult to achieve, or long‑standing staff may struggle with the assessment.
COTC cover provides a practical alternative.
AC Environmental provides qualified Technically Competent Managers (TCMs) who are formally appointed to your site to meet the Environment Agency’s technical competence requirements.
This ensures your permit remains compliant, even if your new consolidated SR2022 permit now requires a hazardous qualification. It also allows you to stay compliant, avoid retraining pressure and keep your site operating legally without disruption.
How COTC cover works
COTC cover means a qualified TCM is formally appointed to your site to provide the technical competence required under your permit. We match the qualification to your permit type, including hazardous and non‑hazardous operations.
For scrap metal, ELV and skip/transfer stations, this often means providing a hazardous‑qualified TCM to cover the updated activities introduced by the POPs‑related changes.
We also support WEEE recyclers, wood recyclers, local authorities, HWRCs, bulky waste handlers and reuse operations, but the most urgent need is currently in the metal recycling and skip/transfer sectors.
How to check whether your permit has changed
You may be affected if:
- you hold one of the consolidated SR2022 permits
- your permit now lists POPs‑affected waste streams
- your current TCM qualification is non‑hazardous
- you operate a scrap metal, ELV or skip/transfer site
- you haven’t reviewed your permit since December 2024
If you’re unsure, we can confirm your position quickly and clearly.
To review your permit or discuss your technical competence requirements, you can contact our team.
Call 01782 308 444 , request a permit check today via email info@ac-environmental.co.uk , Or contact us online.
Frequently asked questions
What are POPs and why do they matter?
- POPs (persistent organic pollutants) are chemicals that remain in the environment for extended periods and can be harmful. When waste streams containing POPs appear on a permit, the site may be treated as handling hazardous waste, which affects the TCM qualification required.
Why did the Environment Agency change the permits?
- The EA consolidated and updated several older Standard Rules permits (such as SR2008 and SR2015) into the new SR2022 permits. As part of this process, certain waste types were reclassified as potentially hazardous, which affects the technical competence required. As a result, operators handling POPs‑affected materials need to check they have the correct technical competence in place.
Do I need to retrain to keep operating?
- Not necessarily. Retraining is one option, but many operators choose COTC cover instead, especially if gaining the hazardous qualification is difficult or impractical.
What happens after the RPS expires in 2026?
- After 31 December 2026, operators must either hold the correct qualification or have COTC cover in place. Operating without the correct competence becomes a compliance failure.
Does this affect all waste sectors?
- The changes affect multiple sectors, but scrap metal, ELV and skip/transfer stations are seeing the biggest impact because POPs‑affected materials commonly appear in their waste streams.
Why operators trust AC Environmental
We work across the waste and recycling sector, with deep experience in scrap metal, ELV and skip/transfer operations. Our qualified TCMs cover hazardous and non‑hazardous activities, and we provide clear, practical guidance tailored to your permit.
Our aim is simple: to keep your site compliant, confident and operating without disruption.
About the author
David Alcock – Senior Environmental Consultant, AC Environmental
David Alcock is a senior environmental consultant specialising in waste permitting and regulatory compliance. He advises operators across the scrap metal, ELV, skip/transfer, WEEE and local authority sectors, with a focus on Standard Rules permits, POPs‑affected waste classifications and technical competence requirements. David has extensive experience helping sites interpret SR2022 permit changes, understand the impact of RPS 326 and implement practical compliance solutions such as hazardous TCM qualification pathways and COTC cover.
Website: https://ac-environmental.co.uk
Do you need help understanding your Standard Rules permit?
If your permit now includes POPs‑affected waste or you’re unsure whether your TCM qualification is still valid, our team can confirm your position quickly.
Call 01782 308 444,
Email info@ac-environmental.co.uk,