COTC Cover for Skip Hire & Waste Transfer Stations

Supporting Operators Affected by SR2022 and POPs‑Related Permit Changes

If you operate a skip hire or waste transfer business, your permit conditions may have changed. Have you checked whether your site is now affected?

Skip hire companies and waste transfer stations have been heavily affected by recent changes to Standard Rules permits, but many operators don’t realise their permit conditions have shifted.

Following the reclassification of POPs (Persistent Organic Pollutants), the Environment Agency has updated several SR permits to bring mixed municipal, commercial and construction waste streams into scope. Because skip hire and WTS sites routinely receive mixed loads, many operators are now working under new compliance expectations, stricter POPs handling rules, and in many cases a changed requirement for COTC cover or a different TCM qualification — often without having been directly notified.

In December 2024, many SR2008, SR2015 and other Standard Rules permits were consolidated into the new SR2022 permits.

This consolidation brought POPs‑affected waste streams into scope for the first time, meaning sites that previously did not handle “POPs‑affected waste” under their old permit conditions may now fall under the updated SR2022 requirements . Even if you were never directly notified of the change.

And there is a hard deadline operators must be aware of…

RPS 326 is the temporary allowance that lets operators continue working while they update their POPs procedures, and it expires on 31 December 2026.

After this date, the Environment Agency expects full compliance with the updated SR2022 conditions and TCM/COTC requirements.

This means many skip hire and waste transfer operators are working toward a fixed compliance deadline without realising it.

As a result, many sites are currently exposed to:

• non‑compliance
• enforcement action
• increased inspection frequency
• mandatory corrective actions

In summary, skip hire and waste transfer stations affected by SR2022 and POPs changes must ensure they have the correct COTC cover, TCM attendance, and POPs procedures in place before the 31 December 2026 RPS 326 deadline.

This page explains what has changed, which sites are in scope, and the practical steps operators must take to remain compliant.

Have You Checked Whether Your Standard Rules Permit Is Affected?

If you’re unsure whether your site is affected, we can check this for you immediately.

Call 01782 308 444, and we’ll be happy to help.

Useful Links:

• COTC cover for SR2022 POPs‑affected permits
• COTC cover for SR2022 permits
• Request an SR2022 permit review
• Contact our team

What This Page Covers

This page explains:

• Why skip hire & waste transfer stations are heavily affected by POPs
• What the Environment Agency now expects under SR2022
• When you need COTC cover
• POPs identification, segregation and storage expectations
• What operators must do now to remain compliant
• The 31 December 2026 RPS 326 deadline and how it affects your site

For full guidance on SR2022 POPs‑affected permits, see our main page:
COTC Cover for SR2022 POPs‑Affected Permits

Why Skip Hire & Waste Transfer Stations Are Most Affected

Skip hire and waste transfer stations handle a wide range of mixed municipal, commercial and construction waste streams – many of which now contain POPs‑affected materials.

Common POPs‑containing wastes at skip hire and WTS sites include:

• upholstered domestic seating (sofas, armchairs, office chairs)
• mattresses and soft furnishings
• carpets and underlay
• insulation materials
• WEEE containing flame retardants
• plastics with legacy brominated flame retardants
• demolition waste containing treated materials

Under SR2022, these materials must be identified, segregated, stored correctly, and prevented from being mixed with non‑POPs waste.

Because skip hire and WTS sites receive mixed loads, they are at higher risk of unknowingly accepting POPs‑affected waste, making them a priority sector for EA inspections.

What the Environment Agency Expects Under SR2022

Under SR2022 and updated POPs guidance, skip hire and waste transfer operators must demonstrate:

• correct identification and segregation of POPs‑affected waste
• clear procedures for handling upholstered seating and other POPs materials
• updated Fire Prevention Plan (FPP) considerations
• correct storage, containment and labelling
• evidence of staff training and POPs awareness
• updated site procedures and management system documentation
• correct TCM attendance and COTC cover for the new waste streams

The EA is now actively checking that sites have updated their procedures to reflect the new POPs requirements.

When Skip Hire & Waste Transfer Stations Need COTC Cover

Many skip hire and WTS sites now require additional COTC cover where:

• POPs‑affected waste streams are now in scope
• the site handles mixed municipal waste containing POPs
• the permit conditions have changed under SR2022
• the site previously operated under SR2008 or SR2015
• the EA has raised concerns during an inspection
• the operator has expanded waste types or volumes

In practice, most skip hire and WTS sites will need to review their COTC/TCM arrangements to ensure they meet the updated SR2022 requirements.

Our Support for Skip Hire & Waste Transfer Stations

We provide complete compliance packages tailored to skip hire companies, waste transfer stations and MRF operators, including:

• COTC cover and TCM attendance
• POPs identification and segregation procedures
• Waste acceptance checks and load inspection guidance
• Fire Prevention Plan (FPP) updates
• Management system updates for SR2022
• Staff training on POPs and waste handling
• EA inspection preparation and support
• Full permit reviews and compliance audits

Our team supports operators nationwide and can provide immediate assistance.

What Operators Must Do Now

To remain compliant under SR2022 and POPs guidance, skip hire and WTS operators should:

1. Review their permit to confirm whether SR2022 applies
2. Identify all POPs‑affected waste streams on site
3. Update waste acceptance and segregation procedures
4. Ensure correct storage and containment of POPs materials
5. Update the management system and FPP
6. Confirm correct COTC cover and TCM attendance
7. Train staff on POPs identification and handling
8. Prepare for EA inspections and evidence requests

Who This Applies To

This guidance applies to:

• skip hire companies
• waste transfer stations (WTS)
• mixed municipal waste handlers
• commercial waste operators
• construction & demolition waste processors

Need Support? We Can Help

If you’re unsure whether your site is affected, or you need immediate COTC cover, we can check this for you.

Call 01782 308 444 to find out more and check if your business is affected by permit changes.

FAQs Skip Hire & Waste Transfer Stations

Do skip hire sites need to separate POPs waste?

Yes. POPs‑affected waste must be identified, segregated and stored separately.

Do I need TCM attendance under SR2022?

Many sites do. POPs‑affected waste streams may require a different TCM qualification.

What happens if I don’t comply by 31 December 2026?

RPS 326 ends, and the EA expects full compliance. Non‑compliance may lead to enforcement action.

Can AC Environmental provide immediate COTC cover?

Yes. We support operators nationwide.

Why operators trust AC Environmental

We work across the waste and recycling sector, with deep experience in skip hire & waste transfer stations, scrap metal and ELV 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,

or request a permit check online.