Why are scrap metal and ELV sites affected by SR2022 changes?

Because the consolidation of standard rules permits brought POPs-affected waste streams into scope for many operators for the first time.

What is the deadline for compliance?

Operators must comply with SR2022 and RPS 326 requirements by 31 December 2026.

Can you check whether my site is affected?

Yes. AC Environmental can review your permit and confirm whether your site falls under the updated SR2022 requirements.

COTC Cover for Scrap Metal & ELV Sites

Q: Do scrap metal sites need COTC cover under SR2022?

Yes. Most scrap metal and ELV sites now require COTC cover due to POPs-related waste streams and updated permit conditions.

COTC cover for scrap metal and ELV sites – Supporting operators affected by SR2022 and POPs‑related permit changes.

Many Scrap Metal & ELV Operators Don’t Realise Their Permits Have Changed

The Environment Agency updated multiple Standard Rules permits to reflect the reclassification of POPs (Persistent Organic Pollutants). These materials were not included in older permits, which means many scrap metal and ELV operators are now unknowingly operating under new conditions, new compliance expectations, and in many cases, a new requirement for COTC cover or a changed TCM requirement.

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

This consolidation brought POPs‑related waste streams into scope for many operators 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 they 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 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 operators who are unaware of the permit changes may also be unaware that they are now working toward a fixed compliance deadline.

As a result, many sites are currently exposed to:

non‑compliance
enforcement action
increased inspection frequency
mandatory corrective actions

In summary, scrap metal and ELV sites 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.

Check 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:

What This Page Covers

This page explains:

Why scrap metal and ELV sites are heavily affected by POPs
What the Environment Agency now expects under SR2022
When you need COTC cover or increased TCM attendance
How AC Environmental supports scrap and ELV operators
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 Scrap Metal & ELV Sites Are Most Affected

Scrap metal and ELV (End‑of‑Life Vehicle) sites handle multiple waste streams that commonly contain POPs (Persistent Organic Pollutants), including:

Shredder residue
Upholstery and foams
Plastics from dashboards, trims and interiors
WEEE components
Electrical harnesses
Treated textiles
Legacy fire‑retardant materials

Because POPs cannot be reused, recycled or recovered, they must be:

Identified
Segregated
Stored correctly
Sent for destruction

This places scrap metal and ELV sites under increased EA scrutiny, especially under SR2022.

What the Environment Agency Expects

Under SR2022 and updated POPs guidance, scrap metal and ELV operators must demonstrate:

A competent person (COTC holder) is in control of operations
Correct POPs identification and segregation
Updated storage, labelling and containment
Evidence of staff training
Accurate waste transfer documentation
Demonstrable TCM attendance at the required frequency
Updated fire prevention and site management plans
Clear audit trails for POPs‑affected waste streams

If any of these areas are weak, the EA may require increased TCM attendance or issue improvement actions.

When Scrap Metal & ELV Sites Need COTC Cover

You may need additional COTC cover if:

Your site does not have an in‑house COTC holder
Your current TCM cannot meet the required attendance
You have received an EA inspection, warning or improvement notice
You handle POPs‑affected waste streams
You operate under some of the new SR2022 permit conditions
You are expanding, changing processes or increasing throughput
You need to meet the 31 December 2026 RPS 326 deadline

We provide immediate, short‑term, and long‑term COTC cover for scrap and ELV operators.

Our Support for Scrap Metal & ELV Operators

We provide complete compliance packages tailored to metal recycling and ELV depollution sites:

COTC Cover (Weekly, Monthly or Bespoke)

Reliable, qualified TCMs who understand scrap and ELV operations.

POPs Compliance Checks

Identifying risk materials and ensuring correct segregation and documentation.

SR2022 Permit Support

Ensuring your site meets the updated conditions and EA expectations.

Depollution & Storage Audits

Clear, practical recommendations to reduce risk and improve compliance.

Documentation & Record‑Keeping

Waste transfer notes, POPs logs, training records, storage plans and more.

EA Inspection Preparation

We prepare you for inspections and can attend on the day.

Corrective Action Plans

Clear, actionable steps to bring your site into full compliance.

What Operators Must Do Now

To remain compliant under SR2022 and POPs guidance, scrap metal and ELV operators should:

Identify all POPs‑affected waste streams
Update storage and segregation procedures
Ensure a COTC holder oversees operations
Meet the required TCM attendance frequency
Review fire prevention and site layout
Update staff training and documentation
Prepare for EA inspections and audits
Be fully compliant before the 31 December 2026 RPS 326 deadline

If you’re unsure whether your site meets the new requirements, we can assess this for you.

Who This Applies To

This guidance applies to:

Scrap metal yards
ELV depollution sites
Metal shredders
Mixed metal recyclers
WEEE dismantlers
Vehicle breakers
Metal merchants handling mixed waste streams

If your site handles any material that might contain POPs, you are in scope.

Get COTC Cover for Your SR2022 Permit

We support scrap metal and ELV operators across the UK with reliable, competent and cost‑effective COTC cover.

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.

FAQs for Scrap Metal & ELV Operators

Do scrap metal sites need COTC cover under SR2022?

Yes. Scrap metal and ELV sites handling POPs‑affected waste must demonstrate competent management, which typically requires COTC cover and TCM attendance.

How do POPs affect ELV depollution sites?

POPs are commonly found in vehicle plastics, foams, textiles and electrical components. These must be segregated and destroyed, not recycled.

What TCM attendance level does the EA expect?

Attendance depends on permit type, throughput and risk. Most scrap metal and ELV sites now require weekly attendance of up to 20% of operating hours.

What happens after 31 December 2026?

RPS 326 expires. All operators must be fully compliant with the new POPs conditions in SR2022 permits and TCM/COTC requirements. Transitional allowances end.

Can AC Environmental provide immediate COTC cover?

Yes, we support operators nationwide and can mobilise quickly.

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,

or request a permit check online.