In December 2024, the Environment Agency consolidated several longstanding standard rules permits into updated versions. While this consolidation modernises and streamlines the permitting framework, it also introduced new technical competence requirements for many operators.
To support a smooth transition, the Environment Agency has issued a Regulatory Position Statement (RPS) allowing operators extra time to obtain any additional WAMITAB qualifications required by the new consolidated permits.
Why Has an RPS Been Issued?
When the following standard rules permits were consolidated on 18 December 2024, some operators suddenly found themselves needing additional technical competence qualifications:
- SR2008 No 11 and SR2009 No 6 > consolidated into SR2022 No 1
Treatment of waste to produce soil, soil substitutes and aggregate
- SR2008 No 3, No 4, No 8, and SR2015 No 6 > consolidated into SR2022 No 4
Nonhazardous waste recycling with asbestos, hazardous batteries, cable and WEEE storage
- SR2008 No 1, No 2, No 6, and SR2015 No 4, No 5 > consolidated into SR2022 No 5
Nonhazardous waste transfer with asbestos, hazardous batteries, cable and WEEE storage
- SR2008 No 12 and SR2015 No 19 > consolidated into SR2022 No 6
Household waste recycling centre
Recognising that gaining new CIWM (WAMITAB) technical competence qualifications takes time, the Environment Agency issued an RPS providing a transitional period for compliance.
What Does the RPS Allow?
The RPS gives operators until 31 December 2026 to obtain any additional WAMITAB qualifications needed as a direct result of the permit consolidation.
This does not remove the competence requirements -it simply delays enforcement to allow operators to update their qualifications without risk of breach.
Who Can Use This RPS?
You can rely on this RPS only if all three conditions apply:
- 1. You hold a permit that was consolidated
Your existing permit must be one of those listed above and now replaced by SR2022 No 1, 4, 5, or 6.
- 2. You already hold the primary competence qualification for your original permit
You must have the correct primary competence qualification and have passed the relevant continuing competence assessment for the original (preconsolidation) standard rules.
- 3. You commit to obtaining additional WAMITAB qualifications by 31 December 2026
You must apply for and achieve the additional qualifications required under the new consolidated permit.
Important: This RPS Will Not Be Extended
The Environment Agency has made it clear that the RPS expires on 31 December 2026 and will not be extended beyond this date. After this deadline, operators must have:
- all required WAMITAB qualifications
- evidence of continuing competence
- full compliance with the updated standard rules
Failure to comply after the expiry date may lead to enforcement action.
What Should Operators Do Now?
Here’s a recommended action plan which Albion can help you follow.
- Review your new consolidated permit (SR2022 No 1, 4, 5, or 6).
- Identify any additional technical competence modules now required.
- Book your CIWM(WAMITAB) qualification and assessments early – avoiding, availability issues, or delays.
- Keep documentation showing you held the correct qualifications for your original permit.
- Record evidence of progress toward obtaining the additional qualifications.
The consolidation of standard rules permits is a positive step toward a clearer regulatory framework, but it does place new obligations on many waste sector operators. The RPS offers breathing space – but only for a limited time.
By acting now, operators can ensure they remain compliant, avoid regulatory risk, and continue operating smoothly under the updated rules.