Scotland’s Landfill Ban – are we really ready?

The 2021 Biodegradable waste to landfill ban is rapidly approaching with less than 26 months before it is implemented, but is Scotland really ready?

The current industry consensus is that there is a shortfall in alternative capacity of 900,000 tonnes in the first year. It may end up being less than this once the exact definition of “biodegradable waste” is fully understood but it also may be much more than this if some of the Energy from Waste (EfW) facilities hit construction and commissioning delays. But let’s assume the shortfall is 900,000 tonnes per annum, what are the possible options for the waste industry in Scotland.

Well assuming no new capacity for EfW or compliant treatment facilities come on stream before 2021 (this will be highly unlikely as they would need to be in the construction phase by now to be ready by 2021) there are really just two options –

  • Refuse derived fuel (RDF) – produce RDF and export to mainland Europe. The total RDF exported from the UK to Europe in 2017 was 3,201 thousand tonnes. This is a slight decline in 2016 figures (3,213 thousand tonnes) and a decline in the rate of increase of RDF exports has long been predicted as more opportunities arise on the domestic energy from waste market and incinerators in Europe begin to reach capacity. Added to this is the forthcoming complications and uncertainty with BREXIT.
  • Landfill in rest of the UK – this would be the only other viable alternative.

So looking at each option in turn, what are the issues

  • Scotland’s share of the RDF market has historically been limited. It is difficult to obtain publicly available figures but estimates from RDF producers in Scotland is it is limited to a few hundred thousand tonnes of RDF per year. To meet the shortfall we will need to increase capacity by a magnitude of three or four times. Not just at the facilities where RDF is produced but also port facilities for storage prior to shipment. Also to meet this requirement would require a further 257 shipments (5 per week) of circa 3,500 tonnes per shipment.
  • Even if an increase in capacity was possible would there be viable markets, what would be the cost (Facilities in Europe would know that Scottish companies had little or no alternative) and will export of RDF even be permitted under BREXIT changes.

The more likely scenario is that waste would be exported for disposal to north of England, however similar problems would exist –

  • Can sites in north England cope with additional 900,000 tonnes per annum of waste?
  • What gate price are they likely to charge knowing full well that Scottish companies had little or no alternative?
  • Additional haulage cost probably in region of £15/25 per tonne depending on location of landfill sites
  • England and Wales landfill tax rate for first three months of 2021 will be £94.15, probably increasing to over £100/tonne from 1st April 2021. So for simply figures 900,000tonnes at £100/tonne = £90million pound landfill tax. So £90million per annum to HMRC rather than to Revenue Scotland (circa £17 cost to each person in Scotland).  

And let’s not forget about the environmental impact of shipping 900,000tonnes of waste across the country. An additional 45 thousand bulk vehicle movements per annum, working out at just under 1,000 vehicle movements per week and the associated emissions.

So in answer to the question posed – “Scotland’s Landfill Ban – are we really ready?” the simple answer is no.

The most effective , efficient, logical and sensible option would be to delay the ban until the requisite infrastructure is in place.

If the ban is not delayed, the much harder question is what can we do to comply with the landfill ban without imposing a significant economic burden on the people and businesses in Scotland?

For all your waste management requirements including Landfill and RDF contact Albion Environmental on 01292 610 428 or