All exports of Article 18 waste from England will need to be reported to the Environment Agency from 1 July 2026, under reforms that extend compliance checks originally developed for waste tyre shipments to every green list waste stream.

Exporters will be required to submit Annex VII data on a monthly basis, reporting retrospectively on the previous month’s shipments. The EA said the changes are intended to verify that waste is being correctly classified, reaching its intended destination and is being managed in an environmentally sound manner.

The reforms apply only to exports, and will not apply to imports of green list waste. Because the EA's jurisdiction covers England only, exporters shipping from Scotland, Wales or Northern Ireland will not be subject to the new requirements unless SEPA, Natural Resources Wales or NIEA adopt equivalent measures.

Evidence and compliance

Alongside monthly reporting, exporters will need to provide evidence that overseas receiving facilities are properly authorised. The EA's minimum requirements include proof of authorisation under the receiving country's law, GPS location data for the site, geotagged photographs of equipment and processing activities, a process flow chart, a valid Article 18 contract between notifier and consignee, and contact details for a named person at the facility. Additional documentation covering environmental management systems, health and safety measures and emergency plans may also be requested.

The requirements mirror those already in place for waste tyre exports, where the EA has been operating enhanced compliance checks since October 2025. In five months of enforcement on tyres alone, the agency served 48 information notices and issued 21 prohibition notices to operators who failed to respond.

That enforcement action followed the EA's discovery that waste tyres exported to India may have been reaching illegal pyrolysis facilities, in a country whose own law prohibits such imports. Roughly 89 per cent of UK waste rubber is shipped to India for recovery, according to the EA's recent international regulation blog post.

The tyre compliance programme has already exposed gaps in documentation. Of 4,189 Annex VII forms received pre-shipment since October, only 54 post-shipment returns contained the required geotagged evidence of arrival. A further 613 were non-compliant due to missing or incomplete information, and 1,172 shipments had passed their deadline with no documentation submitted at all.

Charges and digital tracking

The EA is proposing to introduce charges to fund the expanded compliance regime, but these will be subject to a public consultation and require ministerial approval. Consultation documents are expected within the coming weeks, though the reporting requirements and compliance activity will proceed regardless of the outcome of the charging consultation.

The agency has described the July 2026 changes as an interim step. Further reforms to Article 18 waste controls are planned from 2027 through Defra's mandatory digital waste tracking programme, which will require legislative change. Until that system is in place, the EA said it will rely on monthly data submissions and targeted compliance checks.