Climate News Greenspace Demo - Climate Space Greenspace Climate Update: July 2025


Welcome to the Climate News Greenspace Demo - Climate Space Greenspace Climate Update: July 2025 monthly email as part of your subscription to Waterman's Greenspace platform. The monthly updates show any:

  • new legal entries added to your register;
  • amendments to legal entries in your register; and
  • legal entries removed from your legal register.

It also contains links to new publications from Government and regulatory bodies and examples of relevant offences, highlighting how legislation is implemented and enforced in practice.
As well as receiving this update by email you will also find it saved on your Greenspace site under the Legal Register > Monthly Updates tab at the top of your Greenspace page.


 
 
 
 
 

 
Pertinent Legislation Amended in July 2025
 
 
CLIMATE CHANGE LEVY (GENERAL) REGULATIONS 2001, AS AMENDED
 
 
 
 
 

The Climate Change Agreements (Administration and Eligible Facilities) (Amendment) Regulations 2025 will amend the Climate Change Agreements (Administration) Regulations 2012 and Climate Change Agreements (Eligible Facilities) Regulations 2012 on 1 January 2026.

This legislation will apply across the UK.

What will change?

Holders of climate change agreements receive a discount against the climate change levy in return for binding energy or emissions reduction targets. These reduction targets are applied across a series of target periods and buy-outs are required for operators who do not meet the targets set.

Amendments to the Climate Change Agreements (Administration) Regulations 2012

Amendments add three further target periods for climate change agreement holders:

  • Target period 7: 1 January 2026 to 31 December 2026;
  • Target period 8: 1 January 2027 to 31 December 2028; and
  • Target period 9: 1 January 2029 to 31 December 2030.

During these periods, the targets may only apply to each facility rather than ‘target units’, which allowed the targets to be applied to multiple facilities. Targets have yet to be set for these new periods.

A buy-out formula is set for target periods 7 through 9, which determine fee payable for exceeding targets under the agreement. These fees reflect the rates of climate change levy applicable. This will increase the buy-out cost.

Updated requirements will apply to agreements on the submission of performance data during each target period.

Amendments to the Climate Change Agreements (Eligible Facilities) Regulations 2012

Climate change agreement holders will continue to receive the discounted rate of the levy until 31 March 2033.

Climate change agreement eligibility rules concerning primary energy use will be updated. A lower multiplication factor will be applied for electricity supplied to facilities from 2026. This factor is intended to reflect the greening of the grid and increased efficiency of generation, transmission and distribution.

Rules and the formula concerning electricity generated by Combined Heat and Power (CHP) plants will also be updated. This is intended to reflect the use of renewable and non-renewable fuels and verifying that exported electricity to the grid is only counted when the respective CHP Quality Assurance (CHPQA) standards are met.

 
 
 
 
 
Recent Publications
 
 

New publications this month:

DEPARTMENT FOR ENVIRONMENT, FOOD AND RURAL AFFAIRS (DEFRA)

Defra: digital waste tracking

Webinars and a policy paper published provide further information on the forthcoming introduction of mandatory digital waste tracking across the UK. Defra has confirmed that the system will be introduced across two phases, with the first phase concerning ‘waste receivers’ (permitted or licensed waste management facilities) only.

Legislation applying requirements for phase one is expected in April 2026.

The previous stated objective to have full ‘cradle to grave’ tracking of waste is not reportedly possible at this time, although Defra may deliver this through modelling in the future.

A process flow plan for the planned system and storyboard are also available for the service.

Phase one, October 2026: Waste receivers

The mandatory digital waste tracking system will operate through an online portal with application programming interface (API) functionality allowing waste receivers to connect any existing waste databases to the system.

A private beta of the system will operate between Autumn 2025 and April 2026, with a public beta in April 2026. Waste receivers are expected to put suitable systems in place between April and October 2026 to interface with the system. Waste receivers will need to input data on waste received to the waste tracking system from October 2026, whether directly on the portal or via the API.

An anticipated service charge of around £20 a year will be applied to waste receivers.

As the requirements under phase one will not apply to waste producers, carriers, brokers or dealers, waste transfer notes, hazardous waste consignment notes and consignee returns will remain in use.

Requirements in phase one are not expected to apply to waste exemption holders, due to the diversity and complexity of their operations. Planned reforms to waste exemptions are expected to include enhanced data recording processes, preparing for the inclusion of exemptions in digital tracking.

Additionally, phase one requirements will not be mandatory for household waste recycling centre operators.

Phase two, April 2027: Waste producers, carriers, brokers and dealers

Defra has confirmed that waste tracking requirements are not expected to apply to waste producers, carriers, brokers or dealers until April 2027 at the earliest.

Phase two would include the removal and replacement of waste transfer note, hazardous waste consignment note and consignee return requirements, which will require amendments to UK legislation. These documents would be replaced through the use of the waste tracking portal, with unique waste tracking IDs for each waste movement. Data on waste are intended to be as close to real time as possible.

Producers would not enter waste tracking information into the system, with carriers fulfilling this role.

Enforcement

Defra has stated that the waste tracking system will be enforced via warnings, civil sanctions and prosecutions.

Opportunities for engagement

 

Reforming the waste exemptions system (England and Wales)

This paper sets out plans to reform waste exemptions in England and Wales. This includes new prohibitions on the use of waste exemptions, revisions to a number of exemptions and further record keeping requirements.

Annexes to the paper detail the specific changes planned.

 

Packaging waste: apply for registration and accreditation as a reprocessor or exporter

Instructions are provided on mandatory registrations or voluntary accreditations as a reprocessor or exporter of packaging waste. This notes that due to the introduction of extended producer responsibility, reprocessors and exporters are mandated to register from 1 October 2025 (except registered charities). This registration will concern obligations from 1 January 2026. An annual charge and submission of registration details are required.

It will not be possible to accredit PRNs or PERNs unless the organisations are registered. It will be an offence to recycle or export packaging waste for recycling after 1 January 2026 without being registered.

 

The Environmental Protection (Wet Wipes Containing Plastic) (England) Regulations 2025 draft SI

Draft regulations have been published that would ban the sale and supply of wet wipes containing plastic in England.

 

Environmental Improvement Plan: annual progress report 2024 to 2025

An update is provided on progress against the goals set in the 2023 Environmental Improvement Plan (EIP23).

 

National Policy Statement: water resources infrastructure

Policies are set out for nationally significant infrastructure projects for water resources in England.

 

DEFRA AND ENVIRONMENT AGENCY

Best available techniques: environmental permits

Where particular processes are not covered by Best Available Technique (BAT) guidance, UK regulators have agreed cross-cutting BAT conclusions interpretation guidance you can use. This information is available on request from the regulator.

 

Part B activities: combustion and incineration permits

Further guidance provided concerns combustion plant that burns waste biomass, enabling operators to determine whether a Part B permit or medium combustion plant permit is required.

 

Medium combustion plant: when you need a permit

This guidance now reflects the new regulatory position statement RPS 337 (Using drop-in fuels in combustion plant instead of gas oil), confirms that medium combustion plant controls do not apply to medium combustion plant in gas or oil refineries firing on commercial fuels exclusively.

 

Medium combustion plant (MCP): comply with emission limit values

Information is now included on how emissions limit values (ELVs) will be set for new fuels. ELVs where fuels are not natural gas, gas oil or solid biomass will be set in line with the New Fuels Direction. These ELVs can be used for the following new fuels: landfill gas, hydrogen, and hydrotreated vegetable oil (HVO).

 

Medium combustion plant: apply for an environmental permit

Further guidance is provided for installations where medium combustion plant operations are a directly-associated activity under an environmental permit for industrial emissions activities.

 

ENVIRONMENT AGENCY

Waste Exemptions

Waste exemption charges (England)

As of 1 July 2025, charges now apply to the registration of waste exemptions by most businesses in England.

A £56 registration charge applies to each registration. A band-specific compliance charge is charged for each exemption registered, reflecting the band the exemption is in. Discounts apply where multiple exemptions in the upper band, band 1 or band 2 are registered:

  • Upper band – £1,236 (this band applies to T8, T9 and U16 exemptions only);
  • Band 1 – £420;
  • Band 2 – £212; and
  • Band 3 – £30.

Where an existing exemption is held, the charge will apply when it expires and needs to be registered again.

 

Choosing the right waste exemptions for your activity

Guidance is provided on selecting an appropriate exemption(s) for the planned waste management activities. This guidance also communicates activities that do not require an exemption.

Charges do not apply to the three Non-Waste Framework Directive (NWFD) exemptions:

 

Waste Exemptions: Registration rules and guidance

This new guidance is targeted towards registrants of waste exemptions.

 

T6: treating waste wood and plant matter

This exemption now reflects when a T6 exemption is not needed for land management, such as shredding twigs from tree surgery or clearing and shredding ground cover like brambles.

 

MCERTS guidance

MCERTS: performance standard for organisations undertaking sampling and chemical testing of water

Requirements within this performance standard have been updated. This includes the addition of requirements for urons/carbamates.

 

MCERTS: performance standard for long-term samplers of carbon dioxide

This performance standard has been updated to remove an error.

 

Other New or Updated Environment Agency Guidance from July 2025

Environment Agency fees and charges

Fees charged across a range of regimes have been updated.

 

Nature-based solutions: Environment Agency position statement

This statement describes the regulator’s support for and approach to nature-based solutions (NbS) for flood, climate and nature recovery.

 

Waste: export and import

Further information is provided on waste transiting the UK under notification controls, including associated consent and financial guarantee limitations.

 

Air emissions risk assessment for your environmental permit

This guidance has been updated to address errors in the units used.

 

Protect groundwater and prevent groundwater pollution

Information on Safeguard zones (SgZs) has been updated within this document.

 

SR2024 No 1: research and development at a Part A(1) installation

This standard rules permit has been updated to correct an error.

 

Environmental permits: when and how you are charged

Fees associated with radioactive substances have been updated.

 

Regulatory Position Statements (RPSs)

The following RPSs were published or updated during July 2025:

 

DEFRA, SCOTTISH GOVERNMENT AND WELSH GOVERNMENT

UK REACH: rationale for priorities 2025 to 2026

The rationale for prioritising substances for regulatory action under UK REACH in the 2025 to 2026 financial year is set out. Notably, this includes:

  • An HSE consultation on proposals for UK REACH restriction on per- and polyfluoroalkyl substances (PFAS) in fire-fighting foams.
  • Further review and granting of specific authorisations, where appropriate.
  • The review, consideration and recommendation of additions to the candidate list of Substances of Very High Concern (SVHCs), as per the statutory obligation to do so every two years.

 

DEPARTMENT FOR ENERGY SECURITY AND NET ZERO AND DEFRA

Actions to jointly address climate change and biodiversity loss in England

This report collects action being taken to tackle biodiversity loss and climate change in England.

 

DEPARTMENT FOR ENERGY SECURITY AND NET ZERO

Onshore wind strategy

This strategy collects over 40 actions the government is taking to support the expansion of onshore wind developments in the UK.

 

Clean flexibility roadmap

This roadmap sets out the government's plans to deliver a clean, flexible, consumer-focused electricity system.

 

Heat Networks Regulation

Heat networks regulation: technical standards

Links have been provided to the Heat Networks Technical Assurance Scheme (HNTAS)

 

Heat Network Technical Assurance Scheme (HNTAS): assessment procedures

Draft versions of assessment procedures supporting the HNTAS are now available.

 

Heat Network Technical Assurance Scheme (HNTAS): technical specifications

Draft technical specifications supporting the HNTAS have been published.

 

SCOTTISH GOVERNMENT

Building standards technical handbook January 2025: domestic

A minor update to this document corrects an SAP 10.2 compliance calculation for new homes connecting to a heat network.

 

SCOTTISH ENVIRONMENT PROTECTION AGENCY (SEPA)

Environmental Regulation (Scotland) Charging Scheme Amendment (No 3) 2025

This amendment to the SEPA charging scheme reflects the introduction of version 4 of the Environmental Assessment Scheme on 8 July 2025.

 

Temporary Regulatory Position Statement: 2025 Extended Producer Responsibility for Packaging (pEPR) Producer Data Requirements: Fibre-based composite material

This RPS enables the use of the forthcoming amendment to the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 on the meaning of fibre-based composite packaging and the introduction of a definition of paper and board. This RPS will be withdrawn on 31 January 2027.

 

WELSH GOVERNMENT

Deposit Return Scheme for Wales

Questions and answers are provided on the Welsh version of the deposit-return scheme for drinks containers. Diverging from elsewhere in the UK, this will include glass, although a deposit will not initially be applied on this packaging due to limited implementation timescales. Additionally, the Welsh scheme will be designed to promote reusable drinks containers. This document also addresses how differences between the Welsh scheme and the other UK scheme will be managed.

 

Air quality management: guidance for local authorities

Guidance is provided on how local authorities can meet national air quality objectives applied under the Environment (Air Quality and Soundscapes) (Wales) Act 2024. Local air quality management requirements under this Act came into force on 31 July 2025.

 

Timber Industrial Strategy

This document sets out an industrial strategy for timber in Wales. This includes the contribution timber can make towards decarbonised construction and sustainability.

 

NATURAL RESOURCES WALES

A Greener, Fairer Wales Starts Here: NRW’s Call to Our Next Senedd

These documents present a call on Wales’ next leaders to back proposals to protect rivers, lands, communities and climate for generations to come.

 

DEPARTMENT FOR ENVIRONMENT, AGRICULTURE AND RURAL AFFAIRS (DAERA)

2025 pEPR fibre-based composite material and paper or board producer data requirements

This RPS enables the use of the forthcoming amendment to the Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 on the meaning of fibre-based composite packaging and the introduction of a definition of paper and board. This RPS will be withdrawn on 31 January 2027.

 
 
 
 
 
 
 
Offences
 
 

Company responsible for polluting the Llanishen Brook and Roath Park Lake in Cardiff donates to local rivers trust

A construction, demolition, waste and remediation contractor has entered into a six-figure enforcement undertaking after its activity led to the pollution of watercourses.

On 28 September 2023 a member of the public reported foul-smelling grey water in the Llanishen Brook. Natural Resources Wales officers traced the source of the pollution to groundwork activities taking place at the former HMRC tax office site, where high-rise buildings were being prepared for demolition.

During the works, a crew operating under Erith Contractors Ltd damaged a main sewer line. This resulted in raw sewage discharging into a tributary of Llanishen Brook, eventually reaching Roath Park Lake.

Natural Resources Wales worked with Erith Contractors Ltd to ensure that the damaged sewer was repaired and the pollution contained on the same day.

Erith Contractors Ltd accepted full responsibility for the incident and committed to funding local environmental improvements through South East Wales Rivers Trust via an enforcement undertaking.

Enforcement Undertaking

An enforcement undertaking is a form of civil sanction available under the Regulatory Enforcement and Sanctions Act 2008. It allows companies to make amends for environmental offences by contributing to projects that directly benefit the environment.

Erith Contractors Ltd will donate £150,000 to the South East Wales Rivers Trust. The funds will support projects focused on the conservation and restoration of river habitats across South Wales.

 

East Midlands Airport fined for breaches to permit

East Midlands Airport Ltd has been prosecuted for allowing discharges of drainage water containing aircraft and runway de-icing fluid contrary to the company’s environmental permit.  

The airport’s environmental permit sets a maximum allowable level of Biochemical Oxygen Demand (BOD) in site drainage discharges at 15 mg/l. However, an Environment Agency investigation revealed that this limit was significantly exceeded on three separate occasions between 14 January and 4 February 2022.

Notably, this is not the first time the airport has breached its permit. Since 2006, there have been 13 separate permit breaches, resulting in 10 written warnings.

Breach

East Midlands Airport Ltd was prosecuted for three breaches of its environmental permit, contrary to Regulation 38(2) of the Environmental Permitting (England and Wales) Regulations 2016, as amended:

  • Regulation 38(2) makes it an offence to fail to comply with or to contravene an environmental permit condition.

Penalty

East Midlands Airport Ltd was fined £297,500 for each charge, totalling £892,500. The company was also ordered to pay costs of £65,687.54.

 

Arrests made in recycling fraud investigation linked to suspected money laundering

Three individuals have been arrested as part of an investigation into illegal recycling paperwork, which is commonly used by organised criminal gangs to launder money.

Two men and a woman from Bolton and Chorley were detained on suspicion of conspiracy to commit fraud and money laundering. They have since been released pending further investigation. Evidence gathered during the arrests will support ongoing enquiries and potential enforcement action.

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 require companies that produce or handle significant amounts of packaging waste, such as plastic, glass, and cardboard, to contribute to the cost of recycling and disposal.

To demonstrate compliance, eligible businesses must purchase credits, known as Packaging Recycling Notes (PRNs) or Packaging Export Recycling Notes (PERNs) from accredited waste recyclers or exporters. Each credit confirms that a specific quantity of packaging waste has been properly recycled.

Because these credits carry monetary value and can be traded, the system is vulnerable to abuse. Organised criminal groups have exploited this by forging documentation or falsely claiming recycling activity, enabling them to generate large profits or launder money under the appearance of legitimate operations.

 
 
 
 
 
 
Kenny Wintle
e: kenny.wintle@watermangroup.com

Waterman Infrastructure & Environment Ltd
2nd Floor | Cubo | 38 Carver Street | Sheffield | S1 4FS | t: 0114 2298900
Pickfords Wharf | Clink St | London | SE1 9DG, t: 0207 928 7888

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