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Q: With the F-gas, to comply with ISO14001 do we need to have the certificate of service suppliers on our system?

Q: We use subcontractors to supply, fit and service refrigeration units for our customers. What certificates do we need to keep for our company?

Your organisation should keep records of the name, address and certificate number of any companies and technicians used to install, service or decommission equipment. The certificates should be from an accredited organisation and retained for at least 5 years.

More information can also be found in the LUS entry “Assimilated Regulation 2015/2067, 2008/304, 2008/306, 2008/307 and 2015/2066 on training and certification requirements for personnel working with certain fluorinated greenhouse gases”.

Q: Do the F-gas regulation updates apply to the UK?

The F-gas regulations we mentioned during the webinar apply to the European Union, therefore the Republic of Ireland. These regulations do not apply to the UK.

Q: At the risk of asking a silly question, what actual certificates do persons need to work on F-gas systems?

Guidance around what certificates an individual needs to conduct different kinds of activities relating to F-gases in the UK can be found here: “Qualifications to work with F gas”. The guidance also includes a list of recognised accredited organisations who offer the training and can issue certificates. There are three levels of certificates which cover different activities.

Organisations involved with F-gases must also hold a company registration or a “REFCOM” certificate. These records must be kept for at least 5 years.

More information can also be found in the LUS entry “Assimilated Regulation 2015/2067, 2008/304, 2008/306, 2008/307 and 2015/2066 on training and certification requirements for personnel working with certain fluorinated greenhouse gases”.

Q: F-gas refilling, can I check the following are correct: Currently banned for refilling: 508B, 507A, 404A, 434A, 422A, 422D, 134A, 428A, 22. Next to be banned: 410A, 407A, 407C, 407F, 401A, 417A, 424A, 427A, 438A, 448A, 452A, 453A

Since 2020, you must not use virgin (unused) F-gases to refill existing stationary refrigeration systems when both of the following apply:

• The refrigeration system contains F-gas equivalent to 40 tonnes or more of carbon dioxide (CO2).
• The F-gas has a global warming potential above 2,500.

The most common types of F-gas this impacts are R508B, R507A, R404A, R434A, R422A, R422D, and R428A, which you have mentioned. Refilling with R22 has also been banned for a number of years due to it being an ozone-depleting substance. The other F-gas you mentioned (R134A) has a GWP of 1430, so it is not currently banned for refilling.

Please note that the above (excluding R22) can be used for refilling if it has been reclaimed (until 2030 only) or if it has been recovered and recycled from similar equipment by your business or the business which serviced your equipment (also until 2030 only).

There are currently no additional official bans planned for the use of virgin F-gases to refill existing stationary refrigeration systems. However, the UK government’s ongoing phase-down approach under the F-gas Regulations is expected to lead to further restrictions in the future. This will likely result in a continued shift toward lower-GWP alternatives and a gradual reduction in the availability of high-GWP F-gases.

Further information on banned F-gas for refilling equipment can be found here and information around banned F-gas within new equipment can be found here.

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Q: Silly question but we’re part of a packaging compliance scheme, is there anything else we need to do?

Provided you are members of a registered compliance scheme, and are providing them with the required data and fees, you should be covered in terms of your duties.

Q: I understand that for the Producer Responsibility any packaging that is used to package a product only applies to orders delivered into the UK.

That is correct, it only applies to packaging supplied in the UK and not packaging supplied overseas.

Q: Please could you confirm if the record retention period for packaging is the same under UK packaging membership schemes or just in the EU?

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 for the UK specifies that all relevant documentation must be kept for at least 7 years.

Q: What are the labelling requirements for 2025/40 on packaging & packaging waste that I need to comply with if I am not the manufacturer of packaging but sell my product within packaging?

There are duties for organisations which are ‘economic operators’ in the EU market (manufacturers, suppliers, importers, distributors, authorised representatives and fulfilment service providers) relating to labelling outlined in Regulation (EU) 2025/40 on packaging and packaging waste.

Q: Does the Packaging Regulations 2024 revoke the Packaging Regulations 2007? I work for a Toll manufacturer who had obligations under the 2007 regulations but I am trying to determine if these obligations now move to our Customer who owns the materials we handle.

The Producer Responsibility Obligations (Packaging Waste) Regulations 2007 and The Producer Responsibility Obligations (Packaging Waste) Regulations (Northern Ireland) 2007 are revoked on 1st January 2026 by The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024.

Q: Regarding the packaging thresholds, we meet the 25 tonnes criteria, however, 60% of our stock is exported so that packaging would be exempt. How would I prove that, would it be reasonable to base packaging % exported based on % of £’s coming in from export?

Packaging which is exported from the UK is exempt from The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024. A reasonable method to assess, review and monitor your status as being under the threshold would be to apportion the tonnage of packaging based on the associated monetary value. This data should be regularly assessed to ensure that if the threshold is met, you’re able to comply immediately with any relevant requirements.

Q: Only a small fraction of our business is using packaging, how do we assess the need for registering with the regulator – by revenue of the whole business or the relevant fraction which is using packaging?

Companies need only register with PackUK if they are producers of packaging (as a brand owner, packer/filler, importer, distributor, online marketplace operator, service provider, or a seller). Duties and responsibilities lie with producers of packaging only.

Q: I work for a charity, but we are a ‘large business’, do you think the waste legislation exemption will change?

If you’re referring to charities being exempt from the Packaging Extended Producer Responsibility (pEPR) obligations, the exemption applies to all charities, regardless of their size. We are not aware of any upcoming changes to this exemption.

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Q: Out of interest. My waste contractor wants me to separate waste but it’s different to how our sister organisation has been told to separate their waste. Do we still have to do it how they ask us to?

The simpler recycling legislation allows some flexibility for waste collectors, including combined collections of some recyclable streams. So, yes, the separation requirements for customers can vary amongst different waste collectors. As a minimum, general waste, food waste, and dry recyclables must be collected separate from each other.

Q: Our landlord combines all our waste (general waste/food waste and recyclables), they ensure it is separated with their waste provider when collected. Do we need to ensure we are compliant as a business, by separating the waste out before collection by the landlord? Where do we stand if we separate our waste but the landlord mixes it back together?

Under the new rules, waste collectors must update their collections so recyclable waste streams are collected separately. The main duties of organisations are to separate and present the waste for collection according to the agreement. In your situation, we’d recommend discussing this with your landlord to see if any changes will be implemented by 31st March to prevent non-compliance.

Q: How will the TEEP work?

Under the new rules, the TEEP (technically, environmentally and economically practicable) test for separate collections no longer applies. The requirement, covered in regulation 13 of The Waste (England and Wales) Regulations 2011, was removed by:

• The Separation of Waste (England) Regulations 2024; and
• The Waste Separation Requirements (Wales) Regulations 2023.

Q: Does simpler recycling apply to temporary site offices on construction sites?

Yes, it applies to all industrial or commercial waste which is similar in composition to household waste.

Q: Hi, is there any de minimis for food and glass waste collections? Our stores would produce virtually none of either of these.

We are not aware of a minimum for waste glass. In terms of food waste, de minimis in Wales is 5kg per week. However, this does not apply in England, where food waste must be collected separately regardless of the quantity produced.

Q: Our business is in Bolton and we have been informed that Bolton Council have an exemption on the food waste separation. Are there separate borough rules to the main gov guidelines?

The waste separation rules are the same, however, some waste collection authorities have been granted exemptions which allow them to delay its implementation until later dates. The full list can be found in the Schedule to The Environment Act 2021 (Commencement No. 9 and Transitional Provisions) Regulations 2024.

Q: Which external body will enforce the simpler recycling requirements and what are possible consequences for non-compliance?

Compliance with simpler recycling rules will be enforced by the Environment Agency (the EA), who can issue compliance notices to both waste collectors and businesses failing to meet their obligations.

Q: Can food waste not be disposed of with General Waste? The volumes that are generated across our premises would be so small to justify the use of 240 litre bins at each site.

Under the simpler recycling rules, food waste must be collected separately from other waste streams and must not be mixed with general waste.

Q: The Separation of Waste (England) Regs are coming in at the end of March but isn’t actually due for discussion in Parliament until April. I’ve spoken to our waste collectors and they are non-the-wiser as to what waste streams have to be segregated and how they need to be segregated. The regs affect companies with 10 or more personnel across the whole company, not single offices. Our main concern is food waste for an office of a maximum of 7 people and usual attendance of 4 people. Food waste by its very nature isn’t going to stay fresh for a month and is best disposed of immediately or at least weekly. This will end up costing companies a fortune. Is there any guidance available in these situations? We don’t want to be storing waste that is likely to go off and cause health issues but don’t want to spend a fortune on weekly collection of minor amounts of waste either.

Under the simpler recycling legislation, food waste must be separated from other waste streams. While in Wales this only applies to those producing more than 5kg of food waste per week, in England food waste must be separated regardless of the quantity produced.

Q: Can you advise more on the proposed regulation change of the stacking of shipping containers?

The proposed changes to the Welsh Fire Prevention & Mitigation Plan Guidance include an amendment to the storage of materials and containers, one of which states that shipping containers should not be stacked so that each can be accessible to extinguish a fire within. Further information can be found on page 18 of the draft updated FPMP guidance found on this consultation page.

Q: Does Simpler Recycling apply on construction sites as well? And can we broadly categorise it into food, general and dry recyclables, or do glass, metal etc. need to be different?

The simpler recycling rules are focused on specific types of waste, and not on different types of workplaces. As such, the rules apply to construction sites in relation to relevant waste (waste similar in composition to household waste). Regarding the minimum separation requirements, general waste, food waste, and dry recyclables must be collected separately from each other, but this will likely vary between different waste collection authorities or waste collectors.

Q: A High Court ruling on Monday overturned the previous classification of chicken manure as an agricultural by-product in a landmark ruling, reclassifying it as “waste” which must be disposed of in accordance with local council waste rules. Is there confirmation regarding the waste classification for chicken manure: would it fall under 02 01 06?

Animal faeces, urine, and manure fall under the 02 01 06 waste code. There has not been further guidance provided around this as of yet.

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Q: For EUDR, should we purchase newsprint for producing papers outside of Europe where the papers are distributed in the UK? Is this outside of the scope of the legislation?

The European Deforestation Regulation does not apply in Great Britain, but does apply in Northern Ireland. EUDR applies to pulp and paper products in chapters 47 and 48 of the CN lists here, so if the newsprint is supplied under one of those CN codes then EUDR would apply.

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Q: Deposit and return scheme (DRS), how will this affect vending machine products?

Drinks covered by the scheme that are sold via vending machines will need to charge the deposit amount in the same way as all retailers do, but are not required to provide return points.

Q: Will DRS machines need to be provided in the malls of shopping centres or just in individual shops?

The requirement to provide return points lies with individual grocery retailers, although retailers in urban areas with a retail space of <100m³ are exempt. There is an option that premises can offer a voluntary return point to support the scheme even if they are not legally obliged to.

Q: Can I register now as a producer for the DRS?

A scheme operator hasn’t yet been appointed for England and Northern Ireland, as such it’s not possible to pre-register. They’re expected to be appointed in April.

Q: Will online retailers be exempt from collecting containers under the new DRS?

Online retailers will not be required to offer a return point, but can register as a takeback service provider and collect empty containers at the point of delivery to refund the deposit.

Q: Do we know if there will be any exempt premises like they were discussing with the original Scottish DRS?

Exemptions have been provided in the legislation for certain premises and organisations, such as hospitality venues, educational premises and mobile caterers. Guidance on this can be found here.

Q: We have 2 small-use drinks vending equipment (less than 500 items per year). Will I need to register with the UK scheme?

The requirement to register is placed on producers (i.e. manufacturers, importers and fillers of drinks containers), rather than suppliers of drinks in containers.

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Q: Are we going to have to replace any AFFF extinguishers we have on site?

Q: AFFF extinguishers – we have several that are still “in date”. Does this mean that they cannot be left in place after 4th July this year? Or do we need to swap them all out for water? If so, the costs will be very large!

All aqueous film-forming foam (AFFF) extinguishers containing PFOA (C8) should be replaced by 4th July 2025 for suitable alternatives that do not contain banned substances.

Q: How do you know if your fire extinguishers contain PFOAs?

This will be detailed in the safety data sheet for the extinguisher. If you do not have access to this, you can check by contacting the extinguisher manufacturer.

Q: If we have AFFF extinguishers that are currently inaccessible and are unsure if they will be accessible by the time the ban is implemented, what should we do?

Steps should be taken to ensure these are not inadvertently used once banned. Once access is available, you should immediately arrange their appropriate disposal (and replacement if required).

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Q: There is some confusion over what will be covered by the CBAM scheme. It clearly shows raw materials, however, will it cover parts and goods made from raw materials such as iron, aluminium, and steel?

There is a list of products in the schedule of the Regulation (EU) 2023/956 establishing a carbon border adjustment mechanism which contains the CN codes of all the products EU CBAM applies to.

At the moment, the UK doesn’t have a definitive list of products as the scheme is currently not in force, although it is predicted to cover slightly different things.

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Q: For ETS, what do you mean by standalone scheme year? Do I have to do anything new for it?

The 2026 standalone scheme year is to be treated as an extension of the first allocation period of 2021–2025, so there are no new or additional requirements for the 2026 scheme year.

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Q: Can you give me some examples of construction products, I’m still not totally sure the kinds of things it includes?

This is in reference to Regulation (EU) 2024/3110 laying down harmonised rules for the marketing of construction products. Construction products are any items that are permanently incorporated into construction works, e.g. windows, doors, and plasterboard.

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Q: Sorry, I missed the slide about thresholds at the start, would we still count as a large organisation with over 250 employees?

This will depend on the other two thresholds. To be classified as a large organisation under the Companies Act 2006, you need to meet two out of the three criteria of a large organisation. These criteria are being updated on the 6th April 2025, with the new thresholds being:

• 250 or more employees;
• a turnover of £54 million or more; and
• a balance sheet of £27 million or more.

Having 250 employees only satisfies one of these thresholds, so you need to check if you meet either of the other thresholds before you can be sure if you are categorised as a large organisation.

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Q: If a CPC has actually expired, can we use the fast-track training to renew it?

The ‘Return to Driving’ training module is available to drivers that have had their Certificate of Competence (CPC) expire within the past 2 years. This training module allows the driver to take a 7-hour course that will allow them to drive professionally in the UK for 12 months. The driver then has the option to undertake a further 28 hours of National Driver CPC or International Driver CPC training within the 12 months to regain their full CPC.