On 10th September 2025, we held our Environment and Health & Safety Legal Update webinar. We reviewed the key changes in legislation from the past six months and looked at what’s on the horizon. The session ended with a live Q&A.
Our extremely popular EHS Legal Update Webinar has now taken place, but you can catch up on demand.
In this session, our expert consultants walked through the latest developments in environmental and occupational health & safety legislation, before turning to our “On the Horizon” section, providing early insight into what’s coming next.
The webinar closed with a live Q&A, where attendees put their questions directly to our panel of in-house experts.
Questions & Answers
During the webinar, we gathered your questions and have answered them below. If you’d like to know more about our Consultancy Service or the Legislation Update Service, please contact us.
Q: What equipment typically contains POPs?
Equipment that typically contains POPs include:
- upholstered furniture, where POPs are used as fire retardants;
- electrical and electronic equipment, such as
- transformers;
- circuit boards;
- capacitors
- hydraulic systems; and
- heat transfer equipment (e.g. refrigeration units, industrial cooling systems, etc).
If you are unsure if equipment or waste that you hold contains POPs, it is important to check if this is the case and then follow the associated disposal requirements.
Q: Could you send the list of the POPs mentioned earlier?
The POPs and their requirements mentioned in the Webinar are listed below.
UK
- Polychlorinated biphenyl (PCB) – In Northern Ireland, organisations must remove all equipment containing more than 0.005% PCBs, or PCB volumes greater than 0.05 dm3 by 31st December 2025.
- All compounds classed as POPs – the maximum permitted waste concentration limits for POPs are updated in Great Britain, this includes new limits added for Perfluorooctanoic acid (PFOA).
EU
- Perfluorooctanoic acid (PFOA) – the deadline for the ban on PFOA used in fire-fighting foams has been extended until 3rd December 2025.
- Perfluorooctane sulfonate (PFOS) – The maximum concentration of PFOS permitted is reduced from 3rd December 2025.
- UV-328 – The concentrations in which UV-328 is allowed is set to 100mg/kg, with increasingly strict limits coming into effect from 2027 and 2029.
Q: With regards to foam fire extinguishers, if they’ve recently been purchased in 2025 will there be a grace period to get them replaced?
PFOA is banned for use in fire extinguishers in Great Britain and will be banned in the EU from 3rd December this year. The HSE’s proposed ban on all PFAS in fire extinguishers in Great Britain includes a 5 year transition period.
Q: If I hold a certificate as an ISO 14001:2015 internal auditor can I get it upgraded to the 2026 version easily?
Transition training is normally available following a major update to an ISO standard, meaning you don’t have to complete a full internal auditor course. The length of transition training varies depending on the extent of updates made to the standard and whether you require internal or lead auditor transition training, it’s normally a 1-2 day course.
Q: Is it thought that 45001 will follow suit to the 14001 changes?
A new version of ISO 45001 is expected in 2027, with ISO 9001 expected to be updated next year. We would expect both standards to include similar changes to ISO 14001 to ensure consistency and support the implementation of an integrated management system in organisations.
Q: Similarly to the questions above, is it expected that ISO 50001 be updated in line with the changes in ISO 14001?
A full revision of ISO 50001 has not yet been announced. We’d expect this to be considered following the updates to ISO 9001 and 45001.
Q: Hi, is 14001 certification automatically transferred?
A transition period of 3 years is given to transfer to a new version of an ISO standard, this aligns to the standard 3-year re-certification cycle.
Q: Are you offering training for the transition to 14001:2026?
Please contact us directly to discuss your training needs with our wonderful customer team.
Q: Does anything change for BNG for normal developments?
The requirements of The Environment Act 2021 (Commencement No. 10) Regulations 2025 update applies only to developments on crown land. Developers must still achieve a biodiversity gain value of at least 10% for developments in England. A biodiversity gain plan must be submitted alongside the planning application demonstrating how the developer plans to meet this target.
Q: Biodiversity net gain – what happens if a development can’t achieve 10% biodiversity net gain on-site – are there offsetting options?
If developers cannot achieve all of their BNG on-site, they can deliver through a mixture of on-site and off-site. Developers can either make off-site biodiversity gains on their own land outside the development site, or buy off-site biodiversity units on the market.
If developers cannot achieve on-site or off-site BNG, they must buy statutory biodiversity credits from the government. This should be a last resort. The government will use the revenue to invest in habitat creation in England.
Q: We supply drinks across the UK, will we need to follow the scheme from 2027?
The schemes for England, Scotland, and Northern Ireland start in 2027, so for sites within these jurisdictions you will need to follow the deposit and return scheme from 2027. We are still waiting for the official start date for the Welsh deposit and return scheme, so for any Welsh sites you operate you will need to wait until the official start date is announced.
Q: What is the position is regarding the waste carriers not issuing a waste transfer note per pick up, but instead an annual waste transfer note with the weight only?
Under The Waste (England and Wales) Regulations 2011, an annual waste transfer note (season ticket) can be used instead of individual WTNs for a period of up to 12 months, where the waste holder, waste carrier, and type of waste remain unchanged. If any of these details change, a new season ticket or individual WTN must be used. A season ticket must record: the current holder of the waste, the waste carrier and the type of waste. The site where the transfers take place can also be recorded on the season ticket, if that will be the same for each transfer. If you use a season ticket for your waste transfers, you must also keep a separate document (schedule), which must include specific details for each transfer: date, time, quantity of waste and, the site where the transfer takes place (if not included on the season ticket). The season ticket and the schedule must be kept for 2 years after the last waste transfer.
Q: In relation to the DEFRA changes does the exemption of construction / demolition waste include soil wastes?
Under the DEFRA reforms to the U1 waste exemption (now renamed ‘Use of wastes to construct and maintain surfaces and barriers’), some soil wastes (such as soil stones and dredging spoil) are included, but only in line with the conditions in Annex 1.
Q: How will technical competence for the permit holders be determined?
According to the current guidance, there will be 2 routes available: workplace competence (workplace based qualification) or individual assessments. DEFRA are still working on details. A copy of the policy paper can be found here.
Q: With the waste carrier broker dealer reform, will waste carriers licences/environmental permits no longer be available via the public register?
The current guidance on the waste carrier, broker and dealer system reform makes no reference to any changes to the public registers. In this case, it seems fair to assume the new permits and exemptions will continue to be listed on the same platform. We would expect a public register to continue to be available to enable individuals and organisations to check that their waste transporters and/or controllers have the required permit.
Q: In relation to waste exemptions for local authorities collecting household waste, is there any exemptions for local authorities collecting waste from businesses?
According to the current guidelines, local authorities carrying out their statutory duty to collect household waste can operate without a permit; however, if operating collection services of commercial and industrial waste, local authorities will be required to apply for a permit.
Q: We have a compost permit, but also have a D6 exemption for other activities not relating to our compost. Does this change mean we can’t have both?
That is correct based on the current policy paper, the new rules planned will prohibit the use of waste exemptions at permitted sites. Detailed guidance can be accessed here.
Q: With the changes to the waste carriers licence to be a permitted process and the prohibition of waste exemptions at permitted sites does this mean that anyone with a carriers licence in future will not be permitted to hold exemptions?
That would depend on the permit. Each permit type will be differentiated according to the activity carried out under the permit, the scale of the operations undertaken, and type of waste carried by the permit holder, with additional tiers that take into consideration the type and volume of waste carried. The changes to waste exemptions prohibit the use of exemptions at permitted sites, so it seems fair to conclude you may still be able to hold exemptions, if the activities carried under the permit are not site specific activities.
Q: How long would an existing Waste Carriers license last for, assuming the new changes come in to force? Would they overlap or would you need a new permit as soon as they come into force?
According to the guidance, existing CBD registrations will be replaced either with ‘standard rules’ environmental permits or with exemptions, both of which will be subject to renewal every 3 years. Although specific arrangements for transition to the new system are not available yet, this will most likely be clarified in upcoming legislation.
Q: Do you know when the exemption changes policy paper will be passed into legislation?
There is currently no confirmed date for relevant legislation being published.
Q: Regarding the public register of waste carriers, how do we access this register?
The public register can be accessed at Waste Carriers, Brokers and Dealers.
Q: We’re a university and hold a waste carriers licence to enable us to transport our own waste between our own sites, will the changes affect us in any way?
The existing registrations (licences) will be replaced with a ‘standard rules’ environmental permit or a registered exemption. If you currently hold a waste carrier licence you would be required to apply for a transporter permit, unless you meet the exemption criteria listed in the policy paper here.
Q: Where can we get the updates of CBAM from please?
If you are a subscriber to LUS, we have a dedicated ‘CBAM’ profile code which you can add to your register in order to make sure that you receive updates. We also have a ‘consultations’ register where we publish consultations which you can use to view and comment on proposed changes. If you are not a subscriber, you can check the official EU CBAM website.
Q: I am very interested in learning about and understanding how CBAM works and any training available in how I can learn about this, especially when it comes into force in January 2027.
Please contact us directly to discuss your training needs with our team.
Q: Do you have any insights into when new EPC MEES requirements are likely to come in to regulation? – e.g. C by 2027, B by 2030.
There was a consultation held by the Department for Energy Security and Net Zero earlier this year which followed on from a consultation in 2020, the feedback is still being analysed. It is anticipated that the Government will publish legislation later this year. Given the Government’s overarching commitments to achieving net zero carbon, it is wise for companies / landlords to begin planning efficiency upgrades in the meantime.
Q: Are there timelines for phasing out older PPE that no longer meets the harmonised standards?
Decision (EU) 2025/895 amending Implementing Decision (EU) 2023/941 as regards the harmonised standards for hearing protectors, personal fall protection equipment, mountaineering equipment, knee protectors, protective clothing against tick bites and electrically insulating helmets is an EU piece, and the revisions to the harmonised standards apply from 16th November 2026 to allow time for manufacturers to prepare for the revised standards.
Q: Tax increases – when are the new costs to be implemented?
Vehicle excise duty tax, landfill tax, aggregates levy, and plastic packaging tax rate increases apply from 1st April 2025. The increased rates for the climate change levy apply from 1st April 2026.
Q: Do you have any information on the introduction timing for EUDR deforestation legislation?
Rules begin to apply for medium and large operators and traders on 30th December 2025, with rules for micro and small enterprises beginning to apply from 30th June 2026. The European Commission’s EUDR webpage is useful in keeping up to date with changes and upcoming important dates.
Q: Re: the DEFRA carbon in materials consultation – is there an expected date when that resultant legislation might be generated?
Following consultations, we expect a response to the feedback within 12 weeks. We cannot advise on the timing of the development and publishing of following legislation as it depends on the Parliamentary process. N.B. On the 10th September, the response deadline for the consultation ‘Growing the market for low carbon industrial products: policy framework‘ was extended to 29th September.
Q: Do you have any details on the proposed Ecocide (Scotland) Bill?
This Bill is in Stage 1 of the process to decide if it should become an Act. If passed, it would allow for people and organisations to be convicted of ‘ecocide’ which is causing severe environmental harm in a way that is intentional or reckless. Information from the Scottish Parliament can be found here. Assuming it is approved, once passed into law we will add an entry to LUS to detail the key requirements.
Q: To what extent will small businesses be required to report for under the finance and sustainability reporting in Ireland?
The European Union (Corporate Sustainability Reporting) Regulations 2025 deferred reporting requirements for listed small and medium-sized companies to 1st January 2028. The requirements for sustainability reporting are partly the same for different company sizes, with some exemptions as detailed in Part 28 of the Companies Act 2014. N.B. Non-public small and medium-sized companies are not required to undertake sustainability reporting under the Companies Act 2014.
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