Can you confirm changes to the height of buildings considered high-risk buildings under the Building Safety Act 2022? 

There haven’t been any recent changes to the criteria to determine whether a building would be classified as a higher-risk building. In May 2025, updated guidance was published clarifying whether roof gardens are considered a storey (they aren’t). The latest guidance on this can be found here. 

What is the threshold for UK CBAM to apply? 

The threshold is £50,000 worth of CBAM goods being imported within the previous 12 months or where this threshold is expected to be met within the coming 30 days. The HM Treasury’s factsheet on this can be accessed here. 

How do we calculate the UK CBAM tax if only have the cost and weight of goods imported? 

If you don’t know the actual emissions data for CBAM goods you would use the Government’s default emissions values and multiply this by the weight of the goods and carbon price. The default emissions values are expected to be published in the near future, guidance can be found here. 

What information do we need to provide to EU customers when sending CBAM goods to them? 

You will need to provide information for them to determine liability to pay the correct price for importing CBAM goods, this would include information on the goods (e.g. the CN code for the goods and volume (weight)) as well as information on their origin and any carbon emissions taxes already paid on the goods. 

Does CBAM relate to construction? 

It can do, but not specifically. The goods covered by UK and EU CBAM include those that typically might be used in the construction industry, such as aluminium, cement, iron and steel. 

Do we need to use the digital waste system as a quarry bringing waste into site? 

Waste receiving site operators in Wales and England must use the digital waste system from 1st October 2026, for those in Scotland and Northern Ireland this is required from January 2027. These rules only apply to permitted sites initially, if your site is covered by a waste exemption, then requirements will only be brought in during phase 2. Guidance on this can be found here. 

Do we still need to use waste transfer and consignment notes? 

There is currently no change to the current requirement to ensure traditional waste transfer notes (non-hazardous waste) or consignment notes (hazardous waste) are used. The shift to digital waste tracking for movements of waste from October 2027 will see changes to how records for waste movements are completed. We expect additional legislation and guidance supporting the change in the coming months. 

Does the UK DRS include vending machines? 

Yes, the DRS will apply to vending machines supplying drinks in relevant single-use containers. If you’re only selling drinks via vending machines there will be exclusions from certain requirements, such as operating a return point (unless you opt-in to host one voluntarily). Guidance on the DRS can be found here. 

Can you share more information on ESOS reporting requirements? 

We recommend using the Government guidance here, which is continually updated with the latest information on qualification and reporting requirements. If you have a specific query regarding ESOS and subscribe to LUS you can submit a helpline query here. 

Are the EU’s changes in relation to goods associated with deforestation expected to be applied in Great Britain? 

DEFRA’s policy paper confirms plans to strengthen the UK Timber Regulation (EUTR) for consistency alongside EUDR, but to what extent the rules will be the same is not yet fully known. Changes to legislation are expected in 2027.  

Do suppliers of wood pallets need to comply with EUDR? 

If pallets are supplied as products, yes. If pallets are supplied as packaging with a product, then no. Pallets supplied as packaging must comply with the PPWR requirements. 

Does the update to rules in Northern Ireland for supplying acids and hexamine to members of the public impact the supply of hazardous substances for industrial use. 

The rules update the substances which are classed as Tier 2 regulated substances and which members of the public must hold a licence to buy or acquire. Professional users and businesses do not require a licence to acquire or buy Tier 2 substances. 

With ISO 9001 changing to include climate change, how does this differ from ISO14001 where it’s a more prevalent theme? 

ISO 9001 requires consideration of climate change as part of the context and planning causes, based on its potential impact on an organisation’s quality management and customer satisfaction. This differs from ISO 14001 where the focus is on reducing the organisation’s environmental impact and promotion of sustainability. The requirement to consider climate change has been included in ISO 9001 since the 2024 amendment. 

What do companies need to do to comply with PPWR? 

Manufacturers of packaging and packaged products must ensure: 

• packaging conforms with PPWR requirements via a conformity assessment procedure; 

• technical documentation is drawn up; 

• records are kept (5 years for single-use packaging and 10 years for reusable packaging); 

• packaging is correctly labelled; and 

• compliance with national extended producer responsibility (EPR) schemes in individual EU countries where products are placed on the market. 

The actual requirements and who is responsible for conformity can vary depending on how goods are supplied onto the EU market. Additional key information on PPWR can be found in our article here. 

Is there an update on when energy from waste will be covered by UK ETS? 

The expansion of the UK Emissions Trading Scheme (ETS) to include waste incineration and energy from waste (EfW) was expected from 2028, however the UK ETS Authority has recently announced this expansion to include waste will not now take place from 1st January 2028. They haven’t yet announced a revised timeline for the expansion, but updates can be found here and you can sign-up for email updates from that page. 

What checks do waste producers need to do to ensure their waste carriers comply with the new requirements? 

The duty of care for waste producers remains the same, to only hand over waste to authorised waste collectors, which means ensuring the waste collector holds the correct authorisation. For example, a waste producer must ensure that their waste carrier`s upper tier licence, expired after 22nd July 2027, is replaced with a relevant permit. 

We move waste between sites which is both ours and a customer but not for final disposal. Which of the permits would apply and what are the requirements as we are currently a Broker? 

This would depend on the exact activities conducted; however, as you seem to both transport and control waste for a customer, you will likely need a waste controller-transporter permit. 

We transport a small amount of waste we produce at our satellite sites (e.g. electricals), to the head office, where it is collected by our waste contractor. Presumably, under the new system, we will require and exemption under ‘waste produced in the course of the operator’s own business’? 

Based on the information provided, yes, you would need an exemption not a permit. Please note that in order to operate under an exemption, you must also meet the conditions in Paragraph 4A of Schedule 2. 

Would a company based in Scotland and holding a waste carrier broker registration with SEPA need to get a separate permit if it undertakes any waste-related activities in England? 

The new permitting system applies to those who conduct waste controlling and transporting activities in England, including if “their registered office and principal place of business are outside England, but they carry on waste controlling or transporting activity from any other place of business in England“. Those falling in this category will need a permit or registered exemption from the Environment Agency, to continue their activity in England after 22nd July 2027. 

How do the DRS and Waste Carriers Licences link? Are companies moving DRS containers expected to have a licence to collect or are they exempt? 

Controlling or transporting returnable DRS items would normally require those conducting the activity to get a registered exemption (not a permit). Moreover, businesses moving empty drinks containers resulted from drinks consumed within their premises to a return point are specifically excluded and don`t need an authorisation under the new permitting system. 

What type of permit is needed for manufacturers collecting unused cut-offs from customers and re-using it in the production of new goods? Also, do such producers have any obligations under the digital waste tracking system? 

Taking unused cut-offs and re-using would involve both controlling and transporting waste. As such, the activity would require a waste controller-transporter permit. If the organisation currently holds an upper-tier registration, a permit will be needed upon its expiry, after 22nd July 2027.  

Regarding the digital waste tracking, the duty to use the digital system only applies to regulated waste management facilities during Phase 1 (October 2026 in England and Wales and January 2027 in Scotland). Others, such as waste carriers, brokers, dealers, may be required to use the system from late 2027 onwards, subject to future legislation.  

Would organisations moving their own waste between different sites / offices need a permit or an exemption under the new system? 

Managing waste produced by own activities, would normally require an exemption rather than a permit, subject to the conditions in Paragraph 4A of Schedule 2. If an organisation already holds a lower tier waste carrier licence for such activities, they will have until 22nd July 2028 to register an exemption with the Environment Agency. 

Will waste transfer documentation be updated in line with the changes to waste transport activities? 

Possibly, to reflect the changes in terminology, but no change is confirmed at the moment.