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R and D codes: recovery and disposal operations

Waste recovery and disposal codes, the R and D codes, name the operation a load of waste ends up in: an R code for recovery, a D code for disposal. This page explains how they differ from the EWC code and which ones a skip yard or transfer station actually uses.

What recovery and disposal codes are

A recovery or disposal code names the operation a load of waste ends up in: an R code describes recovery, where the waste is put back to use, and a D code describes disposal, where it is got rid of. The codes come from the annexes of the waste framework legislation retained in UK law, which is why the same R and D numbers turn up on a permit, on a hazardous consignment note and in the waste tracking service.

It helps to keep two questions apart. The EWC code, the six-digit List of Waste code, answers what the waste is: mixed skip waste, soil and stones, waste wood. The R or D code answers what is done with it: burned as a fuel, recycled, used to restore land, stored before it moves on, or put into landfill. One load carries both, and they are not interchangeable.

Where the codes show up

  • On an environmental permit. A permitted site's permit names the recovery and disposal operations that site is allowed to carry out. If an operation is not on the permit, the site cannot run it.
  • On waste records and returns. Quarterly returns to an area office are built around what came in, what it was, and what happened to it, so the operation code is part of the picture even when the column headings differ by area.
  • On consignment notes for hazardous waste. The receiving site records the operation the load went into.

An example from a skip yard

A skip of mixed construction waste comes over the weighbridge. The yard does not recycle it on the spot: it is tipped, stored and sorted, which in the code list is storage pending recovery, commonly written R13. The wood goes out to be used as a fuel, the hardcore goes to a crusher, and what is left after picking goes to landfill, a disposal operation. One skip, one EWC code at the gate, and several different operation codes behind it once the load is broken up. That is why the code on your permit and the code the next site books the load under are often not the same.

Three codes on one load, and what each answers

On the paperworkWhat it namesWhere it comes from
EWC codeWhat the waste isThe List of Waste, chosen when the waste is classified
R codeThe recovery operation the waste goes intoThe recovery operations listed in the waste legislation, and your permit
D codeThe disposal operation the waste goes intoThe disposal operations listed in the waste legislation, and your permit
Carrier registration numberWho was allowed to move itThe Environment Agency's public register of carriers, brokers and dealers

Related terms

  • EWC code, or List of Waste code. The six digits that describe the waste itself. A code with an asterisk is an absolute hazardous entry and brings the consignment note rules with it.
  • Environmental permit. The authorisation that lists the operations your site may carry out, the waste types it may accept and the tonnage limits. The operations named on it are written as R and D codes.
  • Waste hierarchy. The order of preference, prevention, reuse, recycling, other recovery, then disposal. R codes sit above D codes in that order, which is why a recovery route is the one to evidence where you have it.
  • Consignment note. The record that travels with hazardous waste, separate from a transfer note, and the place the receiving site records the operation the load went into.
  • Waste transfer note. The duty of care record for non-hazardous waste moving from one holder to the next. It carries the waste description, the EWC code, the quantity, the carrier and the destination.
  • Waste carrier, broker or dealer registration. Upper or lower tier, and nothing to do with the operation codes, but it is the other number an inspector will ask for on the same visit.

If you are working out which operations your own permit allows, start with the permit itself and the EA guidance behind it, then check what the destination site tells you it did with the load. A yard can only evidence the operation it actually carried out.

Questions

Is an R or D code the same as an EWC code?

No. The EWC code says what the waste is, in six digits from the List of Waste. The R or D code says what operation the waste goes into, recovery or disposal. A load needs both, and they are recorded in different places.

Which code does a transfer station use?

Most transfer stations and skip yards sit in the storage and sorting part of the list, commonly storage pending recovery, written R13, because the waste is tipped and held before it moves on rather than recovered on site. Your own environmental permit is the authority on which operations you may carry out, so read the operations it names before you record anything else.

Does a waste transfer note need an R or D code on it?

The transfer note is built around the duty of care details: the waste description, the EWC code, the quantity, the carrier and registration number, the destination and the date. The operation code belongs to the site that carries out the operation and to its permit, which is why it appears on permits, consignment notes and returns rather than on every skip ticket.

Where is the official list of recovery and disposal codes?

The numbered lists of recovery and disposal operations come from the annexes of the waste framework legislation retained in UK law, and the Environment Agency's own guidance and your permit restate the ones that apply to your site. Use those rather than a code list copied off a forum.

Does the digital waste tracking mandate change the codes?

The codes are the long-standing operation descriptions in the legislation; what changes is that the records move from paper and spreadsheets into a digital service. Expect to be asked the same questions, what the waste was and what happened to it, in a structured form instead of in a duplicate book.

What happens if the operation recorded does not match my permit?

It is a record that says your site did something it is not authorised to do, which is the kind of mismatch an inspector picks up quickly. Check the operations on your permit, make sure your own records only describe those, and go back to the destination site if their paperwork says something different about where a load ended up.

Sources

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