**UPDATE 30/06/25 – Following discussions with the WRA, the Environment Agency updated RPS 352 on 26/06/25 to include sites which are impacted indirectly by unplanned downtime at biomass plants – more details here. The WRA continues to work with the EA to ensure the RPS is not restrictive and reflects the operational realities of the waste wood sector – including calling for the inclusion of sites which supply the panel board industry.**
The Wood Recyclers’ Association has today (June 18th) welcomed ‘in principle’ the launch of a Regulatory Position Statement (RPS) allowing sites in England to temporarily exceed their permitted storage limits for certain wastes.
The Environment Agency launched RPS 352 this week in response to calls from the WRA and the wider waste industry for more flexible storage due to the current issues with the offtake for certain waste streams, including waste wood.
In the waste wood market, this has included a number of scheduled and unscheduled shut downs at plants processing waste wood, including biomass plants and panel board manufacturers, alongside a fall in demand from the export market – resulting in an abundance of material.
However, the WRA is working with the Agency to address a number of concerns over the RPS in its current form to ensure it is not overly restrictive.
Firstly, the RPS applies only to ‘waste wood destined for incineration’, in addition to refuse derived fuel and municipal solid waste.
This excludes wood recycling sites who supply the panel board industry– despite these sites also being impacted by the current abundance of waste wood in the market, the closure of one UK panel board manufacturing site and lower than usual demand for panel board due to the current economic situation.
Alastair Kerr, Director General of the Wood Panel Industries Federation (WPIF), commented: “The current wording in RPS 352 is restricted to those who are storing material for further transit to incineration. However, it must be broadened to include wood stored that is intended for panel board production.
“The panel board sector provides relatively stable demand throughout the year whereas bioenergy demand can fluctuate. The current market difficulties are putting pressure on all those storing wood for onward distribution and some of those sites are only handling material for panel board consumption, therefore, to limit the RPS to only incineration, would not resolve the current problem that is impacting on all sites storing waste wood for onward distribution regardless of end market.”
Furthermore, the RPS’s restrictions on the time allowed for extra storage do not take into account how long biomass plants stop taking material during shutdowns – which can start three months before and continue three months after, or more for unplanned outages.
In addition, sites must show that their destination plants have ceased operating, which is not necessarily the case as many have just severely reduced their inbound tonnages. Plus, most wood processors do not have a direct agreement with the plants they feed into, as the supply chain is very complex and managed by much larger players at a national level in many cases.
Vicki Hughes, Technical Lead on the WRA Board, said: “We welcome this RPS in principle which is something the WRA has been calling for to help our members navigate the current market conditions and ensure no material is sent to landfill.
“However, in order for this to alleviate the current pressure on the market as intended, it is critical that the RPS is not too restrictive and takes into consideration how the waste wood sector operates.
“We look forward to working with the Environment Agency to resolve these concerns and ensure that the RPS can achieve what it was intended to.”