Scottish waste authorisations: EASR explained

If you manage waste in Scotland, you may now see an EASR authorisation where an older document referred to a waste management licence, a carrier registration or an exemption. You may need to check the transition guidance to understand familiar paperwork. A reference that looks old may still matter, while an activity described as exempt may need a different route.

EASR means the Environmental Authorisations (Scotland) Regulations 2018. Waste management, water and industrial activities moved into this framework on 1 November 2025. SEPA explains the change in its EASR transition guidance.

Describe the activity and identify who controls it. Then check where it happens and which conditions apply, using the documents as evidence for each question. The heading alone will not provide a complete account of the operation. The guidance below explains how to answer those questions using current SEPA information, including the transition position reviewed on 12 October 2026.

For the wider relationship between carrier registrations and site permissions, start with our registrations and permits guide. Here we concentrate on understanding the Scottish framework and the evidence that sits behind it.

What does EASR change for Scottish waste activities?

EASR provides a common authorisation framework across several environmental activities. It brings together arrangements for permission, procedures and enforcement. It does not mean every activity has the same environmental risk or that one document automatically covers every operation a business carries out. SEPA describes the framework in its overview of authorisation types.

Think about a business that transports waste, stores it at a depot and undertakes treatment at a separate site. Those are different activities to identify. A document relating to transport is not enough to explain the depot’s storage arrangements. Equally, a permission for a treatment process does not establish that an unrelated operator can undertake the same process elsewhere.

A useful practical exercise is to describe the operation without regulatory labels first. For example: “Our employees bring waste generated during repair work back to the yard, keep separate containers there, and arrange collection.” This description is more useful than “We need a waste licence”, because it identifies the movement, origin, location and storage stage.

Then compare that description with the current SEPA waste activities directory. Follow the relevant activity through to its actual rules or application requirements. Do not stop at a directory heading that sounds roughly suitable.

What are the four EASR authorisation levels?

SEPA describes four levels: General Binding Rules, notification, registration and permit. The level depends on the activity and its regulatory requirements. These are not four options that an operator can choose between solely on price or preference. The relevant activity and conditions determine the appropriate route.

In outline, a General Binding Rule authorises an activity when all its rules are met, without an application or notification. Notification is used where SEPA must be told about the activity. Registration requires an application and assessment, with standard conditions. Permits cover higher risk or non-standard activities and can contain standard and bespoke conditions. Read the official definitions before applying them to a particular operation.

For everyday interpretation, ask what evidence makes the route work. With a permit, that includes the authorisation documents and relevant changes. With a registration, it includes the granted activity and applicable standard conditions. With a GBR, it means being able to demonstrate that the real activity meets the rules, even though there is no individual approval certificate.

For a GBR activity authorised without an application, ask which specific rule applies and how the operation meets it. “We did not need to apply” leaves those questions unanswered, so keep the rule reference and the supporting explanation together.

How do General Binding Rules work for waste storage?

Temporary storage illustrates why the activity description matters. SEPA’s current storage as part of collection directory distinguishes storage at the place of production, storage at another place owned or occupied by the producer, and storage at a collection point. These have separate GBR routes.

A retailer keeping its own packaging waste where it arises is describing a different arrangement from a contractor bringing collected customers’ waste to a commercial transfer yard. Similar skips or containers do not make the activities legally identical. Establish the actual origin of the waste before deciding which rules to read.

The production storage GBR does not authorise storage at a waste recovery or disposal facility. Its scope excludes waste liquid digestate. These are explicit features of SEPA’s production storage guidance, rather than details to infer from the words “temporary storage”.

As a practical record, keep a short explanation of the activity, the relevant GBR page and evidence showing why it fits. A site sketch, container list and account of where the waste arises can make a future review much easier. These are suggested evidence tools, not a claim that every GBR requires our preferred document format.

Our separate guide to storing your own business waste works through the location and producer distinctions in more detail.

Does an EASR registration authorise a waste site?

Sometimes a registration relates to a site activity. Sometimes it relates to transporting waste or acting as a broker or dealer. The word “registration” by itself does not identify which of those you are looking at. Always read the authorised activity and place, where applicable, rather than treating the category as a universal permission.

SEPA’s waste transport and broker application guidance separates transporting other people’s waste, transporting your own waste, and broker or dealer activities. It also states that its transport application service cannot be used to apply for other EASR activities.

Imagine a business sends you a current transport registration after you ask whether its yard can accept a particular waste. The registration may be entirely genuine. The unanswered question is the yard’s activity permission. Ask for the separate basis on which the site operates, then read its scope against the proposed operation.

The reverse problem also occurs. A document for a fixed treatment site does not explain an independent haulier’s transport position. Keeping the two questions separate makes your assessment more precise without suggesting either business has done anything wrong.

For the practical supplier workflow, use how to check a waste carrier registration. For interpretation of what the evidence establishes, see what waste registration can and cannot tell you.

What happened to existing waste licences and exemptions?

The transition depends on the old authorisation category. Existing waste management licences became EASR permits on 1 November 2025 with the same conditions. Older exemptions have different routes and deadlines. Most simple exemptions requiring a new registration or permit have an application deadline of 1 November 2026; relevant complex exemptions may require action earlier if their expiry comes first. Some specified exemption categories have separate arrangements. Activities covered by a GBR moved to that route from 1 November 2025. The controlling reference is SEPA’s transition table.

Do not turn that summary into a blanket statement that every old exemption lasts until the end of October 2026. Find the actual category, the original expiry where relevant and the matching transition row. If the category is unclear, ask SEPA to confirm the applicable route before relying on the old evidence.

In your review note, identify the historic document and the transition rule that changed its position. Then compare the resulting permission with the present activity. Keeping that history alongside the current assessment helps colleagues see whether the permission still matches what happens at the site.

This approach also avoids an unhelpful demand for a freshly reissued document simply because the title uses an older regime. First establish what the transition did to the authorisation. Then identify whether any later variation, transfer or other change affects the answer.

Use waste exemption expiry and renewal to organise the dates and activity-specific transition questions. If an application is awaiting a decision, our guide to pending waste permit applications explains why the current legal basis needs to be identified separately.

Are old WML and PPC reference numbers still useful?

Yes. SEPA says authorisations issued before 1 November 2025 remain searchable under their earlier regime references, including WML for waste activities and PPC for industrial activities. Newer EASR records use EAS references. Active older carrier and broker authorisations also retain their earlier searchable numbers. See SEPA’s public register guidance.

Search using the actual number on the document before guessing a new prefix. Compare the holder, authorised place where relevant, and activity details. Record the number exactly, including any punctuation or leading characters, so another person can reproduce the search.

For a practical example, an old WML document and an EASR description of the same site need not conflict. They might represent a transitioned authorisation using its historic identifier. However, a different site address or an unexplained change of operator still needs investigation. The transition is not an explanation for every discrepancy.

Where documents are absent online, use SEPA’s route for requesting public register information. An unsuccessful document download is a reason to obtain the missing evidence. It is not sufficient grounds on its own to declare a site unauthorised, and it does not provide permission to assume its proposed activities are covered.

Can you rely on a register status of Granted?

Use the status as part of your research, alongside the actual documents. SEPA currently warns that fully or partially suspended and partially revoked authorisations can still display as Granted because of system limitations. Its guidance directs people to contact the registry to check those matters. That limitation is explained on the public register page.

This matters when a decision depends on a particular activity, area or waste stream. An authorisation may exist while a restriction affects the precise operation you want to understand. Save the relevant documents and ask a focused question if the available evidence does not settle that point.

For example, “Does authorisation X currently allow activity Y in the storage area shown on this plan?” is easier to answer than “Is this company compliant?” The first question identifies the evidence and scope. The second asks for a much broader conclusion that a single register entry cannot supply.

Avoid writing an unrestricted approval statement in your own records when you have checked only the existence of an authorisation. A more useful note explains what you checked, which operation it supported, and any outstanding restriction question.

Does a Scottish registration work in England and Wales?

SEPA’s transport guidance says to register with the agency where your primary business activity takes place, with the transport authorisation valid in Scotland, England and Wales. That is a specific cross-border transport arrangement, explained in its registration requirements.

It does not make a Scottish site’s authorisation portable. Nor does it turn a permission for one storage or treatment operation into permission to undertake a different operation across the border. When interpreting a movement, separate the transporter’s registration from the receiving site’s permission in the country where the site operates.

Also avoid translating Scottish activity descriptions directly into England and Wales tier labels. SEPA expressly includes a business’s own construction and demolition waste within its transporting your own waste route. England and Wales have their own upper and lower tier rules, covered in our tier guide.

A GB-wide business can keep one evidence worksheet with separate columns for transport, site operation and national rules. That is a practical organisational choice. It helps stop a valid answer to the transport question being copied into a box intended to explain a site’s activities.

How should you read an EASR authorisation document?

Start with a clear question about the operation. Identify the authorised person, place where applicable, activity and conditions. Then assemble the document history relevant to that question. Check for later changes before relying on the front page of an earlier document.

Read conditions as an operating envelope. Ask which wastes, quantities, processes, areas and restrictions are relevant to the work you are examining. Where a condition sends you to another document, plan or set of standard conditions, follow that reference rather than relying on a short summary supplied by someone else.

Our guide to reading a waste permit provides a structured document review. Its practical reading method is useful here, while the applicable Scottish authorisation and SEPA guidance remain the source for the Scottish requirements.

If an unfamiliar term creates uncertainty, describe the proposed activity in everyday language and ask for its regulatory meaning. A good technical question might explain where the waste originates, whether treatment occurs, what equipment is used and how long material remains. That gives the regulator or adviser something concrete to assess.

What should a useful EASR review record contain?

A practical review record should allow a colleague to understand your conclusion without recreating every search. We suggest recording the activity description, relevant authorisation route, holder, location, document references, conditions considered and the date you checked the evidence.

Add a short explanation where an older reference is being used under the transition arrangements. If a new application is needed, identify the applicable transition category and the evidence you have about its progress. Record whether an application has been made or the new authorisation has been granted, since those are different stages.

Choose a review trigger that fits the operation. Examples include a new process, different waste stream, change of location, changed operator or approaching transition deadline. These are recommended prompts for a fresh check, rather than invented statutory review intervals.

Keep the review focused on the activity you need to understand. Follow it through the relevant EASR rules and supporting evidence, and record how you reached your conclusion. That gives a colleague or customer an explanation they can check, without requiring you to assess unrelated parts of the framework.

Sources and further reading

• SEPA: EASR authorisation types.
• SEPA: Moving to the new Regulations, including transition tables.
• SEPA: Waste activities directory.
• SEPA: Storage as part of collection.
• SEPA: Temporary storage at the place of production.
• SEPA: Transporting waste or acting as a broker or dealer.
• SEPA: Public register, historic references and current status limitations.