U9: using waste to manufacture finished goods
Source: gov.uk (2025-07-01)

U9 exemption allows you to use waste in place of raw materials to manufacture a finished product.

There’s a charge for most waste exemptions

This exemption is in band 1. Read waste exemption charges (https://www.gov.uk/government/publications/waste-exemptions-how-to-choose-register-and-pay/waste-exemption-charges) to find out what the charges and charging bands are.

Types of activity you can carry out

These include using:
- boiler ash to manufacture breeze blocks
- waste textiles to manufacture carpet underlay
Types of activity you cannot carry out

You cannot use this exemption if your operation involves any activity described in part A (1) or part A (2) of part 2 of Schedule 1 of the Environmental Permitting (England and Wales) Regulations 2010 (as amended).

These are industrial scale processes which need an installations permit.

Other things you need to know

For the purposes of this exemption, ‘finished goods’ means goods that are ready for use by an end consumer without any further processing. Waste derived finished goods still need to meet the end of waste test (https://www.gov.uk/guidance/check-if-your-material-is-waste#meet-the-end-of-waste-test).

A manufacturing process should result in a product that is significantly different from the raw materials that it was made from.

Wood chip is not considered to be finished goods.

Types and quantities of waste you can use

The waste codes are listed in the List of Wastes (LoW) Regulations. You need to make sure your waste fits within the waste code and the description.

The waste must be stored in a secure location at the place where the manufacturing is carried out.

Ash, ceramics, glass, gypsum, metals must be stored at a secure location with sealed drainage.

Lion faeces, textiles, wood and bark must be stored indoors or in a secure container.

Paper and cardboard must be stored in bales, in a container or indoors.

For paper and cardboard, up to 1,000 tonnes can be stored outdoors in an enclosure designed and maintained to prevent escape of litter.

Heat treatment is not permitted for plastics and rubber.

Within the 30 tonnes limit for rubber, you must store it in piles no bigger than 10 tonnes, with a gap as a fire break between each pile.

You should not use any more waste than you need to or this will be considered as waste disposal and will not be exempt.

U9 related exemptions

T1: cleaning, washing, spraying or coating relevant waste (https://www.gov.uk/waste-exemptions-treating-waste#T1)

T2: recovering textiles (https://www.gov.uk/guidance/waste-exemption-t2-recovering-textiles)

T4: preparatory treatments such as baling, sorting, shredding (https://www.gov.uk/guidance/waste-exemption-t4-preparatory-treatments-baling-sorting-shredding-etc)

If you want to use waste without treatment for a specified purpose you could register U8: using waste for a specified purpose (https://www.gov.uk/guidance/waste-exemption-u8-using-waste-for-a-specified-purpose).

If you want to use more waste than is allowed or a type of waste which is not allowed, you will need an environmental permit.

Register a U9 exemption

You need to register this exemption (https://www.gov.uk/guidance/register-your-waste-exemptions-environmental-permits) with the Environment Agency if you meet the requirements.