On 20 March 2026, the Environment Agency (EA) launched its ‘10 Point Plan’, focused on early intervention, tighter regulation and police-style enforcement powers. The plan is backed by the government’s Waste Crime Action Plan and £45 million of government funding over the next three years, which represents a 50% increase in the EA’s enforcement budget.
This article explores the background to the EA’s 10 Point Plan, its key measures, and the likely impact on organisations operating in the waste sector.
Background
Waste crime is not new, but its frequency and sophistication have increased significantly in recent years. The EA estimates that 20% of all waste disposal may be illegally managed[1] and that around 50% of the waste industry is affected by waste crime.[2] The cost to the UK economy is estimated at £1 to £2 billion a year.[3]
Waste crime includes fly-tipping, burying or burning waste, misdescribing waste to avoid landfill tax or proper management, and operating illegal waste sites.
The waste sector has also become increasingly attractive to organised crime, as a means of laundering the proceeds from offences including drugs, firearms and trafficking.[4] Criminals may establish apparently legitimate waste businesses, operate from genuine sites and deal with genuine clients, while using the business to move illicit funds.[5] Such sites are more likely to operate without regard to regulatory and legal requirements.
The waste sector has traditionally been attractive to criminals because of the financial rewards, low detection and prosecution rates and relatively light penalties. Paper-based waste tracking systems have also been vulnerable to fraud and error, enabling criminals to manipulate the audit trail for waste processing, disposal and export.[6]
Despite the scale of the problem, only 11% of respondents to the 2025 National Waste Crime Survey considered the EA effective at deterring waste crime. By contrast, 60% considered it fairly or very ineffective.[7]
It is against this backdrop that the EA introduced its 10 Point Plan; the EA has adapted and expanded its approach to address the scale of the problem.
The EA’s 10 Point Plan[8]
According to EA chief executive Philip Duffy, the plan marks a shift towards a “relentless focus on where this waste [dumped on illegal sites] is coming from and who in the system is diverting their waste”.
-
- Faster intelligence handling and a more consistent response
The EA recognises that it cannot tackle waste crime alone and that public reporting is critical.
In 2025, it estimated that only 27% of waste crime was reported.[9] To increase reporting, the EA has partnered with Crimestoppers, which allows the public to report crime anonymously.[10] The partnership aims to raise awareness, encourage reporting and build intelligence for the EA.
The EA and Crimestoppers have also launched a national radio and social media campaign.[11]
-
- Earlier intervention on larger sites
The EA intends to increase on-the-ground enforcement, intervening earlier where illegal activity is identified and prioritising larger sites where the potential harm is greatest.
It will also expand its use of restriction notices under section 109A of the Environment Act 1995. These allow the EA to stop illegal or dangerous waste activities immediately and without warning. An initial restriction lasts 72 hours, but the EA can apply to the court for a restriction order lasting up to six months.
Ignoring a restriction notice can result in forced site closure, criminal prosecution, an unlimited fine and imprisonment of up to 51 weeks.
-
- A new unit to improve national understanding of waste crime
The EA is creating an Operational Waste Intelligence and Analysis Unit (OWIA Unit) to identify and locate waste criminals using tools including aerial surveillance.
This includes a 33-strong “drone squad” equipped with laser mapping and light detection and ranging (LIDAR) technology. LIDAR can create detailed 3D maps and identify elevation changes associated with hidden waste.[12]
The OWIA Unit will combine satellite and drone imagery with financial, crime and other intelligence to identify suspicious activity earlier. This will include analysing Suspicious Activity Reports (SARs) for suspicious payments between companies purporting to operate in the waste sector.
-
- Greater transparency and community engagement
The EA has established an online ‘Waste Hub’ to share with the public the latest on its investigations and prosecutions, guidance on waste regulations and details of its publicity campaigns.
It also directs the public to report environmental problems, including fly-tipping and waste burning, to the EA, Crimestoppers or local authorities.
-
- Naming operators involved in illegal activity
Where the evidence supports it, the EA intends to “name and shame” details of operators whose permits have been revoked or suspended, who have been prosecuted, or who have been classed as poorly performing.
The information will be available through the Waste Hub, allowing householders and businesses to identify operators associated with illegal waste activity and report further concerns.
-
- Waste crime will put permits at risk
Waste permits allow businesses to store, treat, transport, recycle or dispose of specified waste. Operators must comply with permit conditions, including restrictions on waste codes and tonnage and requirements to maintain management systems.
Where intelligence indicates involvement in waste crime, the EA can deregister, suspend or revoke permits, potentially bringing the relevant activity to an immediate halt. Operators may also be subject to conditions, with non-compliance potentially resulting in prosecution, fines and asset seizures.[13]
The EA is also strengthening its “fit and proper” checks. Permit applicants and holders must demonstrate appropriate technical, legal and financial competence and undergo identity and criminal record checks.
Importantly, the EA will look beyond the proposed operator to associated “relevant persons”, helping to identify shadow directors seeking to evade regulatory scrutiny.
Fit and proper checks will also apply to permit transfers, allowing the EA to reject a transfer where the incoming operator does not meet the suitability or competence requirements. This represents a significant change from the previous system, under which a waste carrier, broker or dealer could register online by completing a form and paying £191.02.
The weakness of the old system was highlighted when Ann Maidment, director of the Country Land and Business Association, successfully obtained a waste carrier licence for her cow, with the application reportedly approved in under three seconds.[14]
-
- Expanded partnership working
The EA intends to strengthen its partnerships with police forces and other agencies through improved data sharing and coordinated enforcement.
Written agreements with bodies including HMRC and HM Land Registry give the EA greater access to information on matters such as waste shipments and land transfers, enabling more targeted interventions.
The Joint Unit for Waste Crime (JUWC) will also play an increasingly important role. The taskforce brings together 11 enforcement bodies, including the EA, HMRC and the National Crime Agency, to tackle serious and organised waste crime.
In the 2025/26 financial year, the JUWC delivered 111 disruptions, led 23 operations and supported a further 38.[15]
-
- Identifying sites at risk of waste dumping
To counter the risk that organised criminals might conceal ownership of land by dividing large plots into numerous small parcels,[16] the EA will work with HM Land Registry to identify suspicious transactions and, where appropriate, seek restriction or stop orders to prevent land falling into the hands of waste criminals.
-
- Acting against persistent poor performance
Currently the EA rates waste operations and regulated industrial facilities from Band A to F depending on their compliance performance with directly applicable legislation and permit conditions.[17] The rating affects annual subsistence charges, with Band F operators facing a 200% increase.
Where permitted waste sites remain in Bands D, E or F for two or more consecutive years, the EA intends to take tougher enforcement action, including suspension or revocation of permits where justified. Conversely, routine regulatory activity will be reduced at sites demonstrating consistently high performance.
-
- Closing loopholes and tightening controls
One key development is the new digital waste tracking system led by Defra.[18] It will replace paper records with a centralised online database tracking waste from origin to destination, improving transparency and traceability.
The system launched in April 2026 and it becomes mandatory for all waste receivers in England and Wales from October 2026, and in Scotland and Northern Ireland from January 2027.[19]
Once mandatory, non-compliance may result in civil penalties, formal warnings or permit revocation.
What might the 10 Point Plan mean for the sector?
Plans are only as effective as the resources behind them. The EA has received substantial government backing, including a significant increase in its enforcement budget of £45 million over three years, and wider government support by way of its Waste Crime Action Plan.[20]
The latest enforcement figures testify to the EA’s increased focus on waste crime. In March this year, the EA launched Operation Unite, an 18-week nationwide operation targeting waste sites suspected of criminal activity. Officers visited 42 sites, resulting in 17 permits being suspended or facing revocation and more than 30 new criminal investigations.[21] This is purportedly only the first phase of the operation.[22]
The EA are also sending warning signals to the waste sector. On 2 September, in an all-time first, the EA published heat maps that highlight the locations where they have received a high number of waste crime reports in 2025.[23] These are likely to be areas of intensified focus for the EA, and the EA wants this to be known.
The EA will also have increased powers to carry out its plan. In August this year, the government pledged more officers on the front line to support the EA, and an increase in fines for those who dump waste illegally or fail to treat it correctly of up to £5,000, up from the current maximum of £300.[24] The government has also asked Defra, with the support of the Home Office, to consider how powers under the Police and Criminal Evidence Act 1984, the Proceeds of Crime Act 2002, and other relevant legislation, could be expanded to the EA and its enforcement officers.[25][26]
Businesses operating in, or associated with, the waste sector should expect increased scrutiny and proactive engagement from the EA and its enforcement partners. This may cause significant problems for businesses who have unknowingly associated with operators involved in waste crime.
Businesses could face short or long term consequences as a result of these associations, such as an interim Account Freezing Order over business assets or suspension of a waste permit, whilst the authorities establish whether the business was knowingly or wilfully involved in criminality.
Now more than ever, businesses should carefully consider who they deal with, and maintain robust compliance and due diligence procedures. This should facilitate a prompt and effective response, should a regulatory enquiry be received.
This article was written by Maria Cronin, Partner and Abbie Melvin, Associate.
[1] EA National waste crime survey 2025: summary
[2] EA National waste crime survey: 2025 results and findings
[3] Written evidence from Environmental Services Association (ESA) (WCI0022)
[4] FATF REPORT Money Laundering from Environmental Crime
[5] EA Blog: How the Joint Unit for Waste Crime is dismantling organised crime in the UK waste industry
[6] Department for Environment Food & Rural Affairs consultation; Digital waste tracking: What is it and why it matters EA blog
[7] EA National waste crime survey: 2025 results and findings
[8] EA news article
[9] EA National waste crime survey: 2025 results and findings
[12] EA news article
[15] EA Joint Unit for Waste Crime (JUWC): end of year report 2025 to 2026
[16] Climate Change Committee meeting 25.03.2026 notes
[17] Waste operations and installations: assessing and scoring environmental permit compliance
[18] Digital waste tracking service
[19] Digital waste tracking service
[21] EA: Operation Unite: Nationwide crackdown marks new phase in fight against waste crime press release
[22] GOV.UK news article
[23] EA Waste crime reporting in England: heat maps for 2025 research and analysis
[24] GOV.UK news article
[26] Department for Environment Food & Rural Affairs action plan
