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Preview Email
November 2025
Congratulations. There are no changes to the legislation or other requirements in your legal register.
 
Recent Publications

New publications this month:

HM TREASURY

Budget 2025

The 2025 budget took place on 26 November 2025. Key announcements relevant to environmental policy are summarised below. The supporting Finance (No. 2) Bill 2025-26 was also published on the date of the budget.

Climate Change Levy (CCL)

Rates of climate change levy for gas, electricity and solid fuels will be uprated in line with the Retail Prices Index (RPI) from 1 April 2027. The rate for LPG and rate reductions for climate change agreement holders will not change.

The carbon price support rates of climate change levy will remain at the equivalent of £18 per tonne of carbon dioxide in 2026/7.

Amendments to the Climate Change Agreement scheme from January 2026 will mean new entrants will be able to claim relief on their CCL bill before completing a target period.

A consultation response confirms that electricity used in electrolysis to produce hydrogen as well as natural gas as a source of CO2 to produce sodium bicarbonate will become subject to the CCL non-fuel use exemption. This is to be applied by implementing legislation in Spring 2026.

Landfill Tax

The standard rate of landfill tax will increase in April 2026 in line with the RPI. From April 2026, the lower rate will be increased by the cash amount of the increase on the standard rate, with the objective of maintaining the differential between the two rates.

A previous proposal to apply a single rate of landfill tax from 2030 will not go ahead. The exemption from the levy for quarries with landfill permits will also be maintained.

Plastic Packaging Tax

In 2026/7, the plastic packaging tax will increase in line with the Consumer Price Index (CPI).

The budget also confirmed a consultation in early 2026 regarding the mandatory certification of mechanically recycled plastic packaging. This certification would be required for businesses to claim an exemption from the tax.

A new policy paper concerns the application of the mass balance approach to calculate recycled content for chemically recycled plastic and the removal of pre-consumer waste.

UK Emissions Trading Scheme (UK ETS)

The budget confirms the expansion of the UK ETS to international maritime activities. The scheme is being expanded to maritime and waste activities as follows:

  • Domestic maritime activities from 1 July 2026. This will apply to ships of 5,000 GT or greater undertaking domestic voyages and emissions in ports. Government non-commercial vessels will be exempt. A temporary exemption will concern fishing vessels and vessels serving Scotland’s island and peninsula communities. Offshore ships will become part of the scheme from 1 January 2027.
  • Energy from waste and waste incineration will be subject to monitoring, reporting and verification requirements from 1 January 2026, while the full scheme will apply from 1 January 2028.
  • International maritime activities from 1 January 2028. It is proposed that the scope of ships concerned mirrors domestic maritime activities. A consultation concerns this change.

UK Carbon Border Adjustment Mechanism (CBAM)

The Budget confirms the introduction of the UK CBAM from 1 January 2027. Indirect emissions associated with imported products will be excluded from the scope of the UK CBAM until at least 2029. Indirect emissions are those from the generation of electricity consumed to produce goods, whether on-site or off-site.

End of the Energy Company Obligation (ECO) scheme

The ECO scheme will close at the end of March 2026. This scheme aims to tackle fuel poverty and reduce carbon emissions by financing improvements for low-income, fuel-poor and vulnerable households. The ECO scheme is financed through costs on medium and large energy suppliers (the Home Heating Cost Reduction Obligation or HHCRO).

Renewables Obligation (RO)

The government has announced that the domestic cost of the RO will be covered by the exchequer, rather than through domestic electricity bills, until 2028/29.

Electric Vehicle Excise Duty (eVED)

A new mileage-based charge applies to electric and plug-in hybrid cars from 1 April 2028. This will be supplementary to the existing Vehicle Excise Duty (VED) on the vehicle. Rates for the planned eVED would be:

  • 3p per mile for battery electric cars; and
  • 1.5p per mile for plug-in hybrid cars.

A consultation on eVED will run until 18 March 2026.

Plug-in hybrid electric vehicle (PHEV) emissions regulatory standard changes and Benefit in Kind easement

A temporary benefit in kind tax easement for PHEVs to prevent tax charges increasing significantly due to the revised emissions standards. These standards are being revised to better reflect real world emissions, which had previously been underestimated. The easement will run until 5 April 2028.

Warm Homes Plan

The budget announced increased funding for the Warm Homes Plan and an expanded Warm Home Discount Scheme.

Planning capacity and capability

£48 million of funding over three years was announced to improve the operation of the planning system.

Land Remediation Grant

Defra may provide public bodies with grants to remediate land where landfill tax makes this unaffordable.

Environmental regeneration: Reinvesting water company fines

£29 million of investment over two years was announced to clean up rivers, lakes and seas.

UK-EU Sanitary and Phytosanitary (UK-EU SPS) Agreement

Budget announcements included funding for Defra to support the introduction of the planned UK-EU SPS agreement, which would reduce checks on these goods.

 

HM REVENUE & CUSTOMS (HMRC)

Changes to Aggregates Levy legislation in preparation for devolution to Scotland

This document details planned changes under the Finance (No. 2) Bill 2025-26 to support the devolution of the aggregates levy to Scotland from 1 April 2026.

 

DEPARTMENT FOR ENVIRONMENT, FOOD & RURAL AFFAIRS (DEFRA) AND ENVIRONMENT AGENCY

Private beta of digital waste tracking service launched

The Digital waste tracking service policy paper has been updated to include a link to sign up for a private beta. To be eligible, your organisation must:

  • Operate one or more licensed or permitted waste receiving sites in the UK
  • Be able to work with your external software developers or internal development team so you can provide data about the waste you receive via the receipt of waste API;
  • Agree for data provided to be reviewed by regulators and policy analysts for testing purposes; and
  • be willing to provide regular feedback on your experiences of the service.

 

DEFRA

Environmental Improvement Plan 2025

The Environmental Improvement Plan has been updated. This reflects the status of the actions raised in the previous plan and adds further interim targets, which include:

  • Restoring or creating a total of 250,000 hectares of a range of wildlife-rich habitats outside of protected sites by December 2030.
  • By December 2030, doubling the number of farms providing sufficient year-round resources for farm wildlife, compared with 2025.   
  • Reducing the rate of establishment of invasive non-native species by at least 50% by December 2030, compared to 2000.  
  • By December 2030, the highest annual mean concentration of fine particulate matter (PM2.5) in the most recent full calendar year must not exceed 10 micrograms per cubic metre (µg/m3).
  • A population exposure reduction target to PM2.5 of 30% compared to 2018 to be achieved by December 2030.

Additional supporting action and delivery plans were also published, including regarding PFAS and new trees.

 

ENVIRONMENT AGENCY

Noise and vibration: environmental permit application guidance

Guidance is provided on how and when to assess noise and vibration risks in connection with environmental permit applications. The Noise Advisory Tool spreadsheet assists applicants in determining when a noise and vibration impact assessment is needed as part of a permit application or variation application.

 

Under Test (beta): New online service for permit applications in England

During November 2025, a suite of standard rule permits were updated to add a sign-up link for the Environment Agency’s new online permit application service. Persons signing up may also provide feedback on this service.

The service currently only concerns the following activities:

Car and vehicle dismantling or metal recycling, scrap metal and WEEE

  • Metal recycling - car and vehicle dismantling
  • Metal recycling - mixed metals including WEEE
  • WEEE treatment only

Medium combustion plant and specified generators

  • Stationary medium combustion plant (MCP) and specified generators (SG)

Storage or treatment of waste

  • Dredgings
  • Materials recycling facility (MRF)
  • Storage or treatment of healthcare waste
  • Storage or treatment of end-of-life(ELT) tyres
  • Storage or treatment of tyre shred and chip
  • Storage or treatment of waste mattresses
  • Storage or treatment of paper, cardboard and plastic
  • Storage or treatment of waste wood
  • Treatment of waste to produce soil, soil substitutes and aggregate
  • Use of waste to manufacture timber or construction products

Waste transfer station

  • Household, commercial and industrial (HCI) waste transfer station
  • Transfer station taking non-biodegradable wastes
  • Hazardous waste transfer station
  • Physical treatment of waste
  • Household waste recycling centre

 

ESOS Newsletter – November 2025 (Issue 41)

This ESOS update includes a reminder that Progress Update 1 is due to be notified by 5 December 2025. Details of using the MESOS system are also provided.

 

Decarbonisation readiness in environmental permit applications

Applicants for environmental permits for new or substantially refurbished in-scope electricity-generators in England will be required to submit a decarbonisation readiness report from 28 February 2026. This new document provides guidance on how decarbonisation readiness must be assessed and reported.

Qualifying in-scope generators are:

  • Installations undertaking specified activities under Part 2 of Schedule 1 to the Environmental Permitting (England and Wales) Regulations 2016:
    • Section 1.1, Part A(1) (Combustion activities); or
    • Section 5.1, Part A(1) (Incineration and co-incineration of waste).
  • Medium combustion plants used to generate electricity; or
  • Specified generators.

 

Water abstraction licences: competing proposals

A new guidance document states how the regulator will consider and administrate competing proposals to abstract water in England. The Annex states how competing proposals will be assessed.

The Apply for a water abstraction or impounding licence document has also been updated to reflect the process for completing proposals.

 

Regulatory Position Statements (RPSs)

The following RPSs were published or updated during November 2025:

  • Dewatering bentonite slurry waste in a bentonite recirculation plant: RPS 272: Updated, review date set as 30 November 2028.
  • Solidifying wet utilities excavation waste using non-waste absorbents: RPS 275: Updated, review date set as 30 November 2028.

 

DEPARTMENT FOR ENERGY SECURITY AND NET ZERO

UK Emissions Trading Scheme (UK ETS): policy overview

This policy paper now reflects the government’s response to the UK ETS free allocation and carbon leakage review consultation. This confirms that the planned changes to free allocation periods from 2027 will go ahead, while the current carbon leakage list will be maintained and tiered free allocation for sectors at carbon leakage is no longer planned. The response also confirms the planned phase out of free allocations for sectors within the scope of the UK CBAM from 2027, with the objective of phasing free allocations out entirely by 2036.

 

Draft: Heat network technical standard (TS1)

This draft standard is intended to support the Heat Network Technical Assurance Scheme (HNTAS), which aims to ensure the proper design, installation, and operation of Heat Networks.

The draft technical standard is intended to supersede the Heat Networks: Code of Practice for the UK (CP1) from 2020.

 

Marine geological carbon dioxide stores: consenting lifecycle

Technical guidance is provided on regulatory processes for the development of permanent geological marine CO2 storage in the UK exclusive economic zone.

 

National Policy Statements concerning nuclear energy generation (EN-7)

New National Policy Statements (NPSs) have been published concerning new nuclear electricity generation projects. The central NPS has also been published in draft. These set out objectives and policy for this nationally significant infrastructure and provide the framework for decision-making:

  • National Policy Statement for nuclear energy generation (EN-7): habitats regulations assessment
  • National Policy Statement for nuclear energy generation (EN-7): appraisal of sustainability
  • National Policy Statement for nuclear energy generation (EN-7): appraisal of sustainability - post adoption statement

 

MARINE MANAGEMENT ORGANISATION (MMO)

Get permission for marine work

Guidance on marine licensing obligations in English waters, Northern Ireland offshore waters and certain other parts of the world is collated within this document.

 

Marine licensing jurisdiction

This new document explains the MMO’s remit regarding licensing in English waters and Northern Ireland offshore waters.

 

Marine licensing exempted activities

This new guidance document concerns activities that may be exempt from the obligation to obtain a marine licence. Information is provided on conditions that must be met to benefit from these exemptions and how the MMO must be notified. The guidance concerns activities in England.

 

DEPARTMENT FOR BUSINESS AND TRADE

UK Critical Minerals Strategy

This strategy states a vision by 2035 to ensure the required critical minerals are available for economic growth and the clean energy transition.

 

SCOTTISH ENVIRONMENT PROTECTION AGENCY (SEPA)

Management of end-of-life smoke detectors

Updated guidance is provided on options for the management of end-of-life smoke detectors.

 

SCOTTISH GOVERNMENT

Heat in buildings: future plans

The draft Buildings (Heating and Energy Performance) and Heat Networks (Scotland) Bill has been published, alongside supporting explanatory notes. This Bill intends to support the decarbonisation of heat in buildings. It is intended that the bill will be introduced after the Scottish Election in May 2026.

 

Powering Progress Together: Scotland's offshore wind skills priorities and action plan

The 12 actions in this plan set out how skills are to be delivered to support the offshore wind sector in the next two years.

 
Offences

Two men arrested in connection to suspected packaging waste fraud

Two men from South Yorkshire have been arrested for conspiracy to commit fraud and money laundering.

In raids in November 2025, the Environment Agency worked with South Yorkshire Police to apprehend the individuals as part of an investigation into fraudulent waste exporting claims. These types of claims are often used by organised criminal gangs to launder money. A man was arrested at a property in Doncaster, while a second man, from Doncaster, was also detained.

After being interviewed, the suspects have been released on conditional bail, which includes not being able to contact each other, pending ongoing investigations. Evidence gathered during the arrests will support possible future action.

Associated Legislation

The Producer Responsibility Obligations (Packaging and Packaging Waste) Regulations 2024 require producers of waste packaging made from materials such as plastic, glass and cardboard to contribute towards the financial cost of recycling and disposing of the waste.

Obligated businesses under the producer responsibility obligations are required to purchase Packaging Recycling Notes (PRNs) and/or Packaging Export Recycling Notes (PERNs), which are obtained from waste reprocessors and exporters, respectively. PERNs have a significant monetary value, which means organised criminal gangs can look to infiltrate the sector and engage in fraud and money laundering.

 

Recycling firm fined for breaching its waste permit

A recycling firm based in Ilkeston has been fined nearly £90,000 for breaching its waste permit by failing to keep all waste within its premises.

In March 2021, the Environment Agency started monitoring sites at Hallam Fields Industrial Estate, Ilkeston following complaints about dust, odour and noise.

Officers attended land adjacent to Johnsons Aggregates and Recycling’s premises and discovered that a large amount of waste material was on the land. The waste was a type of ash which is commonly used as an aggregate in construction.

Company officials said that the land was owned by someone else and was in the early stages of being developed. They also said that waste on the land had been placed there with the landowner’s permission and for the landowner’s use.

However, the company later accepted that it had made mistakes in dealing with waste and that it had breached its permit by placing the waste on the land.

The Environment Agency subsequently issued a compliance assessment report, which required the company to operate within the installation boundary within the company’s environmental permit. However, when Environment Agency officers returned to the site on 11 May 2021, they found that large amounts of waste remained on site. Company officials said the waste had accumulated and had been more difficult to dispose of due to the COVID-19 pandemic. The company was told to remove the ash from the land by 3 January 2022.

On 4 January 2022, officers visited the land and found that the mounds of waste, though reduced in size, were still being stored and covered approximately 5 acres.

Breach

Prior to and between 22 March 2021 and 13 June 2022, Johnsons Aggregates and Recycling Ltd breached Regulation 12(1)(a) and Regulation 38(2) of the Environmental Permitting (England and Wales) Regulations 2016:

  • Regulation 12(1)(a) states that persons must not, except under the and to the extent authorised by an environmental permit… operate a regulated facility.
  • Regulation 38(2) makes it an offence for a person to fail to comply with or to contravene an environmental permit condition.

Penalty

Johnsons Aggregates and Recycling Ltd was fined £40,000 and ordered to pay costs of £49,886.75.

 

Nursing home operator fined in connection with septic tank spills

A Bristol nursing home operator has been fined for septic tank discharges that led to pollution of nearby farmland.

The prolonged and avoidable environmental incident first started at the Abbots Leigh Nursing Home in 2018, when a permit for a groundwater discharge activity was issued to Treasure Homes Ltd and was later found to be non-compliant following a routine inspection.

Despite numerous communications, the company failed to implement the actions required by the Environment Agency to bring the discharge back into compliance.

The problem did not resolve itself and an Environment Agency officer inspecting the site in early 2022 instructed Treasure Homes Ltd to arrange for various tests to ensure the viability of the septic tank and its discharge, including a definitive test to prove whether the septic tank’s discharge was the source of the pollution.

No update was provided by the company and therefore, the Environment Agency carried out the test on its behalf and recharged Treasure Homes Ltd for the work. On 21 July 2022, dye testing established the track of the polluting material, from the septic tank to the contaminated and boggy area within the neighbouring field, confirming the unauthorised discharge of septic tank effluent. A subsequent Environment Agency report identified the non-compliance with the permit and outlined remedial actions needed. The company did not respond to the report.

On 15 September 2022, an enforcement notice was served on the company formalising the earlier actions. This notice was also not complied with.

Treasure Homes Ltd was given an opportunity to defend itself in an interview under caution in May 2024, and again in July 2024.  The company did not attend either interview.

Background

Treasure Homes Ltd was charged with and pleaded guilty to two offences:

  • Between 21 July 2022 and 24 April 2024: causing a water discharge activity, otherwise than under or in accordance with an environmental permit, namely the discharge of poisonous, noxious or polluting matter, namely septic tank effluent, from an underground tank into the ground, contrary to Regulation 12(1)(b) and Regulation 38(1)(a) of the Environmental Permitting (England and Wales) Regulations 2016:
    • Regulation 12(1)(b) states that persons must not, except under the and to the extent authorised by an environmental permit… cause or knowingly permit a water discharge activity or groundwater activity.
    • Regulation 38(1)(a) makes it an offence to contravene Regulation 12(1).
  • Failing to comply with the requirements of a notice requiring the results of a survey or inspection of the sewerage system by 17 October 2022, under Regulation 61(1) of the Environmental Permitting (England and Wales) Regulations 2016:
    • Regulation 61(1) allows authorities and regulators to use notices to require information from persons within specified periods.

Penalty

Treasure Homes Ltd was fined a total of £20,600, ordered to pay costs of £12,481.21 and a statutory surcharge of £2,000.

Treasure Homes Ltd was also ordered to pay £5,000 compensation to the farmer whose field had been affected by septic tank effluent from the premises.

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