DWTS for anaerobic digestion and biomass plants: what you need to know

The one question that decides it

The Digital Waste Tracking Service does not treat all anaerobic digestion and biomass plants the same way. Whether it applies to you comes down to a single question: does your plant accept waste, or does it only process material you produce yourself?

If your plant takes in food waste, crop residues, slurry or other material from another business or from a third party, you are a waste receiving site. From October 2026 (January 2027 in Scotland), you must record and submit every waste receipt to the DWTS within two working days.

If your plant only digests feedstock produced on your own farm or within your own business, and you hold no environmental permit that authorises you to accept waste from others, you are likely outside Phase 1. The obligation applies to receiving sites, not to producers handling their own material.

This distinction matters more than the technology you run. The law cares about what crosses your gate, not what happens inside the digester.

Why AD and biomass plants are often caught out

Anaerobic digestion sits in an awkward position in the waste industry. Many operators do not think of themselves as waste businesses at all. They think of themselves as energy producers, or farmers, or process engineers.

The reality is that a plant taking in food waste under an environmental permit is a waste operation. The permit is the tell. If your regulator issued you a permit that includes accepting waste, you are in scope for the DWTS in the same way as a transfer station or a landfill.

Biomass plants have the same issue. A plant burning virgin timber grown for fuel is not a waste operation. A plant burning waste wood, or accepting biomass feedstock from third parties under a waste permit, is. The same single question applies.

The government has not carved out an exemption for AD or biomass as a sector. The rules are written around receiving waste, and several of these plants do exactly that.

What you have to do if you are in scope

If you are a receiving site, the obligations are the same as for any other permitted waste site. Register with DEFRA's Digital Waste Tracking Service and get your API credentials, a step that is separate from your environmental permit and involves linking your organisation to your permit number.

From there, every load of feedstock arriving at your gate needs a digital record, submitted within two working days of the day after it arrives, so a load received at 9am on Monday must be reported by 11:59pm on Wednesday.

There is a £26 per organisation annual fee for the service, set by DEFRA and separate from anything you pay a software provider.

You can submit through an API connection using compatible software, or through a spreadsheet you download, fill in and upload. The spreadsheet route is a temporary option expected to remain until at least October 2027.

The feedstock record-keeping angle

AD and biomass plants face a specific practical issue that a skip yard does not. Your incoming loads are feedstock, and the weight and composition of that feedstock matters to your process as well as to your compliance.

The DWTS record requires the same core data as any waste movement: a description of the waste, the European Waste Catalogue code, the quantity, the carrier details and the receiving site details. For an AD plant taking food waste, the EWC code is typically in the 20 01 or 19 12 range depending on whether the material is source-segregated or comes from a treatment process.

Getting the EWC code right matters here as much as anywhere. Miscoding a load of food waste means the record is wrong, and the same penalties apply as for a missing record.

On-farm AD: the exception to watch, and the exemption to check

The on-farm digester that processes only the farm's own slurry and crop material is the classic case of a plant that is not a receiving site. No waste crosses the gate from outside, so no waste receipt needs reporting.

But the line is easy to cross. Many on-farm plants take in food waste from local restaurants, supermarkets or food processors to boost gas yield, and the moment that happens under a permit that allows it, the site becomes a receiving site, with the DWTS obligation attaching to every such load.

Some smaller on-farm plants take that outside food waste under a registered waste exemption rather than a full environmental permit. DEFRA has not yet confirmed a firm Phase 1 date for exemption holders in the way it has for permitted sites, so if that is your setup, do not assume the permit-holder rules apply to you automatically. Check your specific exemption category with your regulator.

If you are not sure which side of the line your plant sits on, check your permit or exemption paperwork first. If in doubt after that, your environmental regulator (the Environment Agency in England, NRW in Wales, NIEA in Northern Ireland, or SEPA in Scotland) is the authority to ask, not a software vendor.

Scotland and the timing

Scotland follows the same rules but three months later. Scottish AD and biomass plants in scope have until January 2027 rather than October 2026. The underlying system and the data fields are identical, so preparing now costs nothing and buys you runway.

Carriers, brokers and dealers join the DWTS from October 2027. If your plant operates its own haulage to bring feedstock in, that haulage may need to comply as a carrier under Phase 2. The receiving site obligation under Phase 1 is the priority for now.

Getting ready

The practical steps are the same as for any receiving site. Confirm your permit or exemption status, check that your registered address matches where you operate, and register with the DWTS to get your credentials.

Choose a submission method and test it in the sandbox environment before the mandate starts. Train whoever logs incoming feedstock so the process runs smoothly from day one.

A plant taking feedstock deliveries seven days a week needs a workflow that can keep up, or the records will fall behind and the enforcement risk builds.