DWTS for scrap metal and metal recycling sites: what you need to know

Scrap metal is controlled waste, even when you pay for it. From October 2026, metal recycling sites that hold an environmental permit must record every incoming load with the Digital Waste Tracking Service. Here is how to tell if it applies to you and what to do about it.

Why scrap metal recyclers are in scope

Metal recycling sites hold permits to receive scrap metal, and scrap metal is controlled waste the moment it is discarded. If you are permitted to receive it, you are a receiving site, and the DWTS obligation attaches to every load that crosses your gate.

The fact that you pay for the material does not change this. Scrap has value, but it is still waste under the law, and the duty of care applies to it like any other controlled waste. From October 2026 in England and Wales (January 2027 in Scotland), that duty includes a digital record for every receipt.

The EWC codes that do most of the work

Metal loads sit in a small number of European Waste Catalogue codes. Most fall in the 17 04 chapter for metals from construction and demolition, or the 16 01 chapter for material from end of life vehicles. Ferrous and non-ferrous metals carry different codes, and a mixed load has its own.

Getting the code right matters because a wrong code means a wrong record, and the penalties for a wrong record are the same as for a missing one. If you take material from car breakers, the depolluted shell is coded differently from undepolluted vehicles, which are hazardous.

The carrier check that catches people out

Metal recyclers buy from all sorts of sources, from skip firms and demolition crews to house clearances and one-off drop-offs. Whoever brings the material is a waste carrier, and they need a registration to carry it.

Before a load is accepted, LoadLog checks the carrier number against the Environment Agency's public register. That removes the risk of taking the driver's word for it and finding out later that the carrier was not registered.

Permit or exemption: which one are you?

The DWTS Phase 1 date of October 2026 is set for permitted sites. If you operate under a full environmental permit, the obligation is clear. If you operate under a registered waste exemption, DEFRA has not yet confirmed a firm Phase 1 date in the way it has for permit holders.

Check your specific exemption category with your regulator before you assume one way or the other. The Environment Agency in England, NRW in Wales, SEPA in Scotland and NIEA in Northern Ireland can confirm where you stand.

What to do now

If you are in scope, register with DEFRA's Digital Waste Tracking Service and get your API credentials. That is separate from your environmental permit and involves linking your organisation to your permit number.

From there, every load needs a digital record submitted within two working days of the day after it arrives. There is a £26 per organisation annual fee for the service, set by DEFRA. You can submit through compatible software or through a temporary spreadsheet upload expected to remain until at least October 2027.