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What is an EWC code? A guide to List of Waste codes

Hazardous Disposal5 minute read

Office worker reviewing waste paperwork on a clipboard beside sealed drums in a tidy industrial unit

An EWC (European Waste Catalogue) code, also known as a List of Waste (LoW) code, is the six-digit code used to classify a waste and show whether it is hazardous. Each code sits within a legal list of wastes, and hazardous entries are marked with an asterisk (*). Businesses in the UK record the EWC code on the paperwork that travels with their waste, and the business that produces the waste is responsible for working out which code applies.

What the List of Waste is

The Environment Agency's Technical Guidance WM3 (Waste Classification: Guidance on the classification and assessment of waste) describes the List of Waste as the legal classification system for classifying waste and identifying whether it is hazardous.

The list comes with legal instructions explaining how it has to be used. The terms EWC code and LoW code are used interchangeably in UK guidance.

How an EWC code is structured

Every EWC code is made up of three pairs of digits.

  • Chapter (first two digits): the list is divided into 20 chapters, numbered 01 to 20. Some are based on the industry or activity that produced the waste, such as Chapter 04 for the leather, fur and textile industries. Others are based on the type of waste, such as Chapter 13 for oil wastes and wastes of liquid fuels.
  • Sub-chapter (second two digits): most chapters are split into sub-chapters by process, activity or waste type, for example 13 01 for waste hydraulic oils.
  • Entry (final two digits): these identify the individual waste, creating the full six-digit code, for example 04 02 16* for dyestuffs and pigments containing hazardous substances.

WM3 explains that chapter and sub-chapter titles are part of the meaning of a code. A waste has to fall within the scope of the title to be considered under that chapter, and some titles exclude certain wastes altogether. For example, 20 01 01 (paper and cardboard) only applies if the waste meets the conditions of the chapter title, the sub-chapter title and the entry description together.

What the asterisk means

The six-digit codes in the List of Waste that are hazardous wastes have an asterisk (*) next to them. For example, 13 07 01* covers fuel oil and diesel.

An entry without an asterisk, and with no link to a mirror or absolute hazardous entry, is automatically non-hazardous. However, WM3 notes that some non-hazardous entries are linked to other entries, for example for electrical wastes, batteries and medicines, so the missing asterisk does not on its own settle the classification.

The four types of entry

WM3 groups every entry in the list into one of four types. A separate guide covers mirror entries in more detail, but in brief:

  • Absolute hazardous: wastes that are always hazardous. If a waste fits the description, that code must be used. A waste under such an entry, such as any non-edible oil, remains hazardous even if it displays no hazardous properties.
  • Absolute non-hazardous: entries with no asterisk and no link to a mirror or absolute hazardous entry, such as 03 01 01 (waste bark and cork).
  • Mirror hazardous: entries marked with an asterisk that have a paired non-hazardous alternative, and that refer to hazardous substances in their description.
  • Mirror non-hazardous: the non-hazardous partner of a mirror pair, often worded "other than those mentioned in" the hazardous entry.

For mirror entries, the guidance explains that an assessment of the waste's composition and hazardous properties is needed before a code can be assigned. Where the composition of a mirror entry waste genuinely cannot be determined, it must be classified under the mirror hazardous entry.

Why the List of Waste is not a simple look-up list

WM3 makes the point directly: the List of Waste is not a "look up" list. To identify the appropriate code, the guidance says the entire list has to be considered, rather than a single process chapter, and the chapters have to be used in a set order of precedence.

In outline, the order is:

  • chapters 01 to 12 and 17 to 20, which cover the source industry or activity and municipal waste
  • chapters 13, 14 and 15, which cover waste oils and fuels, solvents, and packaging and absorbents
  • chapter 16, which covers general wastes such as vehicles, electronic equipment, batteries and chemicals
  • codes ending in 99, which are only used once the earlier steps have not produced a more appropriate code

Because codes are often linked, it is common for more than one possible code to be identified before the correct one is confirmed.

Why EWC codes are needed

Classification comes first. The GOV.UK guidance on how to classify different types of waste says businesses must classify the waste they produce before it is collected, disposed of or recovered. The purposes it lists include:

  • checking if the waste is hazardous
  • checking how the waste must be handled when it is moved
  • making sure that only an authorised organisation takes the waste
  • filling in waste paperwork correctly
  • preventing harm to people and the environment

The waste paperwork given to a waste contractor, whether a waste transfer note or a hazardous waste consignment note, must describe the waste. That description must include the waste classification code, whether the waste is hazardous or POPs waste (waste with a high level of persistent organic pollutants) and other details. That GOV.UK guidance applies to England. For more on the paperwork itself, see our guide do I need a consignment note.

WM3 places classification within the waste duty of care. It also sets out that waste holders have a duty to determine whether a mirror entry waste is hazardous or non-hazardous.

The responsibility for the EWC code therefore sits with the business producing the waste. Our guides on duty of care and the roles of producer, holder, carrier and consignee explain how these responsibilities fit together. Where a classification feels like a grey area, speak to our team.

Using EWC codes across the UK

EWC codes are used throughout the UK, but the technical guidance on applying them comes in more than one version. The GB version of WM3 is intended for anyone who produces, manages or regulates waste in England, Scotland or Wales, and it is published jointly by the Environment Agency, the Scottish Environment Protection Agency (SEPA) and Natural Resources Wales (NRW). WM3 notes that Northern Ireland has its own NI version. There, the Northern Ireland Environment Agency (NIEA) provides WM3 guidance through the DAERA hazardous waste page. Our article on hazardous waste rules across the UK nations covers wider differences between the nations.

Our collection services

Our hazardous waste collections include our chemical waste disposal, oil disposal and solvent disposal services. For background on which wastes count as hazardous in the first place, see what is hazardous waste.

Speak to our team

To discuss your waste, contact our team on 0845 366 9306 or email enquire@hazardousdisposal.co.uk.

This article is for general information only and does not constitute professional, legal or chemical advice. Waste producers are legally responsible for correctly classifying their waste. For guidance on your specific waste, please contact our team.

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