Digital waste tracking for scrap metal yards and vehicle dismantlers

Every load of scrap that comes over your weighbridge is a record for Defra, within two working days. The surprise for most yards is how often a load is hazardous: lead batteries and cars that haven't been depolluted both are.

Who: The operator of a permitted metal recycling site (MRS) or authorised treatment facility (ATF).
Codes: R4 for recycling metal. R13 if you only store it before it goes on.
Hazardous: 16 06 01* lead batteries and 16 01 04* end-of-life vehicles carry an asterisk. Those loads need the consignment note code, or a reason.
Separate: Scrap Metal Dealers Act records are a different duty. Digital waste tracking does not replace them.

Start free Check your permit

What English metal recycling sites took in

From their 2024 returns to the Environment Agency. More than half took lead batteries, which is the commonest code on the list, and it is hazardous.

Code	What the catalogue calls it	Sites
16 06 01*	lead batteries	56%
19 12 02	ferrous metal (pulled out of mixed waste)	41%
20 01 40	metals (from households and businesses)	41%
19 12 03	non-ferrous metal (pulled out of mixed waste)	41%
16 01 04*	end-of-life vehicles (cars not yet depolluted)	40%
17 04 05	iron and steel	40%
17 04 11	cables other than those mentioned in 17 04 10	37%
17 04 01	copper, bronze, brass	35%
16 01 17	ferrous metal (from vehicles)	32%
16 01 06	end-of-life vehicles, containing neither liquids nor other hazardous components (depolluted cars)	29%

"Sites" is the share of the 480 English metal recycling site permits that sent the Environment Agency 2024 waste returns and took that code in at least once EA 2024 Waste Data Interrogator. A code an asterisk follows is hazardous.

Vehicle dismantlers (ATFs)

Nine in ten of the 637 vehicle dismantling and depollution permits took in 16 01 04*, end-of-life vehicles not yet depolluted. Depolluted cars are 16 01 06. SR2015 No 17 lists seven codes: 16 01 03, 16 01 04*, 16 01 06, 16 01 21*, 16 01 22, 16 06 01*, 16 06 05.

The same metal has different codes depending on where it came from: iron and steel off a demolition job is 17 04 05, from a car 16 01 17, pulled out of mixed waste 19 12 02, from households 20 01 40. More on reading codes.

R4 or R13

R4 is recycling or reclaiming metals: sorting, shearing, baling, dismantling. R13 is storing it before it goes on to be recovered somewhere else. In 2024 returns the tonnes at metal recycling sites went under R4 84%, R13 13%, R3 1%, D15 1%, R12 1%; at dismantlers R4 72%, R13 20%, D15 4%, R5 2%, R3 1% WDI 2024. SR2015 No 16 allows R4, R13. Your permit's list is the one that counts.

An example record, filled in

A made-up van load from a builder: some steel and two old car batteries. Two waste items on one record, and because one of them is hazardous, the load needs the consignment note code.

Box	What goes in it (made-up load)
Date and time it arrived	15/10/2026 09:30:00 (Thursday)
Your reference	The weighbridge ticket or transfer note number, e.g. T-10482
Your site and permit	Example Metals, EX0001XX
Carrier and their number	Example Builders Ltd, CBDL123456
How it came	Road
Vehicle registration	AB12 CDE
Item 1	Iron and steel, 17 04 05, Solid, [LOO] Loose, 0, 420 Kilograms actual, R4 for 420 kg
Item 2	Lead batteries, 16 06 01*, Solid, [LOO] Loose, 0, 28 Kilograms actual, R13 for 28 kg
Hazardous properties (item 2)	Yes: the HP codes and components from the consignment note, or say where they came from
Consignment note code	From the note, e.g. EXAMPL/A0001, or one of Defra's three reasons if there is none
POPs	No
Due at Defra by	23:59 on Monday 19 October 2026, two working days after the day it came in

All names and numbers are made up. In England and Wales a consignment note code is six letters or numbers, a slash and five more.

Things that catch yards out

Members of the public. A householder bringing their own household scrap has no carrier number: give Defra's reason, householder. Anyone bringing it in for a business needs their carrier number, or one of the other reasons if it is true. Carrier numbers and the four reasons.
Batteries in the same load. One hazardous item makes the whole record need a consignment note code or a reason. Consignment notes and digital waste tracking.
Kilograms or tonnes. Keep to one unit per item, and check the weighbridge ticket's unit. A kilogram figure typed as tonnes is one of the commonest mistakes.
Other records stay. Scrap Metal Dealers Act records and your permit's waste returns carry on. Digital waste tracking doesn't file them for you.

Who has to report what

You report what comes in. The duty is on the operator of the permitted site that receives the waste Reg 4(1). One record per load, within two working days of the day after it arrives.
Not what goes out. When a load leaves you for another permitted site, that site reports receiving it. Your outgoing paperwork carries on as before.
Not the producer or the haulier, yet. Carriers, brokers and dealers are planned to come in from October 2027 GOV.UK. What is known about that so far.
Paper carries on. Waste transfer notes, Annex VII forms and hazardous waste consignment notes are still needed where they were before GOV.UK.

Permit or exemption?

This is the question that decides whether you report now.

A permit (numbered like AB1234CD or EPR/AB1234CD) for a site that receives waste: you are in phase 1, from 1 October 2026 in England and Wales. In Scotland and Northern Ireland the date is 1 January 2027.
Only a registered exemption (a WEX number): not phase 1. GOV.UK say exemptions "will be included in a later phase" and have not given a date GOV.UK. How to tell which you hold.

Not sure? The free permit check looks your site up on the Environment Agency's register.

Straight answers

Questions people ask

Do scrap metal dealers need digital waste tracking?

A scrap yard with an environmental permit to receive waste does: from 1 October 2026 in England and Wales every load it takes in is reported to Defra within two working days. A collector or mobile dealer without a site comes in later, with carriers and dealers, planned for October 2027.

What R code does a scrap yard use?

R4 for recycling or reclaiming metals. R13 if the site only stores the metal before it goes on. Your permit lists the codes you may use.

Are car batteries hazardous for digital waste tracking?

Yes. Lead batteries are 16 06 01*, an asterisked code, so the load needs the consignment note code, or one of Defra's reasons for not having one, and the hazardous details.

What EWC code is a scrap car?

16 01 04* for an end-of-life vehicle that has not been depolluted, which is hazardous. 16 01 06 for one with neither liquids nor other hazardous parts.

Does digital waste tracking replace my Scrap Metal Dealers Act records?

No. They are a separate duty and carry on. So do waste transfer notes, consignment notes and your permit's waste returns.

Want this done for you at the gate?

Byrne Waste Tracking runs in the browser on a phone or computer, with nothing to install. It remembers your carriers and their numbers, offers the waste codes and R or D codes your site uses, checks each load against Defra's rules first, and sends it to Defra automatically once you've linked your Defra account. Byrne Digital Solutions is listed on GOV.UK as a compatible software provider.

£89 per site per month, no contract. Join before 1 November 2026 and nothing is due until 1 November; join from 1 November and you get 14 days free. After that it's £89 a month per site, and there's no card to enter until you start it. No setup fee when you set it up yourself. If a consultant introduces you, any setup fee is agreed through them and you see the amount before you pay anything.

A site in Scotland or Northern Ireland that joins before 1 January 2027 pays nothing until 1 January 2027, the day the duty starts there.

Start free Log a pretend load first

Got a waste consultant? Ask them about Byrne first. Stuck on something here? Email wilf@byrnedigitalsolutions.co.uk - email is the quickest way to reach me, and I reply the same working day.

Hazardous waste sites: consignment notes and digital waste trackingConsignment notes carry on. Each note is its own record, with the code, HP codes and components.
Digital waste tracking for WEEE treatment facilitiesElectricals and battery codes, which are hazardous, R4 or R13, and an example.
Digital waste tracking for tyre recycling and storage sites16 01 03 on every load, R3, R4 or R13, and turning a tyre count into a weight.
The carrier's number isn't on your paperwork. Here's where to find it.Look the haulier up free on the public register by name or postcode, and the formats Defra accept.
Every guideAll the questions customers ask, one page each.