Environmental · Best Practice · Pre-Construction
Site Waste Management Plan
A plan for managing construction waste including estimates, minimisation strategies, and disposal routes.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. Environmental Protection Act 1990 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.
| Legal basis | Environmental Protection Act 1990 (EPA 1990) |
| Status | Best Practice — Site Waste Management Plans Regulations 2008 were revoked in 2013; the EPA 1990 duty of care for waste remains in force |
| Prepared by | Principal Contractor |
| Targets | ≥90% landfill diversion |
| Waste hierarchy | Prevention > Reuse > Recycling > Recovery > Disposal |
1. The SWMP — Managing Construction Waste Responsibly
Construction and demolition activity generates approximately 40% of all solid waste produced in the United Kingdom. Despite the revocation of the Site Waste Management Plans Regulations 2008 in December 2013, the practical and commercial case for maintaining a robust Site Waste Management Plan remains as strong as ever. The duty of care provisions under the Environmental Protection Act 1990 still require every person who produces, imports, carries, keeps, treats, or disposes of waste to take all reasonable steps to ensure that waste is managed properly and does not escape their control.
A well-prepared SWMP identifies the types and estimated quantities of waste that the project will generate, sets targets for segregation and landfill diversion, establishes responsibilities for waste management, and provides a framework for monitoring and reporting waste performance throughout the project. Many clients, particularly in the public sector and on projects targeting BREEAM credits, continue to require SWMPs as a contractual obligation.
The waste hierarchy — prevention, reuse, recycling, recovery, disposal — is a legal obligation under the Waste (England and Wales) Regulations 2011. Every person who produces waste must apply the hierarchy and take all reasonable measures to prevent waste, then to prepare it for reuse, then to recycle it, and only dispose of it as a last resort. A SWMP is the most effective tool for demonstrating compliance with this obligation.
A waste register makes commercial and environmental sense
Even without a legal SWMP requirement, maintaining a waste register throughout the project makes sense commercially and environmentally. It provides a clear record of waste volumes, disposal routes, and costs, and it demonstrates due diligence in meeting the duty of care obligations under EPA 1990. On any project where waste costs are significant, a SWMP will pay for itself through better segregation and reduced disposal charges.
2. What a SWMP Should Cover
The following table sets out the core sections that a comprehensive SWMP should include. The level of detail will vary depending on the scale and nature of the project, but the fundamentals remain the same for every construction site.
| Section | What to include |
|---|---|
| Project details | Project name, address, client, principal contractor, estimated project value, estimated construction duration, and a brief description of the works. |
| Responsible persons | Name and role of the person with overall responsibility for waste management on site, names of waste champions or environmental coordinators, and contact details for the waste management contractor. |
| Waste streams | Identification of all anticipated waste streams (timber, concrete, brick, metal, plasterboard, packaging, mixed waste, hazardous waste), estimated quantities for each stream, and European Waste Catalogue (EWC) codes. |
| Waste carriers | Names and contact details of all waste carriers to be used on the project, Environment Agency registration numbers, registration expiry dates, and verification records confirming that registration has been checked. |
| Site plan waste areas | Location of waste segregation areas, skip positions, hazardous waste storage areas, and waste compound layout. The site plan should show clear signage, access routes for collection vehicles, and separation distances from drainage and watercourses. |
| Waste hierarchy targets | Percentage targets for prevention, reuse, recycling, recovery, and disposal for each waste stream. The overall landfill diversion target should be stated — a minimum of 90% is considered good practice on most construction projects. |
| Monitoring | Frequency and method of monitoring waste volumes and disposal routes, monthly waste returns, comparison of actual performance against targets, and reporting arrangements to the client and project team. |
| Review | Schedule for formal review of the SWMP (at minimum, monthly), process for updating the plan when waste streams change or targets are not being met, and close-out report at project completion summarising overall waste performance. |
3. Common Mistakes
Treating the SWMP as a file-and-forget document
A SWMP that is prepared at the start of the project and never looked at again serves no purpose. The plan must be a working document that is reviewed and updated regularly as the project progresses. Waste streams change as different trades come on site, quantities may exceed or fall below estimates, and new waste types may be generated. Monthly reviews, updated waste data, and comparison against targets are essential to making the SWMP effective.
Not segregating waste on site
Mixed waste is expensive to dispose of and difficult to recycle. Effective segregation at source — separate skips or containers for timber, metal, concrete, plasterboard, packaging, and general waste — dramatically increases recycling rates and reduces disposal costs. If waste is mixed in a single skip, the entire load is likely to go to landfill or energy recovery, and the project will fail to meet its landfill diversion targets.
Using unregistered waste carriers
Every waste carrier must be registered with the Environment Agency. Using an unregistered carrier is a criminal offence under the Controlled Waste (Registration of Carriers and Seizure of Vehicles) Regulations 1991. More importantly, if waste is fly-tipped by an unregistered carrier, the producer (the construction site) retains liability under the duty of care. Always verify the carrier's registration on the Environment Agency public register before any waste leaves site.
Not retaining Waste Transfer Notes
A Waste Transfer Note (WTN) must accompany every transfer of non-hazardous controlled waste. The WTN must be retained for a minimum of two years. Failure to produce a WTN when requested by the Environment Agency is an offence. WTNs should be filed systematically — by date or by waste stream — and checked weekly to ensure that every collection has been documented. A missing WTN means the project cannot prove that waste was disposed of lawfully.
Underestimating hazardous waste
Hazardous waste requires separate handling, storage, documentation (consignment notes rather than WTNs), and disposal at licensed facilities. Common hazardous wastes on construction sites include asbestos, contaminated soil, lead paint, fluorescent tubes, oil filters, and solvent-contaminated rags. Failing to identify and segregate hazardous waste from the outset can result in contamination of non-hazardous waste streams, significantly increasing disposal costs and regulatory risk.
4. Frequently Asked Questions
Is the waste hierarchy a legal requirement?▾
Yes. The waste hierarchy is a legal obligation under the Waste (England and Wales) Regulations 2011, which implement the EU Waste Framework Directive. Anyone who produces, keeps, or manages waste must apply the hierarchy: prevention first, then preparation for reuse, then recycling, then other recovery (including energy recovery), and disposal only as a last resort. The duty applies to construction waste in the same way as any other waste stream. Failure to apply the hierarchy is an offence.
What landfill diversion target should we set?▾
A minimum of 90% landfill diversion is considered good practice on most construction projects and is typically required for BREEAM credits. Many major contractors now target 95% or higher. The target should be realistic but stretching, and it should be supported by a clear segregation strategy and monitored monthly. If the target is not being met, the SWMP review process should identify the reasons and implement corrective actions.
What is SMARTWaste?▾
SMARTWaste is an online waste reporting and benchmarking tool developed by BRE (Building Research Establishment). It allows construction projects to record waste data, track performance against targets, benchmark against industry averages, and generate reports for BREEAM assessments. Many clients and principal contractors use SMARTWaste as their standard waste reporting platform. It provides a structured way to capture waste data that would otherwise be recorded inconsistently across different projects.
How does the SWMP relate to ISO 14001?▾
ISO 14001 is an international standard for environmental management systems (EMS). A SWMP is not the same as an EMS, but it is a component of effective environmental management on a construction project. If the principal contractor holds ISO 14001 certification, the SWMP should be integrated into the environmental management system and subject to the same audit, review, and continual improvement processes. ISO 14001 requires the organisation to identify environmental aspects (including waste), set objectives and targets, implement controls, and monitor performance — all of which the SWMP supports.
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