Triinu La Caille, FCIWM CMgr FCMI, Head of Compliance & Sustainability, explores why compliance teams are the missing – and often overlooked – link in the circular economy.
We discuss technology and targets, but the UK will not achieve a truly circular economy without compliance teams shaping how materials are actually managed, tracked, and repurposed as products.
I keep meeting organisations that want circular outcomes, but treat compliance like an afterthought. Procurement hunts for recycled content, operations chase diversion rates, and marketing wants a great case study.
Who owns the messy middle, the bit where waste becomes a resource without breaking the law or the chain of custody? That is the compliance team’s lane; when it is empty, circular ambitions stall.
The legal line that changes everything
Once something is ‘waste’, you are in a different world. POPs (persistent organic pollutants) rules are a good reality check. If waste contains POPs, you cannot reuse or recycle that waste; the POPs must be destroyed. That is not optional; it is the law.
Electronics make this concrete. WEEE (Waste Electronic and Electrical Equipment) that is POPs waste must not be prepared for reuse, repaired, or refurbished for reuse. The exceptions carve-out is narrow; only items manufactured on or after 1 January 2009 can be reused within the UK, and only where you can evidence the other conditions.
Otherwise, POPs must be destroyed. In practice, plastic casings, printed circuit boards and cables are common POPs hotspots, so reuse routes close quickly the moment a device becomes waste.
This is exactly where a capable compliance function earns its keep. If reuse is the goal, they help teams design pre-waste pathways. For example, tested post-consumer WEEE that never enters the waste regime, with proper evidence and warranties.
If an item is already waste, they steer it into fully compliant destruction or POPs-safe treatment. It is not glamorous, but it is what keeps circular efforts legal and defensible.
End-of-waste, still harder than it should be
Another reason compliance feels like friction is that the UK’s end-of-waste test is still a confidence game. Operators have to show that a material is produced by a defined process, meets a product standard, and can be used directly like a virgin equivalent.
That is doable, but often slow and uncertain, which nudges businesses toward disposal or low-grade outlets. CIWM (The Chartered Institution of Wastes Management) has argued for a refresh, including clearer, sector-specific criteria to speed up circular markets. I agree. Clearer end-of-waste rules would make compliance faster, not looser.
Data is finally catching up with our promises
Two policy shifts will make or break circular credibility over the next few years. First, Digital Waste Tracking (DWT).
From April 2025, more organisations began onboarding, and from October 2026, receiving sites in England must use the service. That means near-real-time waste data across carriers, transfer stations and end plants. Good compliance teams will use this to prove claims, spot leakage, and close loops with evidence, not anecdotes.
Second, Simpler Recycling. Businesses in England with 10 or more employees must have been separating core recyclable streams and food waste since 31 March 2025, with micro-firms following by 31 March 2027.
For households, local authorities must collect the core materials, with weekly food waste, from 31 March 2026, subject to transitional arrangements. Again, compliance will translate these dates into contracts, site instructions and audits that stick.
Carbon costs are arriving at the back door
The UK ETS (Emissions Trading Scheme) is expanding to cover waste incineration and energy-from-waste (EfW), with a voluntary monitoring, reporting and verification period starting 1 January 2026, and the government signalling full inclusion from 2028 in its consultation package and interim responses.
Whether dates shift or not, the direction of travel is clear: residual disposal will carry a carbon price. Smart compliance people are already stress-testing contracts and modelling cost exposure so businesses do not get caught out.
Waste crime, traceability and why paperwork is climate action
Circularity runs on trust. If you cannot show where the material went, you cannot credibly claim it displaced virgin production. Waste crime eats away at that trust, with official surveys suggesting almost a fifth of waste is illegally managed, with the economic hit sitting around a one billion pounds a year in England.
The scale looks worse the more we look. Recent reporting points to thousands of illegal sites across the UK, with high-profile cases like Hoad’s Wood in Kent and a growing cluster in Oxfordshire and Wigan, and the Environment Agency confirming it closed 743 illegal sites in 2024 to 2025, with many more remaining open.
Parliament has started to say the quiet part out loud. The House of Lords Environment and Climate Change Committee found waste crime is critically under-prioritised, flagged multiple failures at the Environment Agency and the ineffectiveness of the Joint Unit for Waste Crime, and called for an independent review. Ministers have pushed back on a new review for now, which the Committee described as complacent.
So yes, the regulator is working, and often under tough constraints, but it is not consistently the compliance machine the system needs right now. That is a signal to businesses. You cannot outsource assurance to enforcement.
Compliance teams inside operators and clients need to step up, build clean chains of evidence, verify end destinations, use digital waste tracking as it rolls out, and make routine due diligence a habit.
It looks like paperwork. In practice, it keeps material in legal routes, shuts the door on the cheap illegal option, and makes your climate claims defensible.
The people gap that nobody budgets for
Here is the awkward part. Many organisations, especially SMEs, have thin or no in-house compliance capacity. Surveys have long shown low awareness of Duty of Care and weak internal controls across UK businesses. Add new rules on POPs, digital tracking and carbon, and you get a widening skills gap.
CIWM’s 2023 skills report estimated more than 74,000 new roles required by 2030, rising to roughly 239,000 by 2040 across collection, reuse, design, regulation, communications and more. That is a big ask without a plan.
Recruiters are also saying the quiet part out loud as well. John Tilbrook, Managing Director at Newman Stewart, recently called on senior leaders to treat green workforce planning as strategic, not administrative, with cross-functional, data-literate roles that can actually run a circular system. That resonates with what I see: the bottleneck is often people, not technology.
So what does ‘compliance as an enabler’ look like in practice?
Here is the playbook I wish more organisations used.
- Design pre-waste routes for reuse – If you want to reuse, keep qualified products as products. Build tested used EEE channels, warranty packs, serialised records, and commercial terms that avoid tipping items into WEEE. Do that with compliance in the room, not after the fact.
- Know your POPs hotspots – Map where POPs could appear in your portfolio, for example, seating foams, plastic casings, certain cables, and set default routes accordingly. If it is POPs waste, do not pretend it is not; specify destruction with the right evidence.
- Make end-of-waste your product brief – Treat quality specs, contamination limits and customer acceptance criteria as a product management task. The clearer the spec, the cleaner the audit trail, the quicker the upgrade from waste to product. Push for clearer national criteria through your trade bodies.
- Upgrade your data spine before the deadlines – Prepare for Digital Waste Tracking and Simpler Recycling by aligning site codes, carriers, EWC codes and end-destination contracts now. Build dashboards that show not just tonnages, but legal routes and evidence status.
- Model the cost of carbon on residuals – Whether UK ETS lands in 2028 or a touch later, plan for it. Build carbon exposure into T&Cs, explore contracts that reward higher capture of recyclables, and scrutinise EfW heat offtake options to reduce risk.
- Invest in people like you mean it – Build or buy capability in environmental law, data management, product standards and supply-chain assurance. The job market is tight. Upskill the teams you have, and recruit for the blend of policy literacy and operational nous that circular systems need.
Final thought
We do not get a circular economy by wishing materials back into products. We get there by running clean, auditable pathways through a pretty demanding rulebook, and celebrating the people who make that possible.
Put compliance in the centre of the room, give them the tools and the headcount, and the loops start to close.
