The Environment Agency (EA) has confirmed that the T9 waste exemption for recovering scrap metal is still available for registration.  
  
The proposed reforms to exemptions, when enacted, means that in future an environmental permit would be required. The EA has clarified that, although Government has reiterated it’s plans to reform the waste exemptions system, which include plans to remove the T9 waste exemption, operators can currently continue to use the T9 exemption.
 
Operators with T9 and S2 exemptions can renew them together and when the time comes to apply for a permit, the permit application can cover all relevant waste types.  
 
Despite contrary information reportedly provided by some independent consultancies, operators DO NOT have to apply for an environmental permit yet, if they are meeting the exemption requirements. No action is required before waste exemption reforms come into force unless your current activities exceed the exemption thresholds or you are undertaking an activity (eg. mechanically fed shearing) that is not covered by the T9 exemption. There will be transitional arrangements which would allow operators 3 months to make the necessary permit application when the legislation comes into force. The EA will contact exemption holders when waste exemption reforms are likely to come into force. 
 
An EA spokesperson said “For now, T9 exemption operators can still register or renew their exemptions and get their business ready for the waste exemption reforms. There have been no changes in law yet, we will keep waste exemption operators and trade associations such as the British Metal Recycling Association updated on the progress. However, T9 exemption operators will now (from July 2025) need to pay for their waste exemptions when they are registered for the first time or are renewed”. 
 
Antonia Grey, BMRA’s Head of Policy and Public Affairs said “As soon as the EA/DEFRA let us know the timeline for reforms, we will inform members about the changes. In the meantime, we will continue to work with the EA to help develop the best permitting approach for the T9 exemption and improve other scrap metal standard rules permits”.