Changes to EPR05-07 legislation

What’s changing? 

The main change affecting your business, the producer, is the requirement to have a label displaying specific details (or a unique identifier) on the largest of the single container transferred. If you provide just a bag or rigid bin, there also needs to be a unique identifier on this.   
The label you place on your waste receptacle must include: 

  • Your businesses name  

  • Your businesses postcode  

  • phs as the collector  

  • Date waste was placed at waste collection point. 


Why is this important?

Effective waste labelling is crucial to ensure healthcare type waste disposal complies with legalisation.  

The aim of labelling is to prevent rogue waste trading, as it ensures all waste is labelled with details of the producer and the company that is responsible for disposing of it.   

As your waste disposal provider, phs legally need to be able to supply digital documentation for all aspects of the waste we collect. This includes pre-acceptance audits, carriers’ licences, site permits, consignment notes, waste transfer notes and healthcare type waste quarterly returns.  



Extended Producer Responsibility: 


  • It has always been a requirement for healthcare producers to label their waste in order for the waste to be tracked from ‘Cradle to Grave’. 

  • The aim is to reduce waste pollution and be able to track waste back to its producer at any point in its journey. 

  • HTM07-01 states – “Each waste bag must be traceable back to its producer; this includes the post code, facility and department”. 

Frequently Asked Questions

  • Defra and the EA have taken a harder stance on this and have now included this within our recent permits for some depots. 

This means we now also must show that we are enforcing this should the EA audit our locations. 

Yes – this applies to all healthcare type waste except for offensive waste regardless of what vehicle/service line services the unit. However, most WR work is sharps which already have a label affixed to product. 

We will continue to collect for the time being as a grace period whilst the new process is communicated and whilst the old stock of rigid units without a label is exhausted. 

Yes the only HC waste that is exempt from a label is Offensive waste (note: 20L Pharmi Bins, you will need to label the bag inside the unit rather than the rigid container as these units are operated as a liner exchange service) 

Expert support

Our dedicated team of healthcare experts will be in touch by phone to discuss how phs can support you with implementing these changes. If you have any questions in the meantime, please don’t hesitate to speak to your account manager.

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