Written evidence from Biffa (WCI0009)
Lords Environment and Climate Change Committee Waste Crime Inquiry Briefing
Waste Crime Inquiry Briefing
Contents
Waste Crime Overview 3
Efficacy of current regulatory, monitoring and enforcement 4
Addressing the problem 5
Case Study – Organised Crime Units, theft of customer containers in Yorkshire 6
Waste Crime Inquiry Briefing
Waste crime in the UK is increasing in both scale and sophistication, with serious implications for local authorities, landowners, rural communities, and businesses. The Environmental Services Association (ESA) estimates that waste crime now costs the UK economy over £1 billion annually (2021). These costs are distributed across multiple sectors, including local authorities, legitimate waste operators and taxpayers, with costs to private businesses being in excess of this.
Almost one in five waste disposals (18%) in the UK are conducted illegally, reflecting both opportunistic offending and the growing involvement of organised crime groups. The repercussions are significant, generating financial losses, environmental pollution, and social harms such as increased fire risk, contamination, and public health threats.
Although fly-tipping is the most commonly discussed form of waste crime it takes many forms:
Waste crime is not a victimless crime; it is a billion-pound problem with systemic impacts for local communities, taxpayers, businesses and the UK economy. Tackling it requires a coordinated response: government must scale up enforcement and equip agencies with the powers and ringfenced resources to act, while businesses and the public must exercise due diligence in how waste is managed. Only through collective action can the financial, environmental, and social harms of waste crime be reduced.
Questions for the inquiry to address:
Waste crime in the UK
Waste crime is estimated to cost the UK economy over £1 billion annually, a figure that is considered conservative given that only 27% of waste crimes are thought to be reported. The costs are borne across multiple sectors: legitimate businesses lose revenue and face unfair competition, landowners and businesses are saddled with the cost of managing industrial scale dumping on their land, the public sector must divert resources to deal with the environmental consequences, and wider society suffers from degraded landscapes. The impact of waste crime on local communities can be serious on top of, public health concerns fly-tipping for example can make people feel unsafe in their local area, encourage further antisocial behaviour and damage, it can interfere with the operation of local businesses and access to local facilities. and the erosion of trust in the waste system.
One of the most significant drivers of large-scale waste crime is the involvement of organised crime gangs. Waste companies can be an attractive option for gangs seeking money laundering activities. however, rising costs associated with legitimate waste management—driven by tighter legislation, landfill taxes, and regulatory requirements— has also created an opportunity for a flourishing black- market for waste services. Organised crime groups exploit this by offering cheaper disposal options that undercut lawful operators, attracting both unscrupulous businesses and unsuspecting clients.
These groups are highly agile, moving between locations and quickly adapting their methods to exploit weaknesses in the system. Emboldened by inconsistent enforcement and weak information- sharing across regions, many of these groups have grown in scale and sophistication over recent years. Moreover, organised crime gangs that are active in the waste sector are often involved in other serious criminal activities, with evidence suggesting involvement in theft, drug and human trafficking, and violence. With instances of intimidation and threats against legitimate waste operators, the various type of criminal activities are not always distinct.
Fly-tipping remains one of the most visible and public-facing forms of waste crime. On a small scale, this may involve individuals engaging dumping of personal waste. Fly-tipping also exists on an industrial scale and can be embedded within the operation of a superficially compliant business.
Commercial and large-scale fly-tipping not only causes significant environmental damage but is often linked to organised crime gangs. In these cases, fly-tipping becomes systematic and profit- driven, compounding its impact on communities and local authorities.
Some operators successfully masquerade as legitimate businesses by operating some permitted waste sites but engage in at scale fraudulent practices such as the misclassification of waste, illegal exports, or exploitation of regulatory exemptions. These crimes are often more complex and less visible than fly-tipping but can have equally damaging consequences. For example, misclassifying hazardous waste as non-hazardous allows operators to dispose of it at lower cost, undermining environmental protections and creating health risks. In many cases, operators knowingly abuse regulations to save time and money, while in others, businesses may be complicit through negligence or lack of due diligence. The result is a distorted marketplace where law-abiding businesses are undercut by those willing to operate outside the law.
Efficacy of current regulatory, monitoring and enforcement
Responsibility for addressing waste crime and its impacts is split between the police, Environment Agency and local government. All three are already significantly under resourced waste crime struggles to receive prioritisation.
This under-resourcing creates major gaps in oversight, with illegal operators taking advantage of the lack of visible enforcement. Without sufficient staffing, intelligence capabilities, and operational funding, the Agency cannot respond effectively to the breadth and sophistication of the waste crime problem. Strengthening funding and capacity is therefore critical if regulation and enforcement are to be credible and capable of keeping pace with offenders.
Compounding the issue is a misperception within many police forces that waste crime is a victimless offence, largely confined to disputes between businesses. This is simply not the case. Waste crime has enormous economic consequences, costs the taxpayer millions each year, and causes severe environmental and social harms. Communities experience degraded environments, increased health risks, and reduced confidence in lawful waste services, while legitimate businesses face unfair competition. Changing this perception is essential: waste crime must be prioritised and treated with the seriousness it deserves by both police and other enforcement bodies.
These systemic weaknesses create a perfect opportunity for organised crime groups and waster operators with black market activities. Offenders exploit the fact that they can move operations across regions with relative ease, using their agility to avoid detection and enforcement. At the same time, poor national and regional information sharing means that intelligence about waste crime is fragmented, leaving gaps for criminals to exploit. Combined with the widespread de-prioritisation of waste crime by enforcement agencies, this has emboldened perpetrators, allowing them to grow in scale and sophistication. Addressing these vulnerabilities will require better collaboration, improved intelligence systems, and consistent prioritisation across agencies.
Recently proposed legislative reforms may provide tools to strengthen the regulatory framework. The Carriers, Brokers and Dealers (CBD) reform is designed to raise standards within the sector by tightening access requirements and ensuring that only legitimate operators can provide services. By creating a higher bar to entry, the reform should make it more difficult for illegal businesses to operate under the guise of legitimacy. Alongside this, the introduction of Digital Waste Tracking (DWT) has the potential to improve transparency across the waste chain by ensuring that waste can be followed from its source through to its final destination. If implemented effectively, this will expose instances where waste is diverted away from approved channels. However, careful scrutiny will be required to ensure that the system cannot be manipulated by fraudsters—for example, through the misuse of approved operator permit numbers. It will also not address some criminal operations that will simply not register as waste carriers, brokers or dealers.
DEFRA’s recent announcement of vehicle seizure permissions represents another potential step forward. Seizing vehicles used in waste crime could act as a strong deterrent, particularly against fly- tipping and illegal transportation of waste. However, the effectiveness of this measure will depend on the deterrent effect of full implementation. It is vital that data is collected and published on the frequency and outcomes of vehicle seizures to assess whether the power is being used consistently and whether it is having a measurable impact on offending.
Looking ahead, there are concerns that the problem could worsen if regulatory frameworks fail to adapt quickly to new challenges. Changes in legislation often create opportunities for new scams, as non-compliant services emerge to exploit confusion, gaps in enforcement, or those seeking a cheaper service. Rising landfill tax rates, or the removal of lower-rate categories, may incentivise operators to seek cheaper but illegal disposal methods. Similarly, bans on certain materials going to landfill could unintentionally drive-up costs and open new opportunities for criminal operators to profit. Anticipating these risks and preparing enforcement systems to deal with them will be essential to prevent future escalation of waste crime.
To address waste crime effectively, the EA and the Joint Unit for Waste Crime require greater and sustained funding. Both bodies are tasked with preventing and tackling illegal dumping, fly-tipping, and large-scale organised waste crime, misclassification and illegally operating permitted and exempt facilities, yet they are often constrained by limited resources. By increasing ringfenced funding, these organisations can expand their monitoring capacity and improve intelligence gathering.
Because waste crime is often linked to organised crime gangs, which operate across local and regional boundaries tackling these groups requires easier and more structured collaboration between regions and agencies. A more joined-up approach would allow intelligence sharing, coordinated enforcement actions, and targeted disruption of criminal networks. By making regional collaboration smoother and better resourced, authorities can prevent organised groups from exploiting gaps between jurisdictions and operating with impunity.
Enforcement also needs to be strengthened to act as a genuine deterrent. Waste crime often flourishes because perpetrators believe the risks are low and the rewards are high. Some Councils have begun making action more visible to the public in innovate campaigns such visibly designating fly-tipping incidents as crime scenes with police-tape and incident boards. Greater publicity of arrests, prosecutions and fines by authorities can send a clear signal that such behaviour is a crime and will not be tolerated. it is also important for the court system to understand the nature of waste crime and its impact and the range of powers that the court has to impose tougher fines and stronger penalties is important. When enforcement is both visible and consequential, it shifts the cost-benefit calculation for those considering illegal activity.
Finally, public awareness must play a key role in tackling waste crime. Many individuals and businesses unknowingly contribute to the problem by using unlicensed operators or failing to dispose of waste responsibly. Funding for awareness campaigns would help to educate the public on how to identify legitimate services, understand the consequences of waste crime, and play an active role in prevention. The introduction of Digital Waste Tracking is an opportune moment to make the public and businesses aware of their obligation, and ability, to ensure that their waste is being managed properly. It must also be straightforward for members of the public to report waste crime
Case Study – Organised Crime Units, theft of customer containers in Yorkshire
In the past 12 months, 20 waste containers have been stolen from Biffa customer across Yorkshire, one of multiple hotspots for organised crime operations. The waste within the containers usually fly- tipped, often in public spaces, highways, and areas of natural beauty. The empty containers are then sold for a profit at auction, or in some instances used to transport stolen items, such as cars. This is not an issue exclusive to Biffa, nor to Yorkshire; waste services providers locally and across the UK are victims of the same crime.
We understand that offenders are using vehicles without legal registration plates, lacking MOT certification and insurance. These actions not only violate multiple laws but also pose significant safety risks to the general public, road users, and our customers.
In the 2023/24 financial year alone, Biffa experienced 102 container thefts across the UK. The direct cost of replacing stolen containers exceeded £800,000. For local authorities, the wider cost of responding to fly-tipping is estimated at over £1 billion annually. Alarmingly, fly-tipping incidents have increased by 20% in the past five years, suggesting that these costs will continue to rise. Of greater concern is the increasing likelihood that the reckless and illegal transport of these containers could lead to a serious incident or injury.
We have been in discussion with police forces across the region and other waste management companies, including Veolia and Suez to address the issue collaboratively. To date we have, with the support of South Yorkshire Police, had just one container returned. Using GPS location data from a tracker attached to the container, a site was identified and accessed, enabling the container to be retrieved. Despite reports being made by Biffa and our customers, there has been no progress on any of the cases.
08/09/2025