SWUK Protocol 2025: Overhauling Waste Classification in Street Works

Effective from 1 October 2025, the Street Works UK (SWUK) Material Classification Protocol replaces Regulatory Position Statements (RPS) 298 and 299.

Developed in collaboration with the Environment Agency, this protocol introduces a risk-based, standardised approach to managing excavation waste from street and utility works across the UK. Its aim is to improve accuracy, traceability, and regulatory compliance.

Why the Change?

RPS 298 and 299 allowed operators to manage excavation waste without full pre-sampling, acknowledging the unpredictable nature of emergency and unplanned works. However, this flexibility led to inconsistent practices and regulatory challenges.

The new protocol addresses these issues by standardising procedures, enhancing environmental oversight, and aligning with UK waste legislation.

Key Requirements

Operators are now required to conduct pre-excavation risk assessments using the SWUK format. These assessments must consider historical land use, local geology, and potential contamination risks, and must be recorded in the Street Manager system.

Waste materials such as soils, asphalt, and sub-base must be segregated to prevent cross-contamination. Additionally, at least 1% of all excavations must undergo laboratory testing annually. If discrepancies are found between field assessments and lab results, this testing rate may increase to 3%.

Quarterly reporting is mandatory, with data submitted to SWUK and logged in Street Manager. Persistent non-compliance could lead to removal from the scheme. The Environment Agency will oversee classification accuracy and may intervene if standards are not met.

The protocol applies to immediate, minor, and standard works, as well as some major works under the New Roads and Street Works Act (NRSWA). Even in emergency situations, a desktop risk assessment must be completed before excavation begins.

Legal Status and Enforcement

Although not legally mandatory, the SWUK Protocol is endorsed by the Environment Agency as a compliant method for managing waste when pre-removal sampling is impractical. Alternative classification methods may be used, but they must fully comply with WM3 (Waste Classification Technical Guidance) and other UK waste regulations.

Importantly, if the SWUK Protocol is followed correctly and all conditions are met, without causing pollution or harm to health, the Environment Agency generally will not take enforcement action, even if full WM3 compliance is not achieved.

Whilst operators may initially face increased costs due to testing and reporting, potential delays from disputed classifications, and the need for new training and procedural updates, the protocol also presents opportunities: improved staff competence, stronger compliance records, potential cost savings through material reuse, and better collaboration with accredited laboratories.

Next Steps for Compliance

To prepare, operators should review and update their internal waste classification procedures, train staff on the SWUK Protocol and Street Manager, engage accredited laboratories for sampling and validation, and ensure accurate and timely data reporting to SWUK.