What the New Street Works UK Protocol Means for WM3 Waste Classification

For organisations involved in street works and other reactive excavation activities, waste classification is a complex and time-critical part of project delivery. Until recently, many organisations operated in line with RPS 298, a Regulatory Position Statement which set out circumstances where excavated material from street and utility works could be temporarily moved prior to full waste classification under WM3.

At the end of September 2025, RPS 298 was formally withdrawn by the Environment Agency and replaced by the Street Works UK Material Classification Protocol. This new protocol provides important instruction on how classification decisions should be evidenced, and clarifies that excavated material must be appropriately classified before disposal routes are determined. Understanding the practical implications of this change is essential for avoiding project delays or compliance issues.

What Has Changed?

Under defined conditions, RPS 298 set out circumstances in which excavated material could be removed from site and temporarily stored at a suitable location prior to undergoing full laboratory testing and classification. This was particularly relevant for reactive or emergency works, where excavated material often needs to be cleared and removed within tight operational timeframes.

However, since the withdrawal of RPS 298 that specific regulatory position no longer applies. In its place, the Street Works UK Material Classification Protocol clearly states that waste classification must form part of the decision-making process before excavated materials are moved, reused, treated or disposed of. In practical terms, this means classification decisions need to be considered earlier in the project lifecycle, supported by documented and site-specific evidence.

Practical Implications

Bringing classification earlier into the project lifecycle has clear operational consequences for site managers and those overseeing waste management decisions. Most notably, waste assessment must now be integrated into project planning from the outset, rather than addressed later in the delivery process.

In practice, organisations should anticipate a greater reliance on representative sampling and laboratory testing to support WM3 assessments. Testing turnaround times will therefore become more closely aligned with excavation schedules, influencing programming decisions and site logistics. In addition, greater emphasis is now placed on demonstrating that classification decisions are supported by site-specific evidence, rather than relying primarily on historic or contextual information.

These changes also have implications for procurement and budgeting. Waste classification is something that determines permissible disposal routes, the type of facility that can accept the waste, and the associated transport and treatment costs. Because hazardous and non-hazardous classifications involve different pricing structures and documentation requirements, project forecasts and subcontractor arrangements are directly influenced.

How Envirochem Can Help

As waste classification becomes more closely integrated with project planning and disposal decision-making, access to fast, accurate analytical data is essential for organisations involved in street and utility works.

Envirochem supports clients across highways and utilities sectors as an experienced provider of WM3-compliant waste classification and Waste Acceptance Criteria (WAC) testing, with all laboratory analysis carried out by our UKAS-accredited testing laboratory (No. 1227). Whether you are assessing excavated soils or construction materials, our testing supports decisions on suitable disposal routes and landfill acceptance.

Additionally, our team can help you define an appropriate testing plan based on site history and anticipated waste streams. We’ll also help interpret results in the context of project needs, supporting decisions that surround waste handling, transport, and disposal. This insight is especially valuable where waste classification informs procurement, budgeting, and disposal planning.

If your organisation is reviewing its waste management approach following the withdrawal of RPS 298, our team can provide the laboratory support and technical guidance you need. Learn more about our waste classification testing services or contact our team to discuss your requirements.