Regulatory Decision 012.1: Use of end of life vehicles (ELVs) and other wastes within training exercises, teaching activities and public awareness displays

This Regulatory Decision (RD) is valid until 31 May 2026 by which time it will be reviewed. You should check back at that time to ensure the RD is still valid.

NRW can withdraw or amend this RD before the review date if we consider it necessary. This includes where the activity that this RD relates to has not changed.

Regulatory Decision

This RD does not change your legal requirement to obtain an environmental permit for a waste operation when you use end of life vehicles (ELVs) and other waste for:

• training exercises
• teaching activities
• public awareness displays

This RD applies to the:

• Category 1 responders as defined within Schedule 1 of the Civil Contingencies Act 2004
• armed forces
• training providers working on behalf of the above (category 1 responders and armed forces)

It applies to using ELVs and other wastes for:

• training exercises
• teaching activities
• public awareness displays

The uses include:

• cutting or burning ELVs (or both)
• locating and disarming hidden explosives in ELVs
• discharging firearms into ELVs
• live fire scenarios in buildings planned for demolition
• creating crime investigation scenes
• creating fire investigation scenes
• controlled explosions of ELVs

If you cannot comply with the conditions in this RD, you need to apply for an environmental permit.

Conditions you must comply with 

You must:

• make sure that you obtain the ELV or waste electrical and electronic equipment (WEEE) that you use from an authorised treatment facility (ATF), a local authority or waste management company managing waste facilities on behalf of a local authority.
• make sure that you return the waste to an ATF or regulated waste facility as soon as is practicable after use.
• make sure anyone transporting the waste is a registered waste carrier.
• make sure that any transfer of non-hazardous waste is accompanied by a Waste Transfer Note and any transfer of hazardous is accompanied by a Hazardous Waste Consignment Note. Note: we do not require a hazardous waste return from the place at which the waste is received for the training exercise, teaching activity or public awareness display.
• store or use ELVs that have not been depolluted on an impermeable pavement with a sealed drainage system – this does not include vehicles that only retain shock absorbers, air bags or batteries essential for the activity, but are otherwise depolluted.
• use the minimum amount of waste and least polluting waste types for your activities.
• keep records for 3 years to show that you have complied with this RD and make these records available to the NRW on request.

You must not store or use any ELV that has not been depolluted in scenarios that involve burning the vehicle or releasing fluids. This does not include vehicles that only retain shock absorbers, airbags, or batteries essential for the activity but are otherwise depolluted.

Should you wish to use ELVs that retain shock absorbers, airbags, or batteries in scenarios that involve burning of the ELV or releasing fluids you must produce a written risk assessment for the activity taking into account pollution risks and mitigation measures which will be in place. This written risk assessment must be made available to NRW if requested.

You must not use any wastes containing ozone depleting substances or fluorinated gases, for example air conditioning gases in ELVs and refrigerant gases in freezers and refrigerators.

Enforcement

This RD does not change your legal requirement to have an environmental permit for a waste operation when you are using ELVs and other wastes within training exercises, teaching activities and public awareness displays and to comply with the hazardous waste regulations where it concerns consignee returns.

However, NRW will not normally take enforcement action if you do not comply with the need for an environmental permit or the need for hazardous waste consignee return submissions if you meet the requirements in this RD.

In addition, your activity must not cause (or be likely to cause) pollution of the environment of harm to human health, and must not:

• cause a risk to water, air, soil, plants or animals
• cause a nuisance through noise or odours
• adversely affect the countryside or places of special interest