The Environment Agency says it has identified a dramatic rise in the scale and complexity of fraud in the waste export industry in the last three years – with criminals falsely claiming to have exported packaging waste that either never existed, was not UK sourced or had already been the subject of a claim, with total waste crime costing the UK economy an estimated £1 billion each year.
Packaging Export Recycling Notes gives waste exporters evidence that they have met their legal recycling obligations, however, rogue operators exploit the system by falsifying documents, undermining legitimate businesses. The result of this is that illegal waste ends up being exported out of the UK and is often dumped in locations overseas where it harms the environment.
As the waste regulator in England, the Environment Agency is determined to make life harder for criminals and their professional enablers through enforcement action and prosecution.
Evidence has been found of sophisticated and established money laundering networks set up to receive not only the proceeds of Packaging Export Recycling Note fraud but monies from benefit fraud, VAT fraud and acquisitive crime. Such criminality is not only based in the UK as criminal networks extend across international boundaries.
Robust action is being taken by the Environment Agency. During 2024, working together with the North West and Yorkshire and Humber Regional Organised Crime Units and police forces across England, 17 individuals have been arrested for fraud and money laundering. In May 2024 after a proactive operation, a suspect was arrested as he entered the United Kingdom from Spain at Birmingham International airport.
Account Freezing Orders have already led to the forfeiture of £665,000. Further restraints of assets are currently under consideration and upon any conviction, confiscation procedures under the Proceeds of Crime Act will be initiated.
A dedicated team of experienced and skilled investigators has been increased four-fold in numbers to tackle this challenge and has been complemented by the Environment Agency’s own Economic Crime Unit staffed by Accredited Financial Investigators, Intelligence Officers and money laundering experts.
Jon Ashcroft, Producer Responsibility Regulatory Services Operations Manager at the Environment Agency, said:
“Waste crime has an extremely harmful impact on our environment and the Environment Agency is determined to crack down on it, working with law enforcement agencies to disrupt organised crime, arrest suspects and secure convictions.
“Our investigations target the criminals committing fraud as well as those involved in the facilitation of offending. If you are involved, the likelihood is that our law enforcement partners will be knocking on your door soon.”
Strong relationships with domestic and foreign authorities are key to this effort, with evidence collected from waste reprocessing sites across the world being vital intelligence for our teams. For example, EA investigators were recently deployed to Vilnius, Lithuania to gather evidence as part of an ongoing investigation in collaboration with the Lithuanian Department of Environmental Protection.
Prevention and disruption are integral in the fight against organised crime and fraud. Refusing high risk applications is a valuable tool, preventing fraud and the unlawful acquisition of Packaging Export Recycling Note revenue.
In 2023 the Agency received 435 applications for accreditation and approved 386. Over 3 times more applications were refused and withdrawn in 2023 compared to 2022. This trend continues into 2024 with 10 ‘in year’ applications refused so far.
If you suspect someone is operating in a fraudulent manner, the EA asks you to contact ProRes_InvestigationTeam@environment-agency.gov.uk or anonymously at Crimestoppers.
