Miguel Varela AssocMCIWM, founder of TEIMAS, explains why waste traceability is crucial if the world is going to transition to a circular economy.
The UK’s waste management system is undergoing a far-reaching structural transformation that calls for a rethink of the producer’s role, traceability, and the value of materials within a circular economy.
Few things are as revealing as waste. It tells us more about a country, a company, or an economy than any strategic plan or sustainability statement.
What we discard, where we dispose of it, and who ultimately ends up dealing with it, speaks not only of consumption and waste, but also of power, global asymmetries, and who truly pays “the price” for what others produce.
In the UK, as in other countries in the Global North, waste management has been increasingly characterised by the outsourcing of refuse. The case of plastics is particularly telling. At present, the UK sends abroad around 60% of its plastic waste, making it the third largest exporter worldwide, behind only Germany and Japan.
In 2023 alone, England exported just over 600,000 tonnes of plastic waste. Over a quarter of that volume was sent to Turkey, a country with a recycling rate of barely 12%, the lowest among OECD members.
Added to this is a 2021 report by Greenpeace, which documented how much of this British waste ended up dumped, burned, or stockpiled in illegal landfills, far removed from any semblance of a recycling loop.
This is why, when we speak of producer responsibility, we are not dealing with a merely technical or environmental issue. We are speaking of who bears the consequences of decisions made long before a product ever reaches a consumer’s hands, and whether the environmental and social costs are truly accounted for within the business model, or simply externalised – as has historically been the case.
This approach forces us to ask who controls the fate of waste, and what legal and economic mechanisms are (or aren’t) compelling producers to take responsibility for the waste generated by the goods they place on the market.
Traceability, then, ceases to be a mere bureaucratic exercise and becomes a matter of structural transparency – and responsibility can no longer be subcontracted.
From waste to resource
The circular economy is a structural necessity in a world that has already exceeded several of its planetary boundaries. Recognising that waste is not a cost but a secondary raw material marks a profound shift in how we understand production, consumption, and corporate responsibility.
In 2020, the UK generated 40.4 million tonnes of commercial and industrial waste, with landfill being the second most common destination for the total volume of waste. This is in the context of critical material shortages and the growing awareness that import dependency is a strategic vulnerability.
On top of this, the Environment Agency estimates that over 34 million tonnes of waste are handled illegally each year, costing the UK economy £1 billion annually. Under the new legislation, illegal operators caught transporting or managing waste unlawfully could face prison sentences of up to five years.
These figures are compounded by the findings of the Circularity Gap Report 2025, which shows a steady global decline in circularity – from 9.1% in 2018 to just 6.9% in 2025.
In other words, rather than closing the loop, we’re opening it wider. We’re extracting more virgin resources and losing more value at every stage of the cycle. Can we achieve meaningful circularity without traceability? I don’t believe so.
Given the environmental impact of waste and the need to optimise resource use, it’s no surprise that an increasing number of regulations centre around its proper management and the accountability of those who produce and handle it.
This is where the concept of ‘duty of care’, or more specifically, the Waste Duty of Care, comes in. It is the legal obligation of producers to know where their waste is going and to ensure that the individuals or businesses they hire to collect and manage it are operating within the law and sending it to licensed facilities for disposal, treatment, or recycling.
Fulfilling the duty of care, then, should not be seen as a regulatory burden, but as a tool for systemic transformation. To trace waste is to trace responsibility, and, with that, to reduce impact and maximise material efficiency.
Digital traceability: The new language of transparency
From April 2026, mandatory digital waste tracking will become a reality in the UK. Introduced by the UK government as part of its strategy to transition towards a more circular economy, this measure aims to modernise waste management and transform how environmental responsibility is regulated, monitored, and understood.
For the first time, there will be a unified, real-time system capable of revealing what waste is generated, who handles it, what is done with it, and where it ends up. This new obligation rewrites the rules of the game.
It narrows the space for opacity, curbs illegal practices (such as unauthorised exports or fly-tipping), and creates a more level playing field for legitimate operators. It’s worth remembering: waste trafficking is no minor matter as it generates an estimated $12 trillion annually worldwide.
With this mandatory digital tracking system, traceability becomes a legal requirement. Companies must adopt technological solutions that not only ensure regulatory compliance but also help optimise their operations so that this shift doesn’t become a barrier to competitiveness.
But how can a producer ensure that its waste has been properly treated? The challenge is significant because traditionally, responsibility for waste ends at the producer’s door.
To ensure true accountability, it’s essential that waste-producing companies implement systems that include appropriate monitoring and control measures to prevent irregularities.
These must be proportional to the company’s operations, activities, suppliers, actions, and documentation. In other words, they must establish procedures for risk tracking and control, both internally and externally.
- Raise awareness of waste: for example, by creating a comprehensive database of all waste streams produced, and using systems that enable tracking, monitoring, and auditing.
- Measure and verify: using waste data and key performance indicators (such as zero waste to landfill or reduction percentages) to progress towards corporate environmental goals.
- Establish mechanisms for traceability control: both within company sites and beyond, generating and storing evidence of waste movements all the way through to final treatment.
Ultimately, the policy of ‘out of sight, out of mind’ when it comes to waste is neither ethical nor legal. The real question is: do we genuinely want to move towards a circular economy in which we stop seeing waste as a problem and start recognising it as a resource opportunity?
The answer is clear: take responsibility for your waste.
The post Riders of the lost trash: Waste traceability and responsibility appeared first on Circular Online.