The Scottish Environment Protection Agency (SEPA) has published an interim position statement on the storage and reuse of waste paint which clarifies how these activities should be regulated.
Storage and beneficial use of non-hazardous waste paint is normally an exempt activity under the Waste Management Licensing Regulations. Community groups who store waste paint for reuse are required to register their exemption with SEPA in a simple, one-off registration which can be done online and free of charge.
The mixing of waste paints for reuse is not currently exempt from waste management licence requirements. However SEPA supports the reuse and wider benefits provided by these community activities and will not require not-for-profit organisations to hold a waste management licence for the mixing of non-hazardous waste paint. (The storage and mixing of waste paint that is labelled as hazardous, and is therefore special waste, is still a licensable activity.)
Maureen Menzies of RePaint Scotland said “This is welcome news indeed! It is not only a tremendous cost saving for RePaint Scotland but means we can go ahead and bulk up our recycled paint, as can those other organisations who want to top up half full tins, knowing that we are all compliant with SEPA regulations.”
Community groups who are unsure of whether their activities are affected by waste management licensing regulations should contact their local SEPA office for guidance.
A full review of waste management licence regulations and exemptions is being carried out by the Scottish Government and SEPA under the Better Waste Regulation Action Programme.