Running a biogas or anaerobic digestion plant means managing feedstock inputs from multiple sources, tracking digestate through to agricultural application, and maintaining accurate records across every movement. From October 2026, all permitted waste receiving sites — including AD facilities — must record waste movements digitally. This guide covers everything operators need to know.
Anaerobic digestion facilities sit at the intersection of waste management, energy production, and agriculture. Every tonne of feedstock entering the plant — whether food waste, agricultural residues, or industrial by-products — must be documented with a Waste Transfer Note or Season Ticket. Every batch of digestate leaving the site must be tracked. And from October 2026, all of this must feed into the national Digital Waste Tracking system.
The combination of high volumes, multiple feedstock types, multiple regulatory frameworks (environmental permitting, ABP regulations, digestate quality standards), and now mandatory DWT makes paper-based compliance increasingly untenable for any commercially-operated facility.
Multiple feedstock sources
Food waste from restaurants, agricultural residues, industrial by-products — each with different EWC codes and potentially different ABP documentation requirements.
Digestate management
Tracking digestate from production through storage to agricultural application, with different documentation depending on whether it holds PAS 110 certification.
High transaction volumes
A commercial AD plant processing 50,000 tonnes per year may record 2,000+ individual feedstock deliveries. Manual processes cannot reliably handle this at scale.
ABP regulation overlay
Plants processing catering waste containing meat require APHA approval and Category 3 ABP pasteurisation, adding documentation requirements on top of standard waste tracking.
AD plants in the UK operate under an overlapping set of regulatory requirements. Understanding which apply to your facility is the starting point for building a compliant waste tracking system.
All AD plants require either an environmental permit or a registered exemption. The level of permitting depends on the plant's size and accepted waste types:
| Permit type | Capacity | Key requirements |
|---|---|---|
| T24 / T25 Exemption | Up to 1,250 m³ (T24) or 50 m³ (T25) | Register with the Environment Agency. Restricted to specific non-hazardous waste types. No animal by-products without approval. |
| Standard Rules Permit | Up to 75,000 tonnes / year | SR2021 No.6/7 or SR2012 No.12 compliance. Detailed record-keeping and quarterly reporting. Weighbridge mandatory at this scale. |
| Bespoke Permit | No upper limit | Site-specific permit conditions. Higher regulatory scrutiny, more frequent inspections. Custom waste acceptance criteria. |
Under Section 34 of the Environmental Protection Act 1990, AD plants as receiving sites must:
If your plant processes any animal by-products — including catering waste containing meat — you need approval from the Animal and Plant Health Agency (APHA). This adds documentation requirements on top of standard waste tracking:
Category 2 ABPs — e.g. Manure, digestive tract content
Can be used as raw feedstock without processing in many circumstances, but must be clearly documented.
Category 3 ABPs — e.g. Catering waste, food processing waste containing meat
Must be pasteurised to approved standards. Plant must hold APHA approval. Separate commercial documents may be required alongside WTNs.
Every feedstock delivery to an AD plant must be recorded with a Waste Transfer Note or, for regular suppliers, a Season Ticket and docket. As the receiving site, the AD plant is responsible for checking and signing the note, verifying the carrier's registration, and confirming the waste matches the description.
The WTN for a feedstock delivery must contain:
Producer details
Carrier details
Waste description
Transfer details
Using the correct EWC code on every WTN is a legal requirement. The table below covers the codes most commonly encountered at biogas and AD plants:
| EWC code | Description | Typical source |
|---|---|---|
| 02 01 03 | Plant tissue waste | Farms, crop processing |
| 02 01 06 | Animal faeces, urine and manure | Farms, livestock operations |
| 02 02 03 | Materials unsuitable for consumption or processing | Meat and fish processing |
| 02 03 04 | Materials unsuitable for consumption or processing | Fruit, vegetables, cereals, cooking oils |
| 02 06 01 | Materials unsuitable for consumption or processing | Dairy industry |
| 19 06 04 | Digestate from anaerobic treatment of municipal waste | Output from municipal AD plants |
| 19 06 06 | Digestate from anaerobic treatment of animal and vegetable waste | Output from food/farm AD plants |
| 20 01 08 | Biodegradable kitchen and canteen waste | Commercial kitchens, restaurants, schools |
| 20 01 25 | Edible oil and fat | Restaurants, caterers, food manufacturers |
For the complete searchable list of EWC codes, use the EWC code lookup tool. Codes ending with an asterisk (*) denote hazardous waste — if a feedstock carries a starred code, a Hazardous Waste Consignment Note is required rather than a standard WTN.
Digestate is initially classified as waste under UK law and must be tracked accordingly when transferred from the AD plant. Its status — and therefore the documentation required — depends on whether it holds PAS 110 certification under the Anaerobic Digestate Resource Framework.
Digestate without PAS 110
PAS 110 certified digestate
For digestate applied to agricultural land that does not hold PAS 110 certification, the transfer to the farmer requires a WTN with EWC code 19 06 06 and recovery code R10 (land treatment resulting in agricultural benefit). The farmer's details and the receiving land details must be recorded.
For an AD plant receiving weekly or daily deliveries from the same supplier — a supermarket food waste contract, a dairy operation, or a food manufacturer — completing a full WTN for every delivery is unnecessary. A Season Ticket covers all collections of the same waste type from the same producer by the same carrier for up to 12 months.
Each delivery under a Season Ticket still requires a simple docket recording the Season Ticket reference number, date, and quantity. Dockets require no additional signatures and take around 30 seconds to complete. For a plant receiving daily deliveries from a single supplier, this reduces 365 full WTNs to one master document and 365 brief dockets.
Season Ticket conditions — all three must apply:
If any of these changes — a different carrier on a particular day, a different waste stream — an individual WTN is required for that delivery.
For the full Season Ticket workflow including how to handle dockets, see the WTNs vs Season Tickets guide.
Most commercial AD plants use weighbridges to measure feedstock on arrival and digestate on departure. Without integration between the weighbridge and the waste tracking system, operators face a manual data transfer problem:
For a plant processing 50,000 tonnes annually, that represents roughly 2,000+ weighbridge tickets to manually reconcile per year. Each manual step introduces error risk, and lost or illegible tickets can create compliance gaps.
Weighbridge
Exports CSV file
Watch folder
Auto-detected
Sync Agent
Maps fields
Import Hub
Review & approve
WTN created
Audit-ready
WasteBolt's Sync Agent automates the entire process. Your weighbridge exports a CSV file to a designated folder; the Sync Agent detects it within seconds and maps columns to WTN fields using your pre-configured template. Records appear in the Import Hub for review and approval, with duplicate detection preventing the same ticket being imported twice.
Compatible weighbridge systems
As permitted waste receiving sites, all AD plants fall within Phase 1 of the mandatory DWT rollout. The specific obligations are:
October 2026 — England, Wales, and Northern Ireland
Action requiredAll incoming waste movements must be recorded on the DEFRA Digital Waste Tracking service. Paper WTNs are no longer valid for these movements once the mandate applies. The system must be used for every feedstock delivery.
January 2027 — Scotland
Action requiredScottish AD plants follow with a three-month delay. SEPA will enforce compliance from this date.
October 2027 — Carriers, brokers, and dealers
The feedstock suppliers and carriers delivering to your plant face their own mandatory deadline. By this point, the full digital chain — producer records, carrier records, and receiving site records — must all be submitted digitally.
Register for the public beta voluntarily
The DWT public beta is available now for permitted receiving sites. Participating before the mandate means your team learns the system without a compliance deadline hanging over the process.
Audit your current waste records
Review all current WTNs for completeness and accuracy. Identify gaps — missing carrier registration numbers, vague waste descriptions, incorrect EWC codes. DWT will expose these issues at scale.
Switch feedstock records to digital now
Every week you continue on paper is another week of records not in a DWT-compatible format. Digital WTNs created on a compliant platform already produce structured data that maps to DWT requirements.
Configure weighbridge integration
High-volume plants cannot manually enter DWT records for every load. Weighbridge integration should be set up and tested well before the October 2026 deadline.
Choose software with an active DWT API roadmap
DEFRA is building an API that allows approved software to submit DWT data directly, avoiding manual government portal entry. Ask any software provider you are evaluating about their API integration timeline.
For the full DWT timeline and preparation guide applicable to all waste businesses, see How to Prepare for Mandatory Digital Waste Tracking 2026.
Do biogas plants need to comply with mandatory Digital Waste Tracking?
Yes. AD plants are permitted waste receiving sites and fall within Phase 1 of the DWT mandate. From October 2026 in England, Wales, and Northern Ireland (January 2027 in Scotland), all incoming waste movements must be recorded digitally on the DEFRA DWT system.
What waste records must a biogas plant keep?
Records of all feedstock inputs (waste description, EWC code, weight, producer, carrier, date/time), digestate outputs (with PAS 110 status noted), rejected loads and their disposal routes, and ABP documentation where applicable. Records must be retained for a minimum of two years in England, Wales, and Northern Ireland, and three years in Scotland.
Which EWC code covers feedstock entering an AD plant?
It depends on the feedstock type — the table in this guide covers the most common codes. The recovery code on the WTN is always R3 for waste going into anaerobic digestion, and R10 for PAS 110-uncertified digestate transferred to agricultural land with benefit.
Is digestate classified as waste?
Yes, unless it has achieved end-of-waste status through PAS 110 certification under the Anaerobic Digestate Resource Framework. Without certification, every digestate transfer requires a WTN with EWC code 19 06 04 or 19 06 06. With PAS 110 certification, it is a product and waste controls no longer apply.
Can I use Season Tickets for regular feedstock deliveries?
Yes, provided the same waste type is delivered by the same carrier from the same producer every time. A Season Ticket covers all deliveries for up to 12 months, with a brief docket for each individual load. If any of those three conditions changes for a particular delivery, an individual WTN is required for that load.
What ABP documentation is required alongside WTNs?
For Category 2 ABPs (manure, digestive tract content), standard WTNs are generally sufficient but check your permit conditions. For Category 3 ABPs (catering waste containing meat, food processing waste), you need APHA plant approval, evidence of pasteurisation to approved standards, and commercial documents that may be required in addition to WTNs. Consult APHA directly for your specific feedstock mix.
Can I integrate my weighbridge directly with WasteBolt?
Yes. WasteBolt's Sync Agent imports CSV exports from any weighbridge system — including Globeweigh, Avery Weigh-Tronix, Rice Lake, Mettler Toledo, and Fairbanks — and maps them to WTN fields automatically. Records appear in the Import Hub for review and approval before being committed.
Related guides
WasteBolt
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