BP-N002/2024: by-product registration, step by step.
The EPA's national by-product criteria let uncontaminated greenfield soil and stone move site-to-site as a product, not waste: no €10/t levy, no waste facility. Here is how the route actually works, and where the time goes.
At a glance
| Criteria reference | BP-N002/2024 |
|---|---|
| Published by the EPA | 2 July 2024 |
| Material | Greenfield soil & stone |
| EWC code | 17 05 04 |
| Registration reference format | N-BP-XXXX |
| Standstill before movement | ≥5 working days |
| EPA approval step | None, self-certified |
A batch, start to finish
The standstill, precisely
No movement for at least five working days from the date of registration. Registration day is day zero, and weekends and Irish public holidays don't count. The clock is the programme risk, so ExchangeEarth counts it for you and blocks dispatch until it has run.
Straight questions
- Does the EPA approve the registration?
- No. BP-N002/2024 is a self-certified registration route: the producer declares that the material and its use meet the national criteria, and the registration appears on the public register. Clearing the standstill is not an EPA approval. It means no enforcement direction was recorded before movement began.
- When does the five-day clock start?
- On the date of registration, not the date you started preparing it and not the date the EPA acknowledges anything. Working days exclude weekends and Irish public holidays. Registered on day one of the programme, the standstill is usually spent before the first load is due to leave.
- What if my material is brownfield or the use is different?
- BP-N002/2024 covers uncontaminated greenfield soil and stone only. Anything else goes the single-case route: a notification through EDEN's By-Product module (references ART27-nnnn), where the EPA must issue a determination. That typically takes a matter of weeks, so it needs programme planning.
- What paperwork travels with the material?
- Each load carries a per-load reference under the registration (N-BP-XXXX-1, -2, …) and must be producible at the roadside, and electronic form is expressly allowed. A Statement of Conformity accompanies the material and the receiving site provides an End User Declaration. Records are retained for at least five years.
- Does my haulier need a waste collection permit?
- Waste collection permits apply to waste. Soil and stone that genuinely meets the Article 27 by-product conditions and its BP-N002/2024 registration is not waste, so on the statutory text the permit requirement in section 34 of the Waste Management Act 1996 does not apply to moving it. Two cautions. First, no regulator has published guidance confirming this, and by-product status depends on the facts of each batch. Registration records your assessment of the batch; it does not guarantee it. Second, if a batch turns out not to meet the criteria, it is waste, and transporting waste without a collection permit is a serious offence. That is why ExchangeEarth verifies third-party hauliers' collection permits before dispatch even though we do not believe a permit is legally required for a conforming by-product load, and why many producers choose permit-holding hauliers regardless. This is general information, not legal advice on any particular movement.
General information, not legal advice. Read the criteria in full on the EPA site before relying on them.
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