Muck away vs by-product: run the numbers once.
Take a mid-size Dublin basement scheme, roughly 35,000 tonnes of greenfield soil and stone off site. The same material, two legal routes, and a six-figure difference before anyone quotes a gate fee.
The two routes, side by side
Route A: leaves site as waste
| Waste recovery levy, 35,000 t × €10 | €350,000 |
|---|---|
| Facility gate fee | market rate |
| Haulage, ≈1,167 loads (30 t) | distance-dependent |
| Waste collection permits & facility authorisations | required |
Route B: registered by-product €0 levy
| Waste recovery levy (material is not waste) | €0 |
|---|---|
| Gate fee, delivered to a site that wants the fill | typically none |
| Haulage, matched nearby to cut distance | distance-dependent |
| EPA registration, standstill, SoC + EUD | prepared on-platform |
What a matched movement looks like
The by-product route needs a destination that wants the material. That is the marketplace half of ExchangeEarth: surplus matched to demand nearby, so the haul is shorter and the fill arrives certified, with the registration reference, Statement of Conformity and End User Declaration attached.
Straight questions
- Is the €350,000 figure real?
- It is the statutory levy arithmetic: 35,000 tonnes × €10 per tonne under S.I. 441/2024. Gate fees and haulage come on top of it and vary by facility and distance, which is why they are not quoted here.
- Doesn't the by-product route have costs of its own?
- Yes: the registration effort, the five-working-day standstill, per-load documentation, and finding a receiving site that wants the material. Those are process costs rather than per-tonne charges, and they are exactly what ExchangeEarth automates and matches.
- My muck-away contract already covers disposal. Does this still matter?
- The levy is inside your muck-away rate whether it is itemised or not, because facilities pass it through the gate fee. On the next tender, a by-product plan is the difference between pricing disposal and pricing haulage only.
- What about material that isn't greenfield?
- The national criteria route (BP-N002/2024) covers uncontaminated greenfield soil and stone. Other material can still move as a by-product through a single-case Article 27 notification, but the EPA must issue a determination first, which is a longer, case-by-case path.
General information, not legal advice. Statutory figures only; gate fees and haulage rates are quoted by operators.
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