Introduction

Proper waste classification is essential for regulatory compliance, cost-effective disposal, and minimising environmental harm during development. In New South Wales (NSW), environmental consultants follow strict EPA guidelines to categorise waste based on its composition, contamination levels, and potential risk.

This article answers five commonly asked questions about how environmental consultants classify waste in NSW and what it means for your project.

What Is Waste Classification and Why Does It Matter?

Waste classification is the process of assessing and assigning waste to a regulated category based on its physical and chemical characteristics. It matters because:

• It determines whether waste can be reused, recycled, or must be sent to landfill
• Incorrect classification can lead to EPA penalties, delays, or illegal disposal
• It affects transportation requirements, disposal fees, and landfill acceptance criteria
• It is mandatory under the NSW EPA’s Waste Classification Guidelines (2021)

For developers and consultants, correct classification ensures that waste is handled safely, cost-effectively, and in accordance with environmental legislation.

What Are the Main Waste Categories in NSW?

The NSW EPA outlines six core waste categories:

• Virgin Excavated Natural Material (VENM) – clean, natural materials like clay, gravel, sand
• Excavated Natural Material (ENM) – similar to VENM but may contain minor contamination, approved for reuse
• General Solid Waste (non-putrescible) – low-risk, stable waste such as bricks, glass, or contaminated soil with low levels of pollutants
• General Solid Waste (putrescible) – includes organic material prone to decay, such as food scraps
• Restricted Solid Waste – contains contaminants above general solid waste thresholds but below hazardous levels
• Hazardous Waste – poses significant risk to health or the environment; includes asbestos, lead-contaminated soil, or industrial chemicals
  

Understanding which category applies determines the sampling method, required documentation, and disposal options.

If you're interested in learning more about Soil & Waste Classification, visit our dedicated page here.

How Do Consultants Assess and Classify Soil Waste?

Environmental consultants use a structured approach based on the NSW Waste Classification Guidelines (Part 1: Classifying Waste):

1. Preliminary Assessment – review of site history and likely contaminants
2. Sampling Plan – representative soil samples collected following EPA guidelines
3. Laboratory Analysis – samples tested for contaminants such as heavy metals, hydrocarbons, asbestos, or PFAS
4. Comparison with Thresholds – results measured against leachable and total concentration thresholds in the guideline tables
5. Final Classification – waste category assigned and supporting documentation prepared

For example, soil exceeding leachable concentration thresholds for arsenic or petroleum hydrocarbons may be classified as restricted solid waste, even if it appears inert.

What Happens Once Waste Is Classified?

Once waste is classified, consultants assist in managing disposal:

• Waste tracking documentation is prepared (using EPA’s WasteLocate where required)
• Transporters and facilities are selected based on the approved category
• Validation reporting may be completed for contaminated sites to demonstrate compliance
• Landfill or reuse options are evaluated to minimise cost and environmental impact

In some cases, treated or stabilised waste may be reclassified for beneficial reuse under a resource recovery order.

Are There Penalties for Incorrect Waste Classification?

Yes. Failing to classify waste properly can result in:

• EPA compliance actions or environmental protection notices
• Fines for illegal dumping or transporting waste without correct paperwork
• Project delays due to non-compliant disposal practices
• Loss of development approval in sensitive sites or rezoning areas

Engaging qualified environmental consultants helps mitigate these risks and ensures full compliance with the Protection of the Environment Operations Act 1997.

Partner With Experts in Waste Classification and Disposal

At Raw Earth Environmental, we work closely with developers, civil contractors, and project managers to streamline waste classification and ensure EPA-compliant outcomes. Our consultants provide fast, accurate waste assessments to keep your project on track and aligned with best practice.

Speak to our team about compliant waste classification.