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Home Features BAA: Landfill Tax consultation is a crucial moment for our industry & the circular economy

BAA: Landfill Tax consultation is a crucial moment for our industry & the circular economy

by Guy Woodford
June 9, 2025
in Europe, Features
Reading Time: 7 mins read
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Mike Phillips, CEO of British Aggregates Association. Image/BAA

Mike Phillips, CEO of British Aggregates Association. Image/BAA

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The British Aggregates Association (BAA) is urging industry professionals to have their say during a consultation on potential reform of the Landfill Tax. The BAA states…

The current HM Treasury consultation on Landfill Tax, which commenced on 28 April 2025, may appear to be a technical policy review. Still, for those of us working in mineral extraction, reprocessing, and construction, it is a turning point with real consequences for our operations, costs, and the UK’s broader sustainability ambitions.

As professionals working with primary and secondary aggregates, we have a deeper understanding of the complex lifecycle of construction materials than most. Every tonne extracted, processed, reused, or disposed of plays a role in the supply chain that supports all parts of our homes, roads,  schools, and infrastructure. This consultation proposes changes that could inadvertently disrupt that chain for the long term.

The risk: cost rises and unintended consequences

If implemented without a thorough understanding of the potential outcomes, the proposed tax reforms could result in substantial cost increases for managing materials, including those that are by-products of legitimate and often environmentally beneficial recycling or mineral operations. These increased costs risk driving up prices across the construction sector, including in areas already under intense affordability pressures such as housebuilding and infrastructure delivery.

Worse still, this added financial pressure could tip waste producers toward illegal or unregulated routes. A spike in fly-tipping and the use of non-compliant disposal sites is a genuine threat, not just to the environment, but to the reputation of our industry and the enforcement capacity of public agencies.

Restoration and BNG delivery at risk

Mineral sites are also bound by long-standing planning conditions that require the import of inert materials for safe and beneficial restoration. These are not just environmental obligations, they are legal responsibilities that return worked land to community, conservation, or agricultural use.

Increasingly, these restoration schemes are being designed to meet Biodiversity Net Gain (BNG) requirements, as mandated by national planning frameworks and regulators. Achieving BNG typically involves significant regrading, capping, and profiling work, all of which rely on access to clean, inert materials. By imposing a single rate of landfill tax on all such materials, regardless of their end use, the government risks making BNG delivery prohibitively expensive or, in some cases, practically unachievable.

The BAA hosted a dedicated conference that brought together over 50 professionals from across the mineral supply chain. Image/BAA

This would be a significant counterproductive outcome,  undermining not only the credibility of environmental regulation but also the ability of our sector to contribute positively to landscape and habitat enhancement across the UK.

BAA at the forefront of engagement

The British Aggregates Association is playing a leading role in representing the sector’s voice in this consultation. Most recently, the BAA hosted a dedicated conference that brought together over 50 professionals from across the mineral supply chain, including producers, manufacturers of specialised plant and machinery, planning and permitting experts, and end-users.

This forum provided a vital opportunity to share perspectives, voice concerns, and ensure that real-world experience is reflected in the association’s response to government. The message from that event was clear, but there is strong industry support for environmental responsibility. However,  it must be underpinned by policy that is practical, proportionate, and encourages the use of secondary and recycled materials, and not penalises it.

Mike Phillips, CEO of the British Aggregates Association, said: “This review will have a significant impact not only on our vital sector, but on everyone who uses minerals in one form or another. I fully recognise the importance of recycling, reusing, and repurposing materials, which is essential to a modern, sustainable and environmentally responsible economy. But I urge the government to truly listen to the needs of our industry. By all means, impose higher fines and heavily penalise unlawful activities, but responsible, lawful operators must not be punished for doing the right thing. We need a system that supports good practice, not one that undermines it.”

The British Aggregates Association is playing a leading role in representing the sector’s voice in the Landfill Tax consultation. Image/BAA

Why this matters to the circular economy

The circular economy is not just a slogan; it’s a principle many of us are actively enabling through investment in reprocessing plant and machinery to enable diversion from landfill, and the development of secondary aggregates. We are transforming construction and demolition materials into high-value products for reuse.

It is in no one’s best interest to send recoverable, usable materials to landfill. This benefits neither the environment or the economy. The government and HM Treasury must recognise this and ensure that fiscal policy acts as an enabler of responsible material recovery and not as a barrier. By penalising material reuse or failing to distinguish between waste and resource, the current proposals risk setting us back at a time when momentum is building toward more sustainable, lower-carbon construction practices.

The danger is that an overly rigid tax regime could punish exactly the kind of innovation and environmental responsibility that government policy claims to support.

A call to action

The British Aggregates Association is urging all professionals involved in mineral extraction, construction, and materials management to engage with this consultation before it closes. Whether you’re an operator, contractor, consultant, or supplier, your voice matters. We need government to understand the operational realities and avoid policy decisions that could undermine environmental goals and commercial viability.

We also encourage those in planning and policy roles to consider the importance of materials to legal restoration obligations and BNG delivery, as well as the essential role of secondary materials in building a sustainable and affordable future.

Make your voice heard.

The consultation is open until 21st July 2025, and responses can be submitted via the HM Treasury website: Consultation on reform of Landfill Tax – GOV.UK

It only takes a short time, but we at the BAA are here to help, assist and compile responses whose outcomes will shape our industry for years to come.

Let’s ensure those outcomes are informed by the people who know the industry best, which is us.

For further information, please get in touch with Mike Phillips at mphillips@british-aggregates.comaggregates.com

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