News · Enforcement

Hoads Wood clearance is a duty of care story for every commercial waste contract

Frazer Lanagan, Managing Director of FJL Waste Services

Frazer Lanagan, Managing Director · 9 October 2026 · 4 min read · In response to BBC

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The short version

  • The Hoads Wood clearance took 15 months and 2,500 lorry loads to undo six months in 2023 of illegal dumping.
  • UK producers of commercial waste are legally responsible for where their waste ends up, not just who they hand it to.
  • Verify your waste carrier's licence number on the Environment Agency's public register before signing any new contract.
  • FJL puts 100 percent of its collections through licensed facilities with a full waste transfer note paper trail.

The clearance of the Hoads Wood illegal dump in Kent has finished after 15 months, and the BBC's figures ought to land hard with any business that signs a commercial waste contract. Criminals tipped nearly 40,000 tonnes of material on a protected ancient woodland site in six months in 2023, and 2,500 lorry loads of waste were needed to carry it back out again on the public purse.

Hoads Wood is a waste crime story, not just an environmental one

At the height of the dumping, residents counted 20 to 30 trucks per day driving in and tipping. The waste was piled up to 15ft (4.6m) in places on a Site of Special Scientific Interest. Three arrests followed in February 2025 and the Environment Agency-led clean-up began in June 2025. The BBC lists further supersites being cleared with public money, in Kidlington and near Wigan. Campaigners told the BBC the cleared site is now "catnip" to the gangs who filled it, which is why the Environment Agency has extended the restriction order and dug ditches to keep waste trucks out.

None of that waste moved itself. Someone cut a deal with someone else, handed over material they were legally responsible for, and asked no further questions about where it ended up. That is the thread running through every illegal supersite, and it is sitting inside commercial waste contracts across the country right now.

Duty of care does not end when the lorry leaves the yard

Every UK business that produces commercial waste is legally responsible for making sure that waste is handled by licensed carriers and taken to licensed facilities. The responsibility sits with the producer. Hand your material to someone who dumps it in a wood, and the fact that you paid in good faith will not shield you if the chain can ever be traced back to your loading bay.

Dumps the size of Hoads Wood need a steady supply of material. Material at that volume is far more likely to come from businesses than from householders dropping off the odd bag at the end of a drive. Somewhere between a producer's yard and the ancient bluebell woodland in Kent, a chain of custody broke and nobody along it stopped and checked.

What a legitimate chain looks like

A legitimate commercial waste collection has markers that any producer can verify. The hauler sits on the public waste carrier register and will produce their licence number on request. Every collection is covered by a waste transfer note that names the producer, the carrier and the receiving site. The receiving site is a licensed facility, and the carrier can tell you which one. FJL's own collections, around 190,000 of them in a year moving roughly 10,000 tonnes, go through that paper trail end to end, with 100 percent diverted from landfill.

What to check

  • Pull the waste carrier licence number of your current provider from your most recent waste transfer note and verify it on the Environment Agency's public register.
  • Ask the operator which licensed facility your material actually ends up at. A legitimate provider will answer plainly.
  • Keep waste transfer notes on file. If the chain is ever questioned, those notes are what the regulator will ask you for.
  • If a new provider will not name the licensed facility they tip at, treat the refusal as the warning sign it is.

The Hoads Wood site is what happens when businesses stop asking where their waste is actually going, and the duty of care rules exist precisely to make sure that question gets asked every time.

Frazer Lanagan, Managing Director, FJL Waste Services

Common questions

Do I need to check my waste collection provider's licence myself?

Yes. Under UK duty of care rules, the business that produces commercial waste is responsible for making sure it is handled by licensed carriers and taken to licensed facilities. Verify the carrier licence number on the Environment Agency's public register before signing any new contract.

What happens if my commercial waste ends up at an illegal site?

If a chain of custody traces back to your loading bay, the fact that you paid in good faith will not shield you. The producer is legally responsible for ensuring the chain is lawful, which is why the paperwork and the carrier's licence matter from the first collection onwards.

What should a waste transfer note contain?

It should name the producer, the carrier and the receiving site. Keep these on file. If the chain is ever questioned, those notes are the evidence the regulator will ask you for.

Frazer Lanagan, Managing Director of FJL Waste Services

Frazer Lanagan

Managing Director, FJL Waste Services

Frazer has 20 years in the waste and recycling industry, including time with large national operators, before starting FJL Waste 13 years ago.

More about Frazer Lanagan→

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