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A move by the Environment Agency (EA) to increase charges for waste activities would “put further pressure on a sector that is already at breaking point”, according to Community Pharmacy England (CPE), while the National Pharmacy Association (NPA) has described the proposals as “outrageous”.
In their responses to an EA consultation on proposed regulatory changes for reducing waste crime and changes to charges, both bodies said they “strongly disagree” with proposals set to come into force in April 2025.
The changes include charges for activities where the EA said it has not previously recovered its costs, such as a registration charge for waste exemptions.
The EA also plans to update existing hourly rate charges, which it said “are no longer recovering full costs”, such as for unplanned events, the control of major accident hazards and water pollution incidents.
In its response to a proposal that requires exempt operators to pay a registration charge of £56 to register one or more waste exemptions for a three-year period, CPE said it “strongly disagrees”, noting that NHS community pharmacies would be unable to pass the costs on to their patients.
“While other businesses are entitled to increase their charges to the public for services they offer, community pharmacies are not able to do this [as] NHS services are funded by the NHS/the government,” CPE added.
The NPA echoed CPE’s concerns, saying that funding cuts mean pharmacies are in a “precarious financial position” and “would not be able to cope with these additional charges as they cannot pass on the costs to their patients”.
In an email to The Pharmaceutical Journal on 23 January 2025, CPE said that “if all community pharmacies registered [for] the exemption in the first year of the charges being introduced, it would cost the sector £900,000 (the lowest amount it would cost the sector)”, adding that the charges are subject to inflation, meaning the costs to pharmacies will increase each year.
The EA is also proposing a “compliance band charge” for registering under the ‘T28 waste exemption: sort and denature controlled drugs for disposal’, which allows pharmacies to denature and dispose of controlled drugs to comply with the Misuse of Drugs Regulations 2001.
Both pharmacy bodies said they did not agree that the T28 exemption in band 3 should apply to NHS community pharmacies because they are already regulated by the General Pharmaceutical Council and must already register for the T28 exemption to meet the NHS terms of service.
In its response, CPE concluded: “NHS community pharmacies are not able to cope with any additional burdens, unless they are funded by the NHS and agreed with the government. The introduction of these charges would put further pressure on a sector that is already at breaking point.”
Commenting on the consultation, Gareth Jones, director of corporate affairs at the NPA, said: “Charging pharmacies for a routine piece of red tape for them to do their job is an outrageous and unnecessary tax on an already hard pressed sector.
“Pharmacies have to dispose of out-of-date medication as a matter of routine and there are well established procedures for doing that.
“It’s right the government should crack down on fly-tipping and environmentally damaging waster dumping, but they should exempt pharmacies from this proposed charge and recognise that they play a vital role in the responsible disposable of drugs and prevent them becoming a hazard to the public.”
According to EA data, illegal waste activity is estimated to cost taxpayers and the legitimate industry nearly £1bn per year, with its most recent waste crime survey claiming that 18% of waste (34 million tonnes per year) may be managed illegally at some point in the waste cycle.
In its consultation, the EA said: “Waste exemptions are abused to hide illegal waste activities creating wide-scale risk of pollution and harm to communities.
“We know a significant number of operators who register waste exemptions and do not comply. For example, we found 42% of registrants inspected in 2022 were non-compliant.”
“Better monitoring of waste exemptions will help achieve the targets from the [government’s] ‘Resources and waste strategy for England‘ to deter criminals from operating in the waste management sector and enforce better environmental standards,” it added.
Research published in August 2024 revealed that active pharmaceutical ingredients (APIs) were present in 52 out of 54 river sites across ten national parks in England.
A total of 31 APIs were detected, with the most common being cetirizine, metformin and fexofenadine, while metformin, caffeine and paracetamol showed the highest mean concentrations.
