EWC chapter 09: photographic industry waste codes explained

X-ray processors in hospitals and dental surgeries, commercial photo labs, offset printing units using photographic plates, and even single-use camera recycling — all generate waste classified under EWC chapter 09. With 8 of its 13 codes carrying a hazardous asterisk, and a counterintuitive split on silver-bearing waste, knowing which code applies is what determines whether you need a consignment note or a standard transfer note.

What is EWC chapter 09?

Unlike the larger EWC chapters that span several subcategories, chapter 09 has just one: 09 01 (wastes from the photographic industry). The codes cover the full range of photographic process waste — liquid chemistry, silver-bearing by-products, film and paper, and disposable cameras. Note that code 09 01 09 does not exist in the UK List of Wastes; the numbering jumps from 09 01 08 to 09 01 10.

EWC chapter 09 contains 13 codes: 8 are absolute hazardous entries (marked with an asterisk) and 5 are non-hazardous. All six of the liquid process chemistry codes (09 01 01* to 09 01 06*) are hazardous — there are no non-hazardous mirror entries for photographic chemicals.

What are all the EWC codes in chapter 09?

Which photographic wastes are hazardous?

The hazardous entries in chapter 09 are all absolute — that means they are hazardous regardless of concentration or composition. This is different from chapters such as 06 or 11 where some codes have both a hazardous (*) and a non-hazardous mirror entry. For chapter 09 liquid chemistry, there is no non-hazardous alternative: if you generate developer, fixer, bleach or silver-bearing liquid from a photographic process, it is hazardous waste.

Is silver-bearing photographic film classed as hazardous?

This is the most counterintuitive distinction in chapter 09. Silver is a hazardous substance in solution (it is toxic to aquatic organisms at low concentrations), but silver that is fixed within solid photographic film or paper does not trigger the hazardous classification. The key split is:

• →09 01 07 — solid film/paper with silver: non-hazardous. This includes exposed and unexposed photographic film, X-ray film and photographic printing paper that contains silver halides or metallic silver. Dispose via a standard waste transfer note.
• →09 01 06* — solid silver from on-site treatment: hazardous. Silver sludge or silver-bearing solid residue recovered from treating photographic liquid waste on-site (for example, from an electrolytic silver recovery unit).
• →09 01 13* — aqueous liquid from silver reclamation: hazardous. The residual silver-bearing solution remaining after on-site silver reclamation, distinct from the solid silver (09 01 06*).

If you send used X-ray film to a silver reclamation contractor, the film itself travels as 09 01 07 (non-hazardous). The liquids the contractor generates during silver recovery at their own site become 09 01 06* or 09 01 13* at that point — your obligation ends at correct classification of the film you consign.

What EWC codes apply to photographic developers?

The vast majority of waste developer from X-ray processors and conventional photographic processors is water-based, so 09 01 01* is the correct code in most cases. Offset printing is the main scenario for 09 01 02*. Solvent-based developer (09 01 03*) is uncommon in modern practice but still generated in specialist reprographic and industrial photographic contexts.

What documentation is required for chapter 09 hazardous waste?

Because all eight hazardous codes in chapter 09 are absolute (not mirror entries), there is no threshold or composition test: if the code applies, the hazardous regime applies. Practically, this means:

• →Complete a hazardous waste consignment note (not a standard waste transfer note) for each collection. Include the EWC code, the UN number where required, and the carrier's upper-tier registration number.
• →Use an upper-tier registered carrier. Lower-tier registration does not cover hazardous waste movements.
• →Retain a copy of the consignment note for at least 3 years (hazardous waste retention period, compared with 2 years for standard waste transfer notes).
• →The receiving facility submits quarterly returns to the Environment Agency (or equivalent regulator) confirming the quantity received.

This guide is general information about EWC codes and waste classification, not legal advice. Verify your classification against the primary sources below and, if in doubt, consult the Environment Agency's technical guidance or a qualified waste consultant.