Deodorants, spray paints, lubricants, air fresheners, expanding foams, pesticides - most workplaces and households use them every day without a second thought.
To most, an aerosol looks like simple packaging; but to waste operators, MRF managers, ADR specialists and fire investigators, aerosols occupy a strange and often misunderstood space somewhere between recyclable metal packaging and dangerous goods.At the same time that Simpler Recycling encourages the recovery of more metal packaging, hazardous waste and transport legislation still recognise that many aerosols remain pressurised, flammable, toxic or capable of causing fires long after people assume they are 'empty'.
CGN 14 has been designed as a practical decision-making guide for anyone handling aerosols in the real world; from cleaners and caretakers through to waste contractors, facilities teams and hazardous waste producers.
Rather than simply listing legislation, this guidance walks through the questions that actually matter:
• Is the aerosol genuinely empty?
• Does it belong in recycling?
• Could it still be hazardous?
• Which EWC code applies?
• When do ADR and UN numbers matter?
• What should happen if it’s damaged, leaking or partially full?
Because in waste management, 'it looked empty to me' is rarely a defence anyone wants to rely on. CGN 13 - link - more like this (hazardous waste) - link - more like this (Simpler Recycling) - link
This Circular Guidance Note (CGN) is intended as a practical awareness and reference document only. It does not replace legal duties, competent technical assessment, site-specific risk evaluation, or professional waste classification advice. Responsibility for the correct storage, handling, classification, transport and disposal of waste remains with the waste producer and all parties within the duty of care chain.
This document should be used in conjunction with relevant legislation and technical guidance including (but not limited to): Technical Guidance WM3 - link - The List of Wastes (England) Regulations 2005 - link
Where uncertainty exists, competent environmental, dangerous goods, or hazardous waste advice should always be sought before disposal or transportation.
CGN Disclaimer & Community Review
As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.
I have always believed that in waste management, getting it right matters more than pretending to already know everything.
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