Consultation on modernising environmental permitting for industry

Closes 21 Oct 2025

Notification of R&D and testing exemptions with the regulator

Currently, there is no requirement for operators of installations that are solely used for research, development or testing of new products and processes to register or notify their installation with the relevant regulator. While this has the benefit of removing the burden of any kind of regulatory process for these activities, it also removes an opportunity for the regulator to become aware of and start to prepare standards for new technologies which will eventually require permitting when they are developed at a commercial scale.  

We would like feedback on the option of requiring operators of sites that fall under the R&D and testing exemption to notify the relevant regulator and provide basic information about the activity. While this notification would be required for the activity to proceed, the regulator would not be required to respond to approve the activity and would not set any conditions – so we would not anticipate a notification requirement having an impact on timelines for trials. The information required as part of a notification could also specifically exclude any commercially confidential information to ensure proprietary information is not compromised. 

12. What would the benefits and costs be of requiring operators of sites, which fall under the EPRs R&D and testing exemption, to notify the relevant regulator?