Environmental permitting covers the permits a manufacturing site needs for emissions to air, discharges to water, and waste management, issued and enforced by the Environment Agency in England (and equivalent bodies elsewhere in the UK). Solvent-using processes are a common example where specific emission limits apply.
Key points
- The Solvent Emissions Regulations, now incorporated into the Environmental Permitting Regulations, set emission limit values for installations using organic solvents above defined thresholds.
- A volatile organic compound (VOC) is defined as an organic compound with a vapour pressure of 0.01 kPa or more at 293.15K, or corresponding volatility under conditions of use.
- The Environment Agency enforces environmental permits in England, incorporating solvent emissions requirements into the conditions of an installation's permit.
- Environmental permitting is separate from workplace safety regulation (COSHH, DSEAR), though many sites need to comply with both frameworks simultaneously.
What This Regulation Requires
Environmental permitting requires manufacturing installations above relevant thresholds to hold a permit covering their emissions, discharges and waste management activities, with specific emission limit values applying to VOC emissions from solvent-using processes.
Who It Applies To
Environmental permits are held by the site operator - in contract manufacturing, this is the manufacturer's responsibility for their own facility, not something a buyer holds directly.
What This Means for Contract Manufacturing
If your product involves solvent use or other emissions-generating processes, confirm your prospective manufacturer holds the relevant environmental permit and understands the emission limits that apply - see solvent-based production for the related manufacturing capability.
What a Permit Controls
An environmental permit sets the conditions under which a site may operate activities that could pollute - covering emissions to air, discharges to water and sewer, waste handling, and often monitoring, record-keeping and reporting obligations. Conditions are specific to the site and the activities it carries out, so a permit is not a general licence to do chemical manufacturing but an authorisation for particular operations within stated limits.
For contract manufacturing the significance is that a new product can fall outside what a site is permitted to do. Introducing a process that generates a different emission, or increases an existing one beyond permitted limits, may require a permit variation - which takes time and is not guaranteed. This is a genuine and frequently overlooked constraint on which manufacturers can take on which work.
Where Products Commonly Hit Limits
Solvent use is the most common pressure point, because volatile organic compound emissions are controlled and a site will have a limit it must operate within. A manufacturer may be technically able to make your product and still not have headroom under its permit to do so at the volume you need. Recovering solvent by distillation rather than emitting it is one of the ways sites create that headroom.
Discharges to sewer are the other frequent constraint, particularly where a process generates aqueous waste with a significant load. Both are worth raising early: ask whether your product's emissions or effluent profile sits comfortably within the site's existing permit, rather than assuming that technical capability implies regulatory capacity.
What to Establish Before Committing
Ask what the site is permitted for, whether your product falls within it, and what a variation would involve if it does not. A manufacturer who can answer that clearly is one who has thought about the question before. Waste arising from production is a related matter dealt with under chemical waste management, and both feed into the environmental management systems described in ISO 14001.
Permits Constrain Growth, Not Just Entry
A permit limit that comfortably accommodates your initial volumes may not accommodate them after growth. Because a variation takes time and is not certain, it is worth asking not only whether your product fits the current permit but how much headroom exists - a manufacturer approaching a limit across all their customers may be unable to scale with you, however willing they are commercially.
Related Pages
Frequently Asked Questions
Does every manufacturer using solvents need an environmental permit?
Only where solvent use exceeds the relevant regulatory thresholds - smaller-scale use may fall below the permitting requirement, so confirm this rather than assuming either way.
Is environmental permitting the same as COSHH or DSEAR compliance?
No - environmental permitting addresses emissions and discharges to the environment, while COSHH and DSEAR address workplace health, fire and explosion risks. A manufacturer typically needs to comply with both, but they're separate regulatory frameworks.
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Search the DirectoryLast reviewed: August 2026. Regulation and guidance change — verify anything you rely on against the primary source. Tell us if something here is out of date.