Eligibility criteria
Primary CCA eligibility is determined according to whether a site has a part A1 or A2 activity under the Environmental Permitting Regulations (EPR) – see schedule 1, part 2 (see also Appendix G of the EA Operations Manual). Note that if there a threshold applies to the part A or A2 activity (e.g. for production/use/emissions) then, for the purpose of determining CCA eligibility, this does not apply.
Second there is the question of the sector to which the site should apply, chemical activities are generally those in EPR, schedule 1, part 2, section 4 (page 56) – see also Appendix A of the Operations Manual which sets out the main headings. In this context:
- Chemical processing should be taken to mean that a chemical reaction takes place as a fundamental part of the activity.
- Mixing substances which do not chemically react should not be considered as chemical processing, nor should simple adjustment of pH following a formulation operation or mixing operations (often to finish a product) where some minor incidental reactions do occur - see the guidance on the interpretation of Schedule 1.
If the site has a part A1 or A2 activity under the EPR it would usually already have an EPR permit. To help us consider the eligibility of an applicant it would be helpful to see relevant extracts from the permit, e.g. opening section and the page(s) that list the part A1 or A2 activity(ies).
Finally, there is a precedent for including some non-section 4 activities in the chemical sector CCA if they do not fall within other sectors. If applicants wish to check whether such a precedent exists for their part A1 or A2 activity(ies) we would be pleased to comment on supply of the section number and sub-paragraph for the activity.