CL:AIRE DoWCoP: A Simple Guide to Reusing Excavated Soils
Materials Management | February 2025
The CL:AIRE Definition of Waste: Development Industry Code of Practice (DoWCoP) provides a framework that allows suitable excavated soils and materials to be reused on development sites without being classified as waste, provided specific conditions are met.
For many projects, DoWCoP offers a practical route to reduce off-site disposal, minimise environmental impact and manage materials efficiently — but only where it is applied correctly. This article explains how DoWCoP works, when it can be used, and what developers need to consider to achieve compliance.
What Is CL:AIRE DoWCoP?
The DoWCoP is a voluntary code of practice developed to clarify when excavated materials can be reused on site or at another development site without becoming waste under waste legislation.
When the requirements of the DoWCoP are met, excavated materials can be:
Reused legally and compliantly
Managed outside of waste controls
Transferred between sites where appropriate
The framework is widely recognised by regulators and is commonly applied on redevelopment and infrastructure projects across the UK.
When Can DoWCoP Be Applied?
DoWCoP can be used where:
Excavated materials are suitable for reuse
The reuse is integral to a defined development project
Risks to human health and the environment are acceptable
A clear materials management framework is established
It is most commonly applied on:
Brownfield redevelopment sites
Residential and commercial developments
Infrastructure projects involving bulk earthworks
DoWCoP is not appropriate where materials are unsuitable for reuse or where risks cannot be adequately controlled.
Key Components of the DoWCoP Framework
1. Materials Management Plan (MMP)
A Materials Management Plan (MMP) is central to DoWCoP compliance. It sets out:
The source and nature of excavated materials
Proposed reuse locations and purposes
Assessment of suitability and risk
Controls to ensure compliant reuse
The MMP must be prepared by a suitably qualified person and agreed before materials are reused.
2. Qualified Person (QP) Oversight
A Qualified Person (QP) is responsible for:
Reviewing and signing off the MMP
Confirming that DoWCoP requirements are met
Providing independent oversight of materials reuse
QP involvement provides regulatory confidence and ensures decisions are technically robust and defensible.
3. Verification and Record Keeping
DoWCoP requires clear records to demonstrate that:
Materials were reused in accordance with the MMP
Any changes were assessed and documented
Reuse objectives were achieved
Verification reporting is essential to demonstrate compliance and provide an auditable trail for regulators and stakeholders.
What Are the Benefits of Using DoWCoP?
When applied correctly, DoWCoP can:
Reduce off-site disposal of excavated materials
Minimise vehicle movements and environmental impact
Support efficient project delivery
Provide a clear, regulator-recognised compliance route
However, poor implementation or lack of oversight can lead to delays, reclassification of materials as waste, or regulatory challenge.
Common Pitfalls to Avoid
Developers should be aware of common issues, including:
Inadequate site investigation data to support reuse decisions
Overly generic MMPs that lack site-specific detail
Changes to earthworks without reassessment
Insufficient verification and record keeping
Early planning and competent technical support are key to avoiding these risks.
How Terra Environmental Supports DoWCoP Compliance
We provide practical support with DoWCoP compliance across all project stages, including:
Preparation of Materials Management Plans (MMPs)
Suitability and risk assessment of excavated materials
Qualified Person (QP) support
Verification reporting and regulatory liaison
Our approach focuses on proportionate, evidence-based decision-making to enable compliant reuse while maintaining regulatory confidence.
Considering DoWCoP for Your Project?
If your project involves significant earthworks or excavated materials, early consideration of DoWCoP can help identify opportunities for compliant reuse and reduce unnecessary disposal.