Business, industry and planning guidance

Landfill regulation: the latest updates

The landfill licensing process is outlined here – but, like all processes, it is subject to changes. Furthermore, certain landfill licence conditions, such as daily cover, allow for alternative operational measures or activities to be implemented if EPA approval is given in writing.

The purpose of this page is to regularly summarise the most recent changes so landfill licensing stakeholders can keep abreast of EPA’s requirements when it comes to the notification, design and construction of new landfill cells, and to outline EPA’s expectations for obtaining written approvals with other landfill licence conditions.

Improving EPA’s internal approval processes

Checklists for design verification and 53V construction audit submission

EPA’s Development Assessments Unit (DAU) has reformed its internal review processes for landfill related approvals; particularly the approval of notification of intent to construct a new cell and the design and construction of cells, caps and leachate ponds.

DAU has developed checklists of key assessment items for the review of landfill related design submissions and 53V construction audits. These can be populated by the auditor and included in design and construction submissions.

These checklists allow EPA to easily and efficiently locate key items that the auditor has assessed, streamlining the assessment of audits by EPA.

Checklist for auditor assessment of landfill design (cell, leachate pond and cell cap)

A draft checklist has been developed and issued to EPA-appointed auditors for comment and feedback. Once finalised, this checklist will be issued directly to auditors for use and will also be issued to duty holders via the letter of acceptance of notification of intent to construct a new landfill cell.

53V landfill construction checklist

This checklist has been finalised and issued for use by auditors. It will also be issued to duty holders via the letter of acceptance from EPA for landfill related Designs.

EPA envisions that both documents will become an appendix in Landfill licensing guidelines (publication 1323) upon their revision. Copies of either checklist are available by emailing a request to

Design verification – landfill cells, capping and leachate ponds

For most approvals, our timeframe is 20 business days. Our expectation is that landfill licence holders submit auditor-assessed detailed design documentation for new cells, capping and leachate ponds, comprising plans, technical specifications and construction quality assurance plan (CQA), to Publication 1323 Landfill licensing guidelines provides details of information to be included in the plans, technical specifications and CQA plan in Appendices 9, 10 and 11 respectively. 

Additionally, EPA has created a design verification checklist to also be submitted with the detailed design documentation. This checklist would be populated by the auditor. The draft design verification checklist is currently under review by EPA-appointed auditors for comment in relation to its useability and content. Following review and revision, it will be made available for use.

Financial assurance – landfills

Landfill financial assurance estimates must be assessed by an environmental auditor

EPA now requires an environmental auditor, as opposed to a ‘suitably qualified person’, to assess landfill financial assurance estimates prepared by duty holders. This requirement, and the assessment form that goes with it, will enable a streamlined, efficient approval process between duty holders and EPA.

The Landfill financial assurance calculation assessment form (form F1014) must be completed by an environmental auditor and submitted with duty holder estimates. An updated version of the financial assurance calculation guideline (publication 1596) now includes this requirement.

EPA will be requesting all active and closed landfills to submit up-to-date estimates using this new process, in stages. EPA will contact operators to let them know when they are required to submit an estimate. We understand this is a new process and we will provide support and time extensions where they are legitimately required.

Common questions related to auditor assessments have been answered below.

If you would like to provide feedback on your needs and how they can be accommodated during this rollout process, or have any questions, contact the financial assurance team on 1300 372 842 (1300 EPA VIC) or

Waste recovery

Landfill licence condition LI_L10 states that: ‘You must ensure that waste that has been previously deposited is not recovered and reprocessed except in accordance with written approval from EPA’.

Practices to recover materials that have already been placed as waste within landfill cells for either relocation or reprocessing for resource recovery must not be undertaken without the prior written approval of EPA. This is to ensure that the appropriate controls are in place for potential environmental risks, and that EPA is able to verify that appropriate waste handling and tracking procedures are in place.

Where it is proposed to recover and/or reprocess deposited waste, we expect the landfill licence-holder to submit a preliminary proposal using the approvals proposal pathway form to which will allow EPA to complete an initial assessment of the proposal and determine if works are required and/or the potential risks of the proposal. 

Depending on the complexity of the proposal, the landfill licence-holder may be required to produce a site-specific management plan for the recovery/reprocessing activities that includes, but is not limited to, the assessment and mitigation of the following potential risks and impacts:

  • risk of odour to sensitive receptors
  • risk of hotspot/fire
  • flammable/toxic gases
  • impact to surface/groundwater
  • impact of recovered soil to be taken off-site
  • risk of contamination to waste materials to be recovered
  • risk of landfill cell collapse
  • risk of transmitting disease
  • risk of stockpiling of materials
  • impact of litter.

Please direct any questions or queries in regard to recovery and/or reprocessing of deposited materials to

EPA transformation

We are conscious that industry and the community is interested in the progress on drafting regulations under the new Environment Protection Act, along with the development of guidelines that are relevant to landfills and licensing. 

We will be using these updates to provide landfill licence-holders with news on work in these areas. Consultation with a range of stakeholders to inform the regulatory impact statement (RIS) is ongoing. The likely release of the RIS and draft Regulations later this year will provide the community with an opportunity to comment formally on the regulations. 

Further information regarding EPA’s transformation can be found our website on the We’re changing page, and we encourage our landfill licence-holders to subscribe to our regular newsletters to hear about upcoming consultations, events and workshops relevant to your community or business, or contact us with general questions.

Recently released EPA guidelines


Page last updated on 23 May 2019