Road Planings and Article 27 in Ireland: What Movement Evidence Should You Keep?
In short: Ireland's EPA national by-product criteria BP-N001/2023 establish when site-won asphalt from a pavement development, destined for use as raw material in a Reclaimed Asphalt Pavement (RAP) plant for manufacturing bituminous mixtures, can be regarded as a by-product rather than waste. The regulatory decision and the physical truck movements are related, but they are not the same thing.
What does BP-N001/2023 actually cover?
The national criteria are specifically for site-won asphalt intended for dispatch to a RAP plant for use in manufacturing bituminous mixtures. They are not a blanket Article 27 route for every possible use of road planings.
Does a producer still have to register?
Yes. The EPA says the national criteria remove the need for a single-case by-product notification where the material complies with the criteria, but production under the national criteria must be registered through the EPA's EDEN By-product Module.
Why do source, batch and destination matter?
The EPA criteria define a batch around material generated from a specific production process and destined for one specific end user. They also define an approved supplier in relation to a specific production process and RAP plant. That makes the connection between the source job and intended end user operationally important.
Article 27 status and the truck movement are different questions
Tipper360 does not determine whether site-won asphalt satisfies BP-N001/2023 and does not grant by-product status. Its role is to help run and evidence the physical movements once the appropriate parties have established the job and regulatory route.
What should a useful movement record make clear?
For the transport operation, the record should make it possible to establish which road job or source the movement belonged to, who moved it, which vehicle was used, where it went and when the movement occurred. The relevant project information can then stay connected to the movement instead of being reconstructed afterwards from separate paper dockets, photographs and messages.
How do you keep repeated loads tied to the right road job?
Road-planing jobs can involve repeated movements throughout the working day. A practical system needs to keep each completed movement tied to the correct job and source while own drivers and subcontractors are working, without forcing the driver to recreate the entire job for every trip.
What if the destination changes?
The completed operational record should show what actually happened. A change of destination can also have regulatory implications that the responsible parties need to assess; the movement software should not assume that a different destination remains within the same by-product arrangement.
What Tipper360 can keep with the movement
Depending on the configured job, Tipper360 can keep the source or road section, driver, vehicle, times, destination, quantity information, photographs, notes and sign-off associated with the movement. It supports own drivers and subcontractors, repeated loads and offline working.
What Tipper360 does not do
Tipper360 does not grant Article 27 status, replace EPA registration, certify a RAP plant, determine material compliance or decide whether a changed movement remains within BP-N001/2023. Those responsibilities remain with the appropriate producer, end user and regulatory process.
Why keep the movement evidence?
It gives the contractor, road authority, receiving operation and project team a retrievable record of what physically moved from the job. That operational evidence can sit alongside — rather than pretend to replace — the regulatory and technical evidence required under the applicable process.
Official EPA sources
Regulatory information reviewed 30 September 2026. This is operational guidance, not a determination of by-product status.