To comply with the Simpler Recycling requirements a business must separate food waste, paper & card (unless collected with mixed recycling by the waste collector), mixed dry recycling (plastic, glass, metal), and residual waste, as a minimum. Optimising the service to separate these waste streams can often save money.
Depending on the needs of your clients, it may be beneficial to consider additional recycling bins such as glass, plastic, tin/cans if your clients produce high volumes of these materials.
To comply with waste regulations and Duty of Care, you must ensure that you retain a Waste Transfer Note for your waste services. If you are sharing provisions, a Waste Transfer Note in line with the shared provisions contract must be retained to show compliance.
The implementation timelines for Simpler Recycling are as previously announced:
From 31 March 2025, businesses and relevant Non-Domestic Premises (NDPs) in England needed to arrange for the collection of the core recyclable waste streams, with the exception of garden waste (glass, metal, plastic, paper and card, and food waste);
micro-firms* (businesses with fewer than 10 full-time equivalent employees) will be temporarily exempt from this requirement. They will have until 31 March 2027 to arrange for recycling of core recyclable waste streams;
by 31 March 2027, kerbside plastic film collections from businesses and relevant NDPs will be introduced.
Micro-firms are workplaces with less than 10 full-time employees in total. This relates to the total number of full time or full-time equivalent employees in a business, rather than in a certain business location. For example, if a business has 3 locations with 5 employees in each location, they have a total of 15 employees.
To comply with waste regulations and the Duty of Care, a business must ensure that it retains a Waste Transfer Note for the waste services. If a business is sharing waste collection provisions, a Waste Transfer Note in line with the shared provisions contract must be retained to show compliance.
From a shared provision perspective:
Facilities manager / landlord – Had the responsibility to set up services that were compliant from 31st March 2025, unless every business that is utilising the shared provision is a micro firm, in which case, by 31st March 2027.
Waste collector – Has a responsibility to provide a compliant service in line with these dates.
Waste producers – Have a responsibility to utilise the services provided in line with the relevant dates above.
Where there is a mix of micro-firms and non-micro-firms, the service provided needed to comply from 31st March 2025.
Micro firms could theoretically not engage with the recycling / food waste service until 31st March 2027, but in practice they should be encouraged to by the facilities manager.