No minimum threshold set for business food waste collections under Simpler Recycling

Organisations of all sizes will be required to separate food waste for collection regardless of the quantity produced, the Department for Environment, Food and Rural Affairs (Defra) has confirmed, suggesting a stricter requirement than Wales's 5kg minimum threshold.

In a webinar yesterday (12 December) to clarify changes to Simpler Recycling requirements following last month's policy announcement, Defra officials emphasised that even premises generating minimal food waste must participate in separate collections. "Any food waste that's generated by the premises would need to be separated for collection," a Defra official stated, noting this applies to all workplaces including offices, not just food-service operations.

The requirement will affect a broad range of premises including offices, retail establishments, hospitality venues, healthcare facilities, educational establishments, places of worship, penal institutions, and charity shops selling donated goods. However, micro-firms - defined as organisations with fewer than 10 full-time equivalent employees across all locations - will have until March 2027 to comply.

Paper and card collection requirements

Defra's guidance provided significant clarification on the default position for paper and card collections. Officials confirmed that whilst separate collection of paper and card is the default requirement, local authorities retain flexibility through TEEP (Technical, Economic and Environmental Practicability) assessments.

"Paper and card are particularly vulnerable to cross-contamination from food and liquid commonly found on other recycling, which can significantly reduce quality of collected material," a Defra official commented during the briefing. This evidence has driven the decision to maintain separate collections as the default position.

However, local flexibility remains where authorities can demonstrate that separate collection is either:
- Not technically practicable (due to factors such as depot space limitations or infrastructure constraints)
- Not economically practicable (where separate collection would cause excessive costs compared to combined collection)
- Would provide no significant environmental benefit based on analysis of carbon impacts and material quality outcomes

For TEEP assessments, Defra emphasised that authorities need only demonstrate one of these conditions applies, not all three. To support this, Defra revealed it is working with WRAP to develop a new standardised tool for early-2025, to assist local authorities with their written assessments for co-collecting paper and card with other dry recyclables.

Officials clarified that a single written assessment can cover multiple scenarios, including groups of premises, specific geographical areas, or collection routes - significantly reducing the administrative burden initially feared by some authorities. Whilst these assessments won't require submission for approval, they must be retained for potential scrutiny under Environmental Information Regulations.

Phased enforcement approach

Defra outlined a three-stage enforcement strategy for implementation of the new regulations, emphasising support over immediate penalties. The approach will begin with advice and guidance, progress to compliance notices only if necessary, and use enforcement action as a last resort.

This graduated approach aligns with the different implementation timelines: March 2025 for most organisations and relevant non-domestic premises, March 2026 for households, and March 2027 for micro-firms and plastic film collections across all sectors.

Funding arrangements for local authorities

New details emerged on funding arrangements, with resource funding allocations for 2024/25 to be communicated in early 2025, and 2025/26 allocations following in spring. Ongoing food waste collection funding will be subject to the spring 2025 spending review.

For waste disposal authorities, discussions continue regarding potential funding for handling additional separately collected materials, particularly food waste. Officials indicated further announcements would follow the spending review outcomes.

Outstanding implementation areas

Several technical aspects remain under review, including application to litter bins and street cleansing services. Transport sector requirements are also being developed, with ongoing dialogue between government and operators regarding practical implementation on trains and aircraft.

For Schedule 2 premises - which include places like care homes, universities, schools, hospitals, prisons and places of worship - questions were raised about charging arrangements for separate collections and how requirements would apply to premises that may generate little or no food waste. Defra officials indicated these points would require further consideration.

WRAP is developing specific organisational support tools designed to help micro-firms transition to the new requirements by their March 2027 deadline in the most cost-efficient way. These will include practical guidance on container requirements, collection frequencies, and space management.

Container requirements

Officials emphasised flexibility in how requirements can be met, confirming that organisations can determine appropriate container sizes and collection frequencies based on waste volumes. However, any customer-facing containers must follow the same separation requirements as other collections.

For multi-tenanted buildings and business parks, Defra indicated that communal arrangements would be acceptable provided they enable proper separation of the required waste streams.