Simpler Recycling revision mandates separate collection of paper and card

The Department for Environment, Food and Rural Affairs (Defra) has today (29 November) published a Policy Paper setting out a default position that paper and card should be collected separately, in revision to the previous Government’s policy on Simpler Recycling.

This update says the Secretary of State has reached this conclusion based on evidence about the impact of cross contamination when paper and card is collected with other dry recycling.

In a sign of the Government’s ongoing nervousness about the number of bins households need to manage, it has set out its preferred configuration for a typical maximum of four containers, to collect residual waste, organics, paper and card, and all other mandated dry recyclables (metal, plastic and glass). However, given the Government’s tacit preference for anaerobic digestion, in practical terms food waste and garden waste are unlikely to be co-collected.

In another notable shift from the previous administration’s approach, the Government has issued guidance on ‘Ensuring Good Waste Collection Services for Households’ dropping pressure on local authorities to offer residual waste collections at least once a fortnight. Instead, the new guidance sets out - in very broad terms - the service quality requirements, notably specifying the condition ‘no build-up of odorous waste at the kerbside’

TEEP and maintaining the status quote for recycling collections

The guidance provides a clear framework for authorities to justify continued co-collection of paper and card with other dry recyclables through a new instance of Technical, Economic and Environmental Practicability (TEEP) assessments. In order to cite a TEEP exemption local authorities must demonstrate that it is not possible to separately collect paper and card due to at least one of these three conditions:

• Not technically practicable - due to factors such as depot space limitations, access restrictions, or infrastructure constraints
• Not economically practicable - where separate collection would cause excessive costs compared to combined collection, considering factors such as container and vehicle expenses, management costs, facility overheads, and material revenues
• No significant environmental benefit - based on analysis of carbon impacts, material quality outcomes, and contamination rates

Local authorities choosing to continue co-collecting materials must prepare detailed written assessments that include their waste carrier number, the specific geographical areas or collection routes covered, and which dry recyclables they plan to collect with paper and card. These assessments will be available for public scrutiny under Environmental Information Regulations 2004 and may be requested by the Environment Agency.

Reflecting on the relief this represents for many waste service operators, Michael Topham, CEO of Biffa commented: “It is also reassuring to know that collecting and processing fibre can be done as part of dry, mixed recycling where collecting it separately would not be environmentally or economically practical. This will help to ensure Simpler Recycling fulfils the objective of simplifying recycling. Our focus now is to work closely with our customers to make Simpler Recycling a success.”

Authorities must also regularly review these assessments, either annually or when operational circumstances change - such as when contracts end, vehicles are replaced, or new recycling facilities become available.

Implementation Timeline

The guidance sets out a staggered implementation approach for different sectors. From March 31, 2025, businesses and relevant non-domestic premises must arrange collection of core recyclable waste streams. This includes offices, retail, hospitality, healthcare facilities, educational establishments, places of worship, penal institutions, and charity shops selling donated goods.

Under the requirements outlined in "Simpler recycling: workplace recycling in England," workplaces must separate three waste streams: dry recyclables (including paper and card, plastic, metal, and glass), food waste, and residual waste. Businesses can determine their own container sizes and collection frequencies based on waste volumes, though if providing customer-facing bins, these must follow the same separation requirements.

A key exemption applies to micro-firms - defined as businesses with fewer than 10 full-time equivalent employees across all locations - who have until March 31, 2027 to comply. The guidance clarifies that volunteer workers are not counted in determining employee numbers.

For households, local authorities must implement changes by March 31, 2026, including the introduction of mandatory weekly food waste collections. The same 2027 deadline applies to the introduction of plastic film collections across all sectors.

The Environment Agency will enforce these requirements through compliance notices, with enforcement action possible for those failing to meet obligations. From April 2025, members of the public will be able to report non-compliant workplaces to the Agency.

Industry Reaction

The waste and recycling sector has broadly welcomed the announcement, though some concerns remain about implementation timelines.

Dan Cooke, Director of Policy, Communications and External Affairs at the Chartered Institution of Wastes Management (CIWM) commended the updated position: "The new default four bin system is a pragmatic move that CIWM applauds. It is also positive to see that local authorities will still be able to draw on their experience and expertise to deliver best services and value for local residents."

Dr. Adam Read MBE, Chief External Affairs and Sustainability Officer, SUEZ Recycling and Recovery UK, said: “SUEZ recycling and recovery UK (SUEZ) welcomes today’s much-needed policy update. By clearly outlining a simpler, more streamlined and – crucially - consistent framework for recycling across England’s 300+ local authorities and recognising the role played by business, the Government has taken an important first step in driving higher participation in recycling.

"For too long, the ‘postcode lottery’ of recycling services has created challenges for both consumers and the waste management sector. This clarification will help simplify collection practices while reducing the burden on households and businesses. That there is flexibility for local authorities to finesse their approach to reflect their particular area’s requirement is also good news which we will work with our municipal and commercial partners to deliver."

Similarly the Confederation of Paper Industries believes the revision is encouraging for paper reprocessors: “The quality of materials entering the paper and card waste stream is critical to enhancing recyclability and reducing contamination. By prioritising the separate collection of paper and card, this move will not only contribute to higher quality recycling, but will also act as a key driver for increasing recycling rates and advancing sustainability goals.

“To fully realise the potential of these reforms, it is essential to align them with a robust Extended Producer Responsibility framework. This should be supported by thorough recyclability assessments and appropriate fee structures to ensure systemic improvements in waste management and encourage sustainable practices.”

However, the National Association of Waste Disposal Officers (NAWDO) has raised concerns about the timeline for business collections. The organisation advised its members are "disappointed that no moves have been taken to address the March 2025 compliance date for introducing the full range of recycling services to relevant non-domestic premises," noting that setting a compliance date a year earlier than that for households is "illogical and impractical."

Head of Recycling Policy at the ESA, Patrick Brighty, said: “For consumers, the idea of every household having seven bins was always a red herring, so today’s announcement is unlikely to result in a paradigm shift in the number or variety of waste containers they put out for collection, but it does simplify the default expectations for councils, who will have a bit more flexibility in their service choices and less red tape to cut through.

"However, from 2025, packaging producers will be footing much of the bill for kerbside collections under the new Extended Producer Responsibility regime, so councils will have to demonstrate to them that the services they provide offer an efficient and effective use of this money by delivering the required recycling levels and quality.

"Paper and card are particularly susceptible to contamination from other waste, such as liquids, which can make them unsuitable for end markets. Maintaining separate collection of paper and card where practicable is a sensible decision which should help increase recycling performance.”

The government will introduce secondary legislation implementing these policy updates in December 2024, subject to parliamentary process.