Workplace recycling: who is responsible for meeting the requirements?
Who is responsible for ensuring separate collections from workplaces?
Responsibility for compliance with workplace recycling regulations is shared between the workplace itself (whether a business or a non-domestic organisation) and its waste collector.
As of 31 March 2025, all workplaces in England must ensure that recyclable waste streams – specifically paper and card, plastic, metal, glass, and food waste – are collected separately from residual (non-recyclable) waste. Businesses that qualify as micro-firms (those with fewer than 10 full-time equivalent employees) have until 31 March 2027 to comply.
Workplaces are required to:
- Arrange for separate waste collections through an authorised waste collector.
- Present their waste correctly in line with the agreed service arrangements.
Waste collectors, whether they are private providers or local authorities, must ensure that their services are fully compliant with the updated requirements under the Environmental Protection Act 1990. This means:
- Recyclable waste must be collected separately from residual waste.
- Organic waste (e.g. food) must be collected separately from dry recyclables.
- Paper and card must be collected separately from other dry recyclables by default, unless separate collection is not technically or economically practical, or there is no significant environmental benefit.
If a collector chooses to co-collect paper and card with other recyclables, they must produce a short written assessment explaining the justification. Government guidance is available, including a template for this assessment.
Who is responsible for complying with regulations where there is a letting agent or facilities management company, particularly where there are multiple businesses within the arrangement?
Responsibility for complying with workplace recycling regulations in multi-occupancy buildings – such as those managed by letting agents or facilities management (FM) companies – depends on who holds the waste contract.
If the letting agent or FM company is the party managing the waste collection on behalf of the businesses within the premises, they are legally required to ensure that the waste services provided are compliant with the Simpler Recycling reforms. This duty applies regardless of the agent or FM company’s own staffing levels, as compliance is assessed based on the businesses they represent.
If the waste contract covers one or more businesses with 10 or more full-time equivalent (FTE) employees, the requirement to have separate collections for recyclable and food waste applies from 31 March 2025. In contrast, if all businesses involved qualify as micro-firms (fewer than 10 FTEs), the compliance deadline is extended to 31 March 2027.
In cases where multiple tenants share waste services or use communal bins, the overall compliance date depends on the largest business:
- If any of the businesses exceeds the 10 FTE threshold, the shared waste service must be fully compliant by March 2025.
- Micro-firms within that shared system are not legally required to begin separating recyclables and food waste until 2027, but are strongly encouraged to adopt best practices early.
Tenants are advised to actively engage with their letting agents or FM providers to confirm that arrangements are being put in place to meet the legal requirements. A failure to provide compliant waste services could lead to regulatory action from the Environment Agency against the party responsible for the contract.
Can local authorities collect from both households and workplaces in the same service?
Yes, local authorities are permitted to collect waste from both households and workplaces using a combined service, if this is operationally convenient. However, doing so does not alter or reduce the legal obligations placed on workplace collections.
Under the Simpler Recycling reforms, all non-household premises, including businesses and other relevant organisations, must comply with the separate collection requirements from 31 March 2025. An exception applies only to micro-firms (those with fewer than 10 full-time equivalent employees), which have until 31 March 2027 to meet the same standards.
It is also worth noting that local authorities may choose to align their household waste services with the Section 45A requirements ahead of any mandatory deadlines. This is entirely permissible and does not conflict with current legislation, provided that the workplace waste collections still meet all regulatory requirements.
The key point is that workplace recycling duties must be met independently, even when sharing collection infrastructure with households. Simply participating in a mixed collection does not exempt a workplace from its legal duty to separate recyclable materials and food waste appropriately.
What is the responsibility of Local Authorities who do not have a commercial waste service? Is it just to provide reminders/communication about the upcoming changes?
Local authorities are under a statutory obligation to organise commercial waste collections only when formally requested by an occupier of non-domestic premises within their jurisdiction. This means they are not automatically required to offer a commercial waste service unless such a request is received.
Where no existing commercial collection service is in place, a local authority may either establish one directly or choose to subcontract to a licensed private waste operator. However, it remains the authority’s responsibility to ensure that any service provided in response to such a request is fully compliant with the Simpler Recycling requirements, which came into force on 31 March 2025. For micro-firms (those with fewer than 10 full-time equivalent employees), the compliance deadline is extended to 31 March 2027.
It’s important to note that local authorities are not solely responsible for communication or issuing reminders about the new regulations. While communication is encouraged to support awareness and compliance among local businesses, their primary duty in this context is to respond appropriately when a request for waste collection is made. Authorities are advised to seek legal guidance regarding the interpretation of their responsibilities and the implications of different approaches.
Do non-domestic premises need to comply from March 2025 or March 2026 if they are served by a local authority as a household waste service?
Non-domestic premises must begin complying with the Simpler Recycling regulations from 31 March 2025, unless they qualify as micro-firms (with fewer than 10 full-time equivalent employees), in which case the deadline is extended to 31 March 2027.
The only exception applies to food waste collections in areas where the local waste collection authority has a formally approved transitional arrangement. If such an arrangement is in place – as set out in the official Schedule – non-domestic premises located within that area are not required to implement separate food waste collections until the specified transition period ends. This rule holds true regardless of whether the local authority is directly responsible for providing the waste service to the premises.
It is important to note, however, that all other recyclable waste streams – including paper, card, plastic, metal, and glass – must be separated and collected accordingly from 31 March 2025. These requirements apply uniformly to all relevant non-domestic premises, irrespective of how or by whom their waste is collected.
Do the exceptions allowing co-collection of paper and card with other dry recyclables (‘TEEP’) only relate to collections from households or is this for workplaces as well?
The requirement to collect paper and card separately – unless it is not technically, economically, or environmentally practicable – applies equally to household and workplace waste collections, including non-domestic premises.
Where separate collection of paper and card is not feasible, co-collection with other dry recyclables is permitted. However, in such cases, the waste collector must complete a written TEEP assessment (covering Technical, Economic, and Environmental Practicability) that explains and justifies the reason for co-collection.
This flexibility is intended to accommodate a range of real-world operational constraints. To support waste contractors, official guidance and templates have been made available, streamlining the process of preparing the necessary documentation.
Is it the responsibility of the waste producer or the waste contractor to create the written assessment?
Responsibility for completing the TEEP assessment lies entirely with the waste collector. It is not the duty of the business or premises producing the waste to draft or submit this documentation.
If my waste contractor is not offering a separate paper and card collection, do I need a copy of their written assessment that justifies why this can happen for my records?
No. While your contractor must have a valid written assessment in place, you are not required to keep a copy. Should the regulator request verification, they will approach the waste collector directly to obtain the documentation.
Can a written assessment (‘TEEP’) be used to exempt premises that have little food waste or are difficult to collect from?
No, a written TEEP assessment cannot be used to exempt any workplace from the requirement to have food waste collected separately. Under the Simpler Recycling regulations, all workplaces that generate food waste – regardless of the quantity produced – are legally required to ensure it is separately collected for recycling.
This obligation applies universally, including to businesses that do not prepare or serve food, such as offices or retail outlets, if any food waste arises from their operations. The rule is not limited to those with catering services.
The TEEP (Technical, Environmental, and Economic Practicability) assessment is relevant only in one specific area: it may be used by waste collectors to justify the co-collection of paper and card with other dry recyclables where separating them is impractical or offers no meaningful environmental benefit. It does not apply to food waste under any circumstances.
For further guidance on co-collection scenarios, refer to the dedicated section: Dry recycling: co-collection exemptions and exceptions.
How onerous is the written assessment (‘TEEP’)?
The written assessment required under the TEEP (Technical, Environmental, and Economic Practicability) criteria is designed to be straightforward and not overly burdensome. To support waste collectors, Defra has published clear guidance along with a suggested template that can be used to streamline the process.
Importantly, a separate written assessment is not always needed for every individual workplace. Where multiple premises are served by the same collection route or method, and the rationale for co-collecting materials applies equally to all, a single group assessment can be used to cover them collectively.
However, if different services are provided across sites – such as varying combinations of materials collected together – individual assessments should be completed for each distinct service type. This ensures that the justification for co-collecting, for example, paper and card with plastic, metal, and glass, is properly documented and valid in each case.
For more in-depth information, including when and how co-collection may be justified, see the section titled Dry recycling: co-collection exemptions and exceptions.