Simpler Recycling in England: Materials Recycling FAQs for Businesses
The UK government’s Simpler Recycling reforms are changing how businesses in England must sort, store, and present recyclable waste. To help organisations understand and apply these new requirements, the Department for Environment, Food and Rural Affairs (Defra) has published guidance in the form of frequently asked questions. This document is intended to support business representative bodies in answering queries from their members.
Here is a breakdown of the rules every business needs to know to stay compliant with the new system.
Co-Collection of Dry Recyclables: What’s Allowed?
Under the Environmental Protection Act 1990 (as amended), the default requirement is for recyclable waste streams to be collected separately. However, there are practical exemptions that allow businesses to combine certain materials under specific conditions.
Plastic, Metal and Glass
Businesses may present plastic, metal, and glass in a single recycling container. This is permitted without the need for any written justification, as evidence shows that this combination does not significantly compromise the recyclability of these materials.
Paper and Card
Paper and card must generally be presented separately, due to their susceptibility to contamination. An exemption applies only if:
- Separate collection is not technically practicable
- It is not economically practicable
- There is no significant environmental benefit to separating them
In such cases, businesses must prepare a short written justification – often called a TEEP assessment – to support co-collection.
When Is a Written Assessment Required?
A written assessment is only needed if a business intends to present paper and card together with other dry recyclables. The assessment must demonstrate that separation is not feasible on technical, economic, or environmental grounds.
Do I Have to Use Defra’s Template?
No. Defra offers a suggested template, but it is not mandatory. Businesses can use any format that clearly outlines their reasoning.
Who Needs to See It?
You are not required to submit the assessment in advance. However, it must be available for review by the Environment Agency, and – where services are provided by public authorities – members of the public may request access under the Environmental Information Regulations 2004.
Are Different Sites or Situations Treated Differently?
Yes. The justification for co-collecting paper and card must be assessed individually for different business sites, locations, or waste service routes. You may need multiple assessments if circumstances vary across:
- Geographic areas
- Types of premises (e.g. retail vs. industrial)
- Collection arrangements
What Does TEEP Mean?
TEEP stands for:
- Technically practicable
- Economically practicable
- Environmentally beneficial
A business only needs to justify one of these three conditions to support co-collection. For instance, if separating paper and card would be unreasonably expensive, this alone may allow for co-collection under the rules.
Which Plastics Are Included in the Dry Recycling Stream?
The following plastics are included:
- PET (polyethylene terephthalate): bottles, pots, tubs, trays, tubes
- PP (polypropylene): bottles, pots, tubs, trays, tubes
- HDPE and LDPE: same items as above
- Aseptic and refrigerated cartons (e.g. Tetra Paks)
- Plastic film and bags (must contain ≥90% mono-polyethylene or mono-polypropylene)
Plastics must be at least 40mm x 40mm and detectable by near-infrared sorting systems. Plastics with black carbon pigment are excluded.
Are Plant Pots Included?
Only if they meet the material and size criteria. Most black plastic pots are not suitable for recycling under current guidance.
Cartons and Fibre-Based Composites
- Aseptic and refrigerated cartons are considered part of the plastic stream.
- Fibre-based packaging with over 15% non-paper content must not be included in paper and card recycling.
Organic Waste: Food and Garden Materials
Can Food Waste Be Sent to Incineration?
No. Separately collected food waste must go to:
- Anaerobic digestion (AD), or
- Composting (especially when combined with garden waste)
- Sending food waste to Energy from Waste (EfW) does not count as recycling under the legislation.
Is Anaerobic Digestion Considered Recycling?
Yes, if the resulting digestate is applied to land. This qualifies as recycling under the Environmental Protection Act.
Compostable and Biodegradable Packaging
Materials labelled “compostable” or “biodegradable” (e.g. Vegware) are not included in the list of materials businesses must present for recycling. These products do not yet meet the standards for collection under Simpler Recycling, and may disrupt standard processes.
If your business uses such materials, you may arrange a separate voluntary collection, though this falls outside the scope of the new requirements.
Simpler Recycling creates a consistent framework for waste across England, while allowing flexibility based on practicality. For businesses, it’s essential to understand your obligations and assess whether exemptions apply.
Affordable Waste Management helps businesses of all sizes comply with Simpler Recycling regulations by providing reliable collection and disposal services for commercial waste – including dry recyclables, food waste, and organic materials.
Contact us today to arrange efficient and compliant waste collection for your business premises.