Workplace recycling: who is impacted?
What do the Simpler Recycling reforms mean for workplaces?
Starting from 31 March 2025 (or 31 March 2027 for micro-businesses), all workplaces in England must follow the new waste separation requirements as agreed with their chosen waste collection provider. These changes are part of the Simpler Recycling reforms, which aim to standardise recycling practices across the country.
Under the new system, workplaces will be expected to separate the following waste streams as a standard procedure:
- Residual waste (non-recyclables)
- Food waste
- Paper and card waste
- Other dry recyclable materials – including plastic, metal, and glass
These requirements are designed to make recycling easier, more efficient, and environmentally responsible across all sectors.
For further clarity, Defra has published detailed guidance aimed at both waste collection services and businesses. This guidance outlines exactly what is expected and how organisations can prepare to comply.
If you’re unsure how these changes apply to your business, Affordable Waste Management is here to help you adapt, stay compliant, and keep your recycling processes smooth and effective.
Who is affected by Simpler Recycling?
The Simpler Recycling reforms apply to a wide range of workplaces across England – not just traditional commercial businesses. In this context, a workplace is defined as any business or non-domestic premises that produces waste similar in type and content to that typically found in households – commonly referred to as household-like waste.
This includes, but is not limited to:
- Offices
- Shops and wholesale businesses
- Transport hubs like airports, train and bus stations
- Hospitality venues such as cafés, restaurants, and hotels
However, this list is not exhaustive. If your business or organisation generates waste that resembles household waste in its nature or composition, you are likely within scope of the new regulations. If there is any uncertainty, the legislation provides detailed definitions that can help you determine your obligations.
In addition to commercial operations, a number of non-domestic establishments are also covered under the rules set out in the Environment Act 2021 and the Separation of Waste (England) Regulations 2024. These include:
- Care homes and residential facilities
- Educational premises (schools, universities, colleges)
- Hospitals and nursing homes
- Places of worship
- Prisons and correctional institutions
- Charity shops that sell goods donated from homes
- Hostels housing individuals without permanent residence
- Community venues used mainly for public meetings
Whether a workplace produces what is technically classed as commercial or household waste is not relevant under the Simpler Recycling reforms. All workplaces – whether they are businesses or public/non-profit bodies – must comply with the new waste separation requirements by the designated deadlines:
- 31 March 2025 for most organisations
- 31 March 2027 for micro-businesses (those with fewer than 10 full-time equivalent employees)
What is meant by ‘household-like’ waste?
‘Household-like’ waste refers to any waste generated by a workplace that closely resembles the type of rubbish typically produced in a domestic setting. This classification is central to the Simpler Recycling reforms, as it determines which waste streams must be separated for collection.
Examples of household-like waste include:
- Leftovers and food waste from staff kitchens, canteens, or break rooms
- General non-recyclable waste often placed in black bin bags
- Dry recyclable materials such as:
- Paper and card (e.g. newspapers, packaging, magazines, cardboard)
- Glass, metal, and plastic containers (e.g. bottles, tins, jars, trays)
These waste types are considered similar in both composition and origin to what is found in domestic bins, and are therefore subject to mandatory separation under the new regulations.
However, it’s important to note what is not classed as household-like waste. This includes:
- Bulky waste (e.g. furniture, equipment)
- Construction and demolition waste
These types of waste fall under separate regulations and are not included in the scope of the Simpler Recycling obligations regarding material separation.
For a detailed breakdown of what qualifies as household-like waste and the required waste streams, businesses are advised to consult The Separation of Waste (England) Regulations 2024.
If your business handles any of the materials above and you’re unsure of your responsibilities, Affordable Waste Management can offer expert advice and fully compliant collection services tailored to your workplace needs.
How are micro-firms calculated for the purposes of the exemption?
For the purposes of the Simpler Recycling reforms, a micro-firm is defined as a workplace with fewer than 10 full-time equivalent (FTE) employees. This designation determines whether your business qualifies for a delayed implementation date (until 31 March 2027) under the new recycling regulations.
To determine if your organisation meets the micro-firm criteria, you’ll need to calculate the total number of FTE employees over a defined 12-week qualifying period. This includes both full-time and part-time staff.
Here’s how it works:
- Full-time staff count as one full FTE each.
- Part-time staff must be converted into FTEs based on the number of hours worked, pro rata.
Example:
Let’s say your business employs:
- 6 full-time staff, each working 37 hours per week
- 6 part-time staff, each working 18 hours per week
- One of those part-timers has only worked with you for the last 2 weeks
Now calculate the part-time contribution:
- For each of the 5 part-time employees who worked for the full 12 weeks:
- 18 hours/week × 12 weeks = 216 hours
- 216 ÷ 12 weeks = 18 hours/week
- 18 ÷ 37 (standard full-time hours) = 0.48 FTE
- For the employee who worked only 2 weeks:
- 18 × 2 = 36 hours
- 36 ÷ 2 weeks = 18 hours/week
- 18 ÷ 37 = 0.48 FTE
- Total part-time FTE = 0.48 × 6 = 2.88
- Add the 6 full-time staff: 6 + 2.88 = 8.88 FTE
Result: This business would qualify as a micro-firm, as it has fewer than 10 full-time equivalent employees.
How are micro-firms defined? (by premises or enterprise)
Under the Simpler Recycling reforms, the definition of a micro-firm is clearly set out in The Separation of Waste (England) Regulations 2025.
A micro-firm is any workplace – whether a business or a relevant non-domestic premises – that employs fewer than 10 full-time equivalent (FTE) staff across the entire enterprise.
Importantly, this figure is not based on the number of staff at an individual site, but on the total headcount across all locations operated by the same organisation. So, if your business has three branches with 5 staff each, your total employee count is 15, and your organisation would not qualify as a micro-firm.
How are part-time employees counted?
To determine FTEs, part-time staff must be calculated on a pro-rata basis using the number of hours worked relative to a full-time schedule. You’ll need to:
- Add up the actual hours worked by each part-time employee over a 12-week period
- Convert this to a weekly average
- Divide the result by standard full-time hours (typically 37 hours/week)
Are volunteers included?
No – volunteers are excluded from the calculation of FTEs. Whether your organisation relies heavily on volunteer support or has volunteers across different sites, they are not counted when determining your micro-firm status.
Does the micro-firm exemption apply to non-domestic premises e.g. places of worship?
Yes – the exemption for micro-firms does extend to certain non-domestic premises, provided they fall within the definition set out in Section 45AZA of the Environmental Protection Act 1990.
This includes locations such as places of worship, care homes, schools, charities, and other public-use buildings, as long as they have fewer than 10 full-time equivalent (FTE) employees. If eligible, these premises do not need to comply with the Simpler Recycling requirements until 31 March 2027.
Are unmanned and/or remote sites in scope of Simpler Recycling?
Yes – if a business employs 10 or more FTE staff in total across its organisation, all sites, including those that are unmanned or in remote areas, are required to comply with the new regulations from 31 March 2025.
This rule applies even if individual locations have fewer than 10 staff – the law considers the entire business, not each site separately.
However, services for such sites can be scaled appropriately, based on the actual volume of waste produced. There is no minimum collection frequency required under Simpler Recycling for food waste or dry recyclables, meaning businesses can work with their waste provider to develop a cost-effective, low-impact solution for smaller or lower-use locations.
Are chains and franchises in scope of Simpler Recycling?
Yes, chains and franchises are within the scope of the regulations. The date by which they must comply depends on their overall staffing numbers:
If the entire business has fewer than 10 FTE employees, they may benefit from the micro-firm exemption, and their compliance date is extended to 31 March 2027.
If they exceed this number, they must comply by 31 March 2025.
In the case of franchises, each entity should assess compliance individually, especially if registered as separate legal businesses on Companies House. Each franchisee will be judged based on their own FTE count, not that of the brand as a whole.
Are schools in scope for the 31st March 2025 deadline, even if their waste is classified as household waste?
Yes. Schools must comply with the non-household implementation date – 31 March 2025 – regardless of whether their waste is classified as “household” in nature.
The only exception is where a local authority has arranged a specific transitional timeline, particularly around food waste separation. In such cases, schools will align their compliance with that authority’s rollout plan, even if the local council is not their direct waste collector.
Are events such as festivals in scope of Simpler Recycling?
Yes – events like festivals are included under Simpler Recycling regulations if they generate waste that is similar to household waste (e.g. food packaging, drink containers, general rubbish).
Organisers must ensure that recyclables and food waste are separated at the point of collection, in accordance with the legislation. Proper waste management plans should be part of the event’s operational planning.
Are hotel rooms in scope of Simpler Recycling?
Yes. Waste produced by hotel rooms – including food scraps, packaging, and recyclables – must be segregated in line with the regulations.
However, there’s no legal requirement to provide individual recycling bins in guest rooms. What matters is that the hotel has a system in place to sort and separate waste prior to collection by the waste contractor. This can be managed by cleaning staff or back-of-house processes.
Are holiday lets, such as cottages, lodges or cabins in scope of Simpler Recycling?
Yes – holiday lets, including self-catering cottages, lodges, and cabins, are considered to be generating commercial waste under The Controlled Waste (England and Wales) Regulations 2012, if they are operated as a business.
As such, any household-like waste (such as food packaging, paper, plastics, or general refuse) produced by these properties falls under the Simpler Recycling rules from 31 March 2025, unless the micro-firm exemption applies.
Keep in mind:
The micro-firm exemption is assessed across the entire business, not per property. So, if your company manages multiple holiday lets and collectively employs 10 or more full-time equivalent (FTE) staff, you will not be exempt.
Are home-based businesses in scope of Simpler Recycling?
In most cases, yes – but with a longer lead-in time. Home-based businesses are typically considered micro-firms and therefore have until 31 March 2027 to meet the new requirements.
Whether a separate commercial waste collection is required for a home-based business will depend on local authority policy and the nature of the waste being generated. For example, if the business produces significant volumes of packaging or food waste, this may need to be collected separately from domestic household waste.
It’s always wise to consult with your local council or waste management provider to ensure compliance.
Is construction waste in scope of Simpler Recycling?
No – construction waste is not included in the Simpler Recycling reforms. This means materials such as bricks, plasterboard, rubble, concrete, and other building debris do not fall under these requirements.
However, if household-like materials (e.g. cardboard packaging, drinks bottles, food waste) are generated alongside construction waste, these must still be separated and presented for recycling as long as they’re clean, empty, and uncontaminated.
For example, empty cardboard boxes from building materials must be recycled separately, unless they’re heavily soiled or contain hazardous residues.
Does my workplace need to also recycle garden waste?
No – garden waste is not part of Simpler Recycling requirements for workplaces. The legislation only targets core household-like materials, such as food waste and dry recyclables.
However, if your business does produce garden waste (e.g. landscapers, garden centres, facilities with outdoor spaces), you still have a legal obligation to manage that waste responsibly. That means following the waste hierarchy and choosing the most environmentally beneficial disposal route.
This may involve composting, specialist green waste collection, or another sustainable solution – but it’s outside the scope of Simpler Recycling itself.
Not sure what applies to your property or business?
Affordable Waste Management is here to help. Whether you manage a single holiday let or operate across multiple locations, we’ll guide you through the regulatory maze and ensure your waste handling is 100% compliant – and cost-effective.