Workplace recycling regulations: integrated impact assessment - Conclusion

8.1.1    Throughout our extensive engagement on this policy of source separation, the Welsh Government has actively involved businesses, public sector and third sector organisations, many of whom are interested groups and representatives of people with protected characteristics under the Equality Act 2010; Welsh speakers and Welsh language specialist groups; children and young people; and other people who will be affected by these reforms.

8.1.2    Our engagement to-date includes more than a decade of consultation and ongoing engagement to come to our preferred policy option, data gathering and analysis and stakeholder engagement. The Welsh Government has engaged with a range of stakeholders on source separation policy development on an ongoing basis dating back to at least 2009.

8.1.3    Collaboration with stakeholders has provided an opportunity for them to provide integral input on the phasing in of certain waste streams, views on the coming into force date and the proportionality of the enforcement regime. 

• 2009 Towards Zero Waste consultation: The aim of this consultation was to achieve a high level of recycling and to make sure that all recyclates are separated at source so that they are clean and of high value.
• 2013-14 - Environment Bill White Paper consultation: included consultation on the separation duty.
• 2019-2020 - Consultation on Beyond Recycling, the Circular Economy Strategy for Wales: included the commitment to the reforms with approximately 40 face-to-face events tailored to specific audiences and a formal public consultation to promote higher recycling in non-domestic settlings.
• 2019 Consultation on Increasing Business Recycling in Wales: consultation on the preferred policy option to bring forward statutory instruments (SIs) to increase recycling from non-domestic premises such as businesses and the public sector in Wales [7]. 
• 2022-23 Consultation on the Workplace Recycling Legislation: a 12-week public consultation on the draft code of practice and enforcement proposals, face-to-face meetings and public consultations with key stakeholders across target groups. Feedback from the consultations indicated affirmative support for the introduction of these regulations.

 [7] “Consultation – summary of response. Increasing Business recycling in Wales”, Welsh Government, 2021, .

8.2.1    These reforms will increase the quality and level of recycling from non-domestic premises in Wales. In doing so, this will represent a key step forward in Wales’ commitment to reaching zero waste and net zero carbon emissions by 2050. This also reflects the fact that in order to tackle the climate and nature emergencies, moving to a circular economy – where materials are kept in use and waste is avoided - is essential and an important element of being a globally responsible Wales. In line with the Welsh Government’s Well-being objectives [8] the reforms directly support building a greener economy based on the industries of the future and embedding our response to the climate and nature emergency in everything we do. 

8.2.2    A circular economy, which moves away from single use, decreases our emissions, and improves supply chain resilience, benefits the economy as well as the environment, as collected materials are recycled back into the economy whilst reducing our dependency on raw materials extracted from overseas. This in turn reduces the associated damage to nature, biodiversity and the environment globally caused by the extraction and processing of the raw materials. 

8.2.3    For individual businesses and organisations, the reforms will support the move away from a situation where the disposal of waste is a significant cost, to one where that waste material is instead effectively captured and returned into our economy as important commodities. Alongside increased resource efficiency and tackling the cost of living, this will also help to support business productivity and competitiveness in a decarbonising global economy. These reforms bring benefits by creating overall savings to the Welsh economy, securing higher prices for high quality materials captured, whilst creating opportunities to derive greater added economic value in Wales and creating additional jobs in the circular economy – crucial to a more prosperous and resilient Wales. The reforms also create alignment between the recycling behaviours of households and businesses, reducing the complexity of the system for all users. 

8.2.4    Through tackling the climate and nature emergencies, these reforms will bring important environmental, economic and health benefits to people in Wales (a healthier Wales). People will benefit from reduced carbon emissions impacting air quality, and recycling has become a point of national pride which generates opportunities to bring people together e.g. through repair and reuse (a Wales of cohesive communities, a Wales of vibrant culture) and by doing so creates opportunities for the Welsh Language.

8.2.5    For individual citizens, the regulations will provide:
•    less confusion and greater consistency in terms of what and how they recycle. In relation to recycling in the workplace, this will largely be the same as how they do it at home;

• a greater sense of self-satisfaction / agency for their efforts to tackle the nature and climate emergencies; 
• greater empathy for their employers doing their bit. 

[8] “Programme for government 2021 to 2026: Well-being statement”, Welsh Government, 2021.

• maximise contribution to our well-being objectives and the seven well-being goals;  and/or,
• avoid, reduce or mitigate any negative impacts?

8.3.1    The Welsh Government is taking an active role promoting biodiversity, children’s rights, equalities and the Welsh language with these reforms.

8.3.2    To date, the Welsh Government has invested over £1 billion in household recycling, which has transformed Wales from a nation that recycled less than 5% of its municipal waste to over 65% in 2021-22 and is already contributing savings of around 400,000 tonnes of CO2 emissions a year. These regulations promote the shift to a circular economy, reducing resource extraction and limiting the generation of waste, which helps to accelerate decarbonisation and reduce biodiversity loss. Continued action in this area is essential to our response to the climate and nature emergency, supporting the objective of embedding it in everything we do, whilst helping to build a stronger, greener economy as we make progress towards net zero and zero waste, creating a green and prosperous Wales for future generations.

8.3.3    The Welsh Government supports businesses to implement sustainable best practices through Business Wales, Food and Drink Wales, WRAP Cymru and the Biodiversity Partnership, and is developing sector-specific guidance on the implementation of these reforms with WRAP. A variety of support tools will be developed to help businesses and organisations to implement the changes, such as best practice case studies, guides and downloadable signage and resources. To mitigate a potential increase in the use of diesel vehicles in the waste sector, as it may not always be possible for waste collection to collect multiple streams simultaneously, leading to more trips, the Welsh Government is assisting with the transition to greener vehicles with grants to local authorities for electric collection vehicles and charging infrastructure. [9]  Moreover, the negative impact of any expansion to existing waste management facilities or new facilities is more than mitigated by the saving in emissions from the material substitution of the recycled material collected replacing raw materials. 

8.3.4    There are no significant negative effects on the Welsh Government’s statutory public sector equalities duties and implementation of the regulations will be fully compliant with the Equality Act 2010, with the provision of guidance and materials in accessible formats and targeting different languages. All legislation, correspondence and publicity will also comply with the Welsh Language (Wales) Measure 2011. The reforms contribute towards a more equal Wales as they bring about positive action to address the climate crisis which is anticipated to hit the most vulnerable communities hardest and it will also create a cleaner, greener and more sustainable environment with associated jobs and investment in the circular economy. The Welsh Government is working to minimise the cost impact on micro-businesses, which are the only businesses predicted to face a small increase in costs, [10]  by incentivising the co-collection of household and non-domestic waste.  All other businesses are predicted to make savings. 

8.3.5    The Health Impact Assessment concludes that, overall, the circular economy approach (which underpins the regulations) will have a positive impact on the wider determinants of health and wellbeing for the general population. In particular, through reduced emissions of C02 and N02 and mitigating the impact of climate change, which is disproportionately harmful for certain groups.

8.3.6    Children and young people are stakeholders directly affected by these reforms who will reap the many positive benefits. We want to harness the passion and enthusiasm of our young people, utilising the levers at our disposal such as our environmental education programmes, to ensure we involve children and young people early in our future thinking and influence positive behaviour change and creative thinking amongst our next generation. 

8.3.7    We will provide the tools to enable community action. This includes support tools to help to implement the changes, such as best practice case studies, guides, downloadable signage, bin signs and posters, online webinars, and other resources. By supporting local actions, it will collectively make a big difference. We will engage with our schools and communities, working with citizens to support local initiatives and resource efficient actions. In addition, Welsh Government is taking action to promote the procurement of receptacles with recycled content for the public sector. A key priority of this agreement is to increase recycled polythene content within the products supplied. This approach will allow participating organisations to make a decision that is aligned to their environmental and commercial strategy. 

[9]   “Local transport fund, resilient roads fund and ultra low emission vehicle transformation fund: guidance to applicants 2023 to 2024”, Welsh government, 2022, l and “£15m ‘boost’ will increase the number of Welsh electric vehicle charging points”, Welsh Government, 2023.
[10]  “RIA, Welsh Government, 2023, Table 22.

8.4.1    The outcomes of the regulation implementation will be monitored with a combination of quantitative and qualitative methods, depending on the nature of the outcome and the availability of an appropriate data source. The waste tracking system will once implemented, from 2025 onwards, be used as a primary data source to track recycling levels for industrial and commercial waste in Wales, as it will provide information allowing measurement of the amount of waste sent for recycling, landfill, or incineration, and where it is disposed. 

8.4.2    In addition, a number of other data sources that will be used in the interim include: WasteDataFlow, National Resources Wales (NRW) waste and recycling surveys, along with NRW ‘site return’ data. 

8.4.3    The outcomes relating to reduced disposal of food waste to sewer will be monitored during the inspections carried out by Local Authority Environmental Health Officers, who will report the premises disposing of food waste to sewer. 

8.4.4    The Welsh Government will explore the need for specific commissioned surveys to further monitor the extent of compliance and any potential barriers to the successful implementation of the proposals or add regulation-specific questions to the already planned future business surveys. Moreover, qualitative data gathered during the NRW, LA and Welsh inspections of non-domestic premises and waste handlers will further provide information about the impacts of the regulations on businesses.