Workplace recycling regulations: a guide for educational settings and universities

This guide should be read in conjunction with the Separate Collection of Waste Materials for Recycling: A Code of Practice for Wales. This guide provides supplementary advice for individual sectors and should not be read as standalone guidance. 

From 6 April 2024, the new law will mean all workplaces have to present the following materials separately for collection for recycling and arrange for the waste to be collected separately from other waste. 

• Paper and card;
• Glass;
• Metal, plastic, and cartons and other similar packaging (for example coffee cups);
• Food – all premises that produce 5kg or more of food waste in seven consecutive days;
• Unsold small waste electrical and electronic equipment (sWEEE) and
• Unsold textiles.

The 5kg food waste weight limit applies to any seven-day period.  If you produce 5kg or more of food waste during any seven days, then it must be presented separately for collection. If you do not produce over 5kg per week this should be monitored to take account of any changes on the premises, for example an increase of staffing levels or students. 

This law only applies to household like waste produced by workplaces, that is waste that is usually found at home and routinely collected from the kerbside. 

A full list of recyclable materials that should be presented separately for recycling is available here: The Separate Collection of Waste Materials for Recycling: Code of Practice

As a waste producer, you are required to produce a waste transfer note. In most cases, however, your waste collector will produce this for you. You should check this carefully to ensure that the description of the waste being collected is accurate. None of the separated materials can be sent by your waste collector to landfill or incineration. You could consider asking your waste collector for regular evidence of the final processing destinations of your segregated materials.

The new law bans any food waste of any amount from being disposed of down the sink or drain into the sewer. It means you cannot use in-sink maceration units that chop or liquidise food waste and send it down the drain.

While it will not be illegal for you to have a macerator, de-waterer, or other similar food waste disposal technology, it will be illegal to use them to send food waste into sewers.

All occupiers of workplaces must correctly present recyclable materials separately for collection by their chosen waste collector.  Whether you own, rent, or lease your premises, it still applies. 

Undertaking recycling in educational settings has the added benefit of exposing a new generation to environmental issues and normalising recycling behaviour to ensure it is replicated at home, at school, and in later life when in work. 

To identify the different types of waste your establishment produces, undertake a waste audit by walking through different areas such as classrooms or workspaces, offices, canteens or kitchens, to examine the contents of general waste bins and highlight any waste reduction or recycling efforts that are already in place. Within your site areas most likely to generate waste may include:

• Canteens and kitchens - food and packaging waste;
• Staff rooms - paper and packaging waste;
• General Offices – paper;
• Classrooms and workspaces – paper and food waste and
• External grounds such as school playgrounds, the college or university campuses - food waste and packaging.

Educational establishments may also generate types of hazardous waste, such as paints, oils or chemicals that require a specialised waste collection service. 

Reducing or preventing how much waste you produce will help to save money and reduce the size of bins you will need. 

Here are a few tips to reduce your waste:

• Donate surplus or unsold stock – donate surplus food to charity or have an employee fridge for products that they can eat or take home free of charge. GOV.UK has guidance on how food businesses must dispose of food and former foodstuffs
• Use paperless marketing methods;
• Purchase recycled, refillable or reusable products wherever possible;
• Provide water fountains for staff and students to use and use reusable cups, crockery, and utensils;
• For take-away drinks encourage staff and pupils to bring their own reusable cup by charging for single use cups
• Ensure that packaging on your takeaway food and drink is minimised and what packaging is used, can be recycled or reused and
• If you supply Freshers' week goodie bags provide reusable gifts such as coffee cups, water bottles or cotton shopping bags.

There may be some costs to making these changes but increasing how much you recycle could reduce your waste disposal costs in the long run.

If you are already separately collecting and recycling all the materials you need to under the new law, then you may not need to do anything else. We recommend you read The Separate Collection of Waste Materials for Recycling: Code of Practice to double check you are doing everything you need to. This includes a list of all the specific types of things that have to be recycled. 

If you need to organise a new recycling service, it’s worth thinking about the following:

• Whether you need to have collections at certain times or days of the week to accommodate changes in waste volumes and ensure site safety. Remember, waste collection vehicles can be a hazard to pupils or students if they need to travel across areas of high footfall;
• Whether the amount or type of waste you produce varies throughout the year, for example, consider whether you need collections during end of term or half term holidays;
• What is the amount or type of waste you regularly produce?  Does this change during the year?  For example, decreases over Christmas or school holidays. Your recycling collection service, including the number of bins and how often they need emptying, may need to be flexible;
• Maybe little and often works better for you. Most waste collectors offer different container sizes, including sacks for some waste. Once you start recycling you might be able to reduce the size of your general waste bins;
• Speak to your existing waste collector about your new recycling needs. They will need to be aware of the new law and ensure the services they offer will be compliant and
• You could also get quotes from a range of collectors to get the best price and the most suitable service for you.

If you are a local authority school, arrangements may be made jointly for all schools in your council area. The law applies to all local authority premises, so procurement may occur corporately to reduce time and effort across various departments or buildings. 

Public sector organisations can utilise framework contract agreements procured by professional buying organisations such as the Wales Collaborative Procurement Hub (Sell2Wales) to procure goods and services, saving you the time and effort, and possibly money too. 

Universities and Higher and Further Education establishments can access contract frameworks procured by the Higher Education Purchasing Consortium, Wales (HEPCW) or through pan-UK agreements set up by other regional University Purchasing Consortia or the UK University Purchasing Consortia (UKUPC). The UKUPC is an entity created by the eight UK purchasing consortia, supporting collaborative procurement within Higher and Further Education.

It’s important that you consider where and how you will store your waste and recycling. 

Ensure that containers and waste storage areas:

• are safe and accessible for people, including users with disabilities, and your waste collector;
• are not in locations that cause an obstruction, a fire hazard or block escape routes;
• provide sufficient capacity to cope with the types and amounts of waste and recyclables you produce and store between collections;
• are not located near food preparation or storage areas for food safety and hygiene reasons;
• are close to where the waste and recycling is generated;
• are tidy, clean, and free from clutter or loose waste and 
• are secure with close fitting lids, and do not allow waste or recycling to escape.

It is important to:

• label your recycling bins to avoid contamination. You can use labels from the Business of Recycling Wales website and
• prevent water from becoming contaminated by stored waste.

Following this advice and guide will also help avoid any pest control problems. 

In larger premises you may want to hire or purchase a baler to compress materials such as cardboard packaging. You will need to check that your collector is happy with this and whether they have any limits on the weight of the bales you might produce. Your contractor may provide a baler and training.  If you use a baler, you may need to register a “waste exemption” with Natural Resources Wales (NRW).

Schools, colleges and universities with canteens or kitchens will inevitably generate food waste in larger quantities than those establishments not preparing and cooking food on-site. 

When designing your food waste collections in your educational setting, you may want to consider collecting food waste from the kitchen separately to waste collected in “front end” or public areas.  This may enable you to manage the amount of incorrect material in the bins more easily and reduce the risk of contaminating whole external food bins.

There are guidelines on Natural Resources Wales on food waste to help you dispose of waste properly to meet the existing waste Duty of Care law. 

The Food Standards Agency also provides guidance which means that you need to:

• store food waste in sealable containers which are:
  • solid, and strong enough to hold food waste;
  • in sound condition – i.e., without breakages or splits that could enable pests to access waste or cause leaks and
  • easy to clean and disinfect;
• remove food waste and other rubbish from areas as soon as possible and
• have enough waste storage facilities to store and dispose of food waste and other rubbish to keep them clean.

Ensure any changes you make are incorporated into your Food Safety Management Systems.

If your food waste collector allows you to use compostable liners, ensure that your liners are BS EN 13432 compliant. This means that all the food waste is sent for commercial processing to meet the right standards. 

You can refer to our guide for the hospitality sector which will provide more information on collecting food waste for recycling.  

When setting up a recycling scheme engage with: 

• the person responsible for procuring goods and services;
• caretakers or employees responsible for emptying internal bins into external containers, or who liaise with waste or recycling collectors;
• cleaning staff to ensure waste is correctly sorted and to ask them to report issues such as overflowing bins or contamination to the caretaker or management team. They can also advise if you have the correct waste capacity or need more;
• catering staff in on-site kitchens to reduce avoidable food waste via portion control and production of excess and unavoidable food waste;
• Facilities Management providers (if used) to ensure recycling services are provided;
• grounds or estates staff who need to know about changes to collections, and the locations of bins they will use when completing their duties i.e., litter picking or emptying external litter bins;
• teaching staff and Eco Schools Co-ordinators who can link lessons to those recycling activities which pupils need to get involved in and
• Sustainability Officers (common in higher and further education settings), who usually report and engage on environmental and sustainability issues such as waste management.

Use our resources on the Business of Recycling website when engaging with your employees, pupils or students.

You could broaden engagement and messaging on recycling to students and wider employee groups by:

• concentrating recycling bins in high footfall locations and areas which generate the most waste, such as the Students’ Union, offices or workspaces, coffee shops or canteens;
• labelling bins so users know what can and cannot be recycled and to ensure materials are correctly segregated and empty (of drink and food waste);
• providing or updating maps on campus to identify recycling points as well as what can be accepted for recycling at each location;
• ensuring every academic year, you liaise with each cohort of students so recycling messaging is ongoing and in a variety of formats. Provide information on recycling: within freshers' packs, use your website, put up posters around campus and halls, and email students with recycling information and
• reducing inconsistencies between recycling services available on and off campus to reduce confusion for students. Harmonise bin labelling and ask private landlords to provide information to new tenants on the recycling and waste services provided by the local council.

Schools

Wales Recycles launched a schools recycling campaign in September 2023 and provides a range of information, advice and resources to engage pupils and put recycling into practice.

EcoSchools is a global programme and delivered in Wales by Keep Wales Tidy.  The programme is designed to encourage and inspire young people to make positive environmental changes to their school community. 

Lets Go Zero is a UK wide climate change campaign to help schools become carbon zero by 2030. The campaign provides information, resources, case studies and webinars to support schools. 

Universities

Support for higher and further education establishments is available from the EAUC (Environmental Association for Universities & Colleges). They provide a range of resources and information specifically for the post 16 education sector. 

Food Service

There is a ban on Single Use Plastics including plastic cutlery, drink stirrers, polystyrene products and drinking straws. 

Guardians of Grub - resources for the food and hospitality sector to help food waste reduction.  

For support and help for food businesses, including educational premises, to take targeted action to reduce waste in their own operations, their supply chain and from consumers The Food waste reduction roadmap toolkit (WRAP) provides practical actions.  To see what others have achieved following the Food waste reduction toolkit see the Hospitality and food service case studies on the WRAP website.

For any food that is no longer needed but still good to eat the Surplus food hub on the WRAP website provides information on how to increase the redistribution of surplus food. 

For guidance on implementing the new law in the food service locations in your schools, colleges and universities please also see our Hospitality and Food Service Sector Guide