Workplace recycling regulations: a guide for the leisure facilities and entertainment sector

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. 

It also includes community centres and village halls, entertainment, and sports venues (including leisure centres), sports grounds and stadia, showgrounds, heritage buildings, libraries and museums. 

The guide is applicable to organisations that operate either all year-round or seasonally and whether they are within the private, public or third sectors.

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 visitors. 

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 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. 

To understand the different types of waste your workplace produces, undertake a waste audit by walking through the different areas within your premises, e.g., offices, kitchens, on-site cafés, club rooms and lounge areas, food preparation, storage, and delivery areas, to examine the contents of general waste bins, and to highlight any waste reduction or recycling efforts that are already in place. In addition, think about the people who will be using your facilities and the types of waste that they may produce.

Within your premises the areas most likely to generate waste will include: 

• Kitchens, on-site cafés, and food stalls:
  • Food preparation areas - food (spoilage and preparation waste), packaging such as metal, glass, cardboard, plastic films and wrapping.
  • Food consumption areas - food (plate waste), packaging waste such as drinks cans, plastic and glass bottles, drinks cartons, cardboard, and paper;
• Staff room/mess room/office - paper, food, and packaging materials;
• Public areas such as concourses, halls and gift shops – uneaten food, packaging waste such as drinks cans, plastic and glass bottles, drinks cartons, cardboard, and paper; 
• Gift shops – paper and packaging materials such as cardboard, plastic films and wrapping; and unsold textiles and unsold small electricals; and
• Guest and holiday accommodations – food (spoilage, preparation, and plate waste), packaging waste such as drinks cans, plastic and glass bottles, drinks cartons, cardboard and paper.

Depending on the specific nature of your business and the services you provide, you may produce different types of waste, for example, cooking oils and fats, disposable camping gas cylinders or batteries that will require a specialised waste collection service.

If you have hired out your premises before, you should know the types and volumes of waste that are likely to be produced by your clients’ activities. This will help you to ascertain how many containers you will need to supply for both recyclables and other waste to ensure that you comply with the new Workplace Recycling Regulations.

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:

• Provide e-tickets, electronic guides, tourist information and maps for visitors which are accessible on smart phones;
• 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. Guidance is available on GOV.UK on how food businesses must dispose of food and former foodstuffs
• Use paperless marketing methods and offer paper-free receipts by emailing them to customers;
• Ensure that packaging on your takeaway food and drink is minimised and that what packaging is used, can be recycled or reused.
• Purchase recycled, refillable or reusable products wherever possible;
• Provide water fountains for staff and customers to use and use reusable cups, crockery, and utensils;
• For take-away drinks encourage customers to bring their own reusable cup by charging for single use cups and

There may be some costs to making these changes for some workplaces but increasing how much you recycle could reduce your waste disposal costs in the medium to long run. As this law applies to all food and drink caterers, it will be factored into business and management models.

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 that 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. 

Independent businesses

If you operate your business independently, setting up a recycling service and ensuring you are complying with the new law will be your responsibility. 

Franchises or larger organisations

If you are part of a larger organisation, chain, or franchise, then waste management services might be arranged nationally or regionally, with information and guidance provided by your head or regional office. You should contact them to find out about any changes they will be making.

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

• What is the amount or type of waste you regularly produce?  Does this change during the year?  For example, increases 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;
• Whether having recycling collections on certain days of the week e.g. after busy weekends or ‘changeover days’, will help prevent waste and recyclables building up;
• 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 bin;
• If you don’t have much space for external containers, could you share bins with other nearby businesses to help reduce costs and space? Just bear in mind that waste containers can’t be stored on the public highway in between collections; 
• 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;
• Whether you need collections at certain times i.e., at the end of each day or when a hire/event has finished to accommodate changes in waste volumes and ensure site safety. Remember that waste collection vehicles can be a hazard to visitors if they need to travel across areas of high footfall and
• You could also get quotes from a range of collectors to get the best price and the most suitable service for you.

If requested, councils must arrange waste and recycling collection services for you. There is a charge for these services. In rural areas you may find that options for waste and recycling are more limited, and that only councils will provide a collection service to you, especially if you do not produce a lot of waste. 

If you are in one of Wales’ 14 Business Improvement Districts (BIDs), you may find that they already have waste and recycling services which you can access.

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;
• close to where the waste and recycling is generated, i.e. in areas with high footfall at the entrances or exits, communal areas, concourses, next to concessions, food preparation areas, next to the facilities at campsites;
• 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. 

You are responsible for assessing risks associated with storage, handling or use of waste, and implementing effective control measures to avoid and control any identified risks. Hazards associated with poor waste management may include:

• accumulations of waste blocking emergency access or escape routes, presenting trip or fire hazards and attracting vermin.  These all pose health and safety risks – ensure waste storage areas are located away from flammable sources and that flammable materials such as cardboard are stored in sealed or secure containers;
• waste collection vehicles crossing high footfall areas or routes.  This can be dangerous – ideally ensure collections occur when the site is free from visitors. If this is not possible collections should occur during quieter times and a “banksman” or reversing assistant should be used and
• injury to workers due to the handling of waste, e.g., needle stick injuries, back strains caused by excessive manual handling and possible infection by pathogens such as tetanus.

In larger premises you may want to hire or purchase a baler to compress materials such as cardboard packaging. You will need to check 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) .

To keep recycling bins free from contamination, consider providing additional information to clients and visitors. Provide information on your website and as part of the welcome pack provided to holiday makers.  If you operate a venue that is hired out, such as a village hall, you could include the information as part of your terms of use. Ask users to reduce waste, by not using disposable items such as plates, cutlery, cups, recycling bottles, tins, paper and plastics by using the bins and bags available in the hall.

For premises with large outside spaces such as historic buildings with associated parks and gardens, showgrounds or sports stadiums, litter picking will be required. The level of litter picking, its frequency and duration will largely be determined by the nature and level of use of the space. Train and equip staff and supply them with appropriate protective equipment if they are undertaking litter picking or bin emptying duties. Following an assessment of risk, ensure they know what can and can’t be recycled to minimise contamination. Consider the size of containers especially those for food waste, which is dense, to reduce manual handling risks for employees emptying containers into larger commercial bins.

If you regularly hire out your premises for indoor or outdoor events, fairs, concerts, markets, and festivals you should read our guide for the outdoor events and festival organisers

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 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. 

Refer to our guide for the hospitality sector.

When engaging with employees:

• Ask for ideas on how a scheme may work, as they may have spotted opportunities or issues which you have not considered;
• Provide clear instructions on what they should do with different waste streams or recyclables to help you meet your new recycling obligations; 
• Provide training to permanent, seasonal and temporary workers. Use orientation training to ensure new starters can recycle from day one, with regular training and reminders for all employees;
• Share information about recycling via regular updates at team meetings and on staff noticeboards so that employees hear about the differences their actions are making and 
• Ask for feedback if recycling systems are not working well, ensure employees feel listened to and that issues are identified promptly before they cause bigger problems.

When engaging with clients, visitors, suppliers and third-party vendors:

• Ensure that all stakeholders understand their responsibilities regarding recycling and waste management and provide sufficient waste capacity to ensure that they can recycle as required by the new Workplace Recycling law;
•  Include the location of recycling and waste bins on location maps and leaflets highlighting all dedicated recycling and waste collection points with clear signposting;
• Promote the availability of recycling services to visitors in all promotional literature and explain why they should use them and
• Ensure all bins are clearly labelled so that users know what items to place in each bin. Make recycling bins as visible as possible with clear signage on them to help people use the correct bins. Recycling wardens can monitor containers to ensure visitors don’t cause contamination.

Ask your waste and recycling collector for information on how much waste you produce and how much has been recycled. Use this information to review how you may be able to increase recycling and set targets to reduce waste or recycle more. This information can also be used to promote your recycling successes to the local community, your visitors, and clients to reinforce why recycling is so important.

Use our resources on the Business of Recycling website when engaging with your employees, clients, visitors, suppliers, and third-party vendors.

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

If you run a hotel and are looking to measure your waste, the Hotel Waste Measurement Methodology on the sustainable hospitality alliance website gives a common approach to collect waste data, and measure and report waste.

The Food waste reduction roadmap toolkit (WRAP) provides actions to help you reduce food waste.  To see what others have done go to  Hospitality and food service case studies (WRAP).  

If you are looking for ideas of what to do with leftover food, the Surplus food hub (WRAP) can help.