Workplace recycling regulations: a guide for residential settings (including care homes)

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 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 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. 

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, food preparation, storage, areas your residents and their guest have access to, 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.

The areas where you are most likely to generate waste could be: 

• Canteens and kitchens – food (e.g. preparation waste) and packaging waste; 
• Laundry and stores – packaging waste;
• Staff and break rooms - paper and packaging waste; 
• General offices – paper;
• Dayrooms, bedrooms and bathrooms – paper, packaging, and food waste;
• Activities and workshops spaces – paper and packaging waste, unsold electrical and unsold textile wastes and
• External grounds such as gardens and outside seating spaces - food waste and packaging.

Residential 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. Guidance is available on GOV.UK on how food businesses must dispose of food and former foodstuffs
• Use paperless marketing methods;
• Purchase recycled, refillable or reusable products wherever possible and
• Provide water fountains for staff and residents to use and use reusable cups, crockery, and utensils.

There may be some costs to make these changes initially 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 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 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:

• 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 vulnerable residents if they need to travel across areas of high footfall;
• What is the amount or type of waste you regularly produce?  Does this change during the year?  For example, increases at times when you may be accommodating additional clients or residents. 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 bin;
• If you don’t have much space for external containers, could you share bins with other 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 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-run home, arrangements may be made jointly for all similar establishments in your local authority area. The Workplace Recycling Regulations are applicable 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 Sell2Wales to procure goods and services, saving you the time and effort, and possibly money too. The Eastern Shires Purchasing Organisation (ESPO) provides a framework for the procurement of collection services for waste, dry recycling and food waste via Framework 379_21; whilst YPO (Yorkshire Purchasing Organisation) provides a range of frameworks under its Facilities Management section for the procurement of goods and services such as compostable liners, indoor and outdoor waste and recycling containers, wheeled bins and recycling services.

It’s important 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). 

Establishments with canteens or kitchens will inevitably generate food waste in larger quantities than those establishments not preparing and cooking food on site. 

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 and Food service sector guide which will provide more information on collecting food waste for recycling.

When setting up a recycling scheme it could be of benefit to engage and liaise with: 

• managers who procure goods and services; 
• caretakers, employees, or persons 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;
• your Facilities Management providers (if used) to ensure recycling services are provided; 
• grounds or estates staff 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; 
• activities co-ordinators can link activity sessions to those recycling activities which clients or residents can get involved in and 
• sustainability officers (common in larger establishments or organisations with more than one site) usually report and engage on environmental and sustainability issues such as waste management.

• 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.

You can use our resources on the Business of Recycling when engaging with your employees.

You could broaden engagement and messaging on recycling to employee, resident, client and visitor groups by:

• concentrating recycling bins in high footfall locations and areas which generate the most waste, such as common rooms, day rooms, offices or workspaces, kitchens 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);
• for large establishments you could consider providing maps on site to identify recycling points as well as what can be accepted for recycling at each location; 
• ensuring new employees, residents and clients are provided with suitable recycling messaging, and where appropriate training, which is ongoing and in a variety of formats. Provide information on recycling; within orientation packs, put up posters around the site with recycling information and
• reducing inconsistencies between recycling services available on and off the site to reduce confusion for users. Harmonise bin labelling with that used by the local authority which is usually the widely used Wales Recycles iconography also used in our resources on the Business of Recycling. This consistent approach will help users engage with the onsite recycling provision in a more consistent manner as well as embedding useful recycling behaviours that clients and residents can use once they transition to independent living for example.

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

Plastic packaging in the hospitality and food service industryy (WARP) provides many challenges and opportunities, the UK Plastic Pact has four targets working towards a world where plastic is valued. There are actions you can take to achieve these targets.

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 on the WRAP website

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