Workplace recycling regulations: a guide for the retail 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.

From 6 April 2024, the new law will mean that 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. 

If you share a space e.g., a shopping centre or retail park, you will need to check if a central recycling system that meets the requirements of the law will be provided by landlords. If so, it will be your responsibility to ensure you and your staff use the recycling systems provided correctly. If not, your recyclable waste will be your responsibility.

If you mainly have an online presence, you will still need to comply with the changes on any premises that you use.

The retail sector is one of the UK’s largest producers of waste, producing waste streams that are generally easily recycled. Increasing recycling activity within your business may reduce waste management costs. 

To identify the different types of waste your store produces, undertake a waste audit by walking through the different areas within your store i.e., front, and back of store including warehousing 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. 

Within a store the areas most likely to generate waste will include: 

• warehousing/back of store – packaging such as cardboard, plastic films & wrapping; 
• staff room/mess room/office - generating paper, food and packaging materials and
• front of store – some packaging waste, promotional materials, damaged stock and unsold products.

Depending on the nature of your business and the items you sell, there may be types of waste that you produce, for example damaged stock, which may be hazardous and 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 and offer paper free receipts by emailing them to customers;
• Purchase recycled, refillable or reusable products wherever possible and
• Provide water fountains for staff.

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 retail outlets, 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 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. 

Shopping centres or managed locations

If you are within a managed location such as a shopping centre, food or market hall then waste management services might be procured by a facilities management company. You should contact them to find out about any changes they will be making.

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, 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 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 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,
• 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 guidance 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 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)

• 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 website when engaging with your employees.

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

If you sell electrical and electronic equipment (EEE) the waste electrical and electronic equipment (WEEE) regulations require you to provide a way for your customers to dispose of their old household electrical and electronic equipment when you sell them a new version of the same item, these regulations apply regardless of how you sell the products i.e., by internet or through a store.

The Battery Regulations also require you to offer a free collection or ‘takeback’ service of waste or used batteries if you sell or supply the equivalent of selling one pack of 4 AA batteries per day over a year. If you sell more than this then you must have a collection point at your premises. These rules apply whether you run a shop, a chain of shops or sell batteries online, by mail order or telephone.

Green Street have produced a Planet Friendly guide to encourage a greener and more sustainable high street. 

For guidance for clothing retailers on how to set up a take back scheme for unwanted clothing see WRAPs retailer clothing take back guide as part of the Textiles 2030 work.

WRAP has further guidance for: SME’s, hospitality and food services, entertainment and leisure facilities, educational establishments and outdoor events.