Clean Energy, Waste and Sustainability

• All businesses (including micro-firms i.e. businesses with fewer than 10 FTE employees).
• Relevant non-domestic premises (residential homes, premises forming part of a university or school or other educational establishment, premises forming part of a hospital or nursing home, and premises of a description specified in regulations made by the Secretary of State).
• Local Authorities.

England only – Northern Ireland, Republic of Ireland, Wales, and Scotland have their own recycling regimes.

• 31 March 2025 – Businesses (excluding micro-firms) and relevant non-domestic premises will need to arrange for collection of the core recyclable waste streams excluding garden waste, i.e. glass, metal, plastic, paper and card, and food waste
• 31 March 2026 – Local authorities will be required to collect the core recyclable waste streams from all households in England
• 31 March 2027 – Micro-firms will need to arrange for collection of the core recyclable waste streams
• 31 March 2027 – Kerbside plastic film collections from businesses, households and relevant non-domestic premises will be introduced.

• Firstly, the reforms could lead to increased operational costs for businesses, relevant non-domestic premises and Local Authorities. They may need to invest in new waste management systems and infrastructure to comply with the new recycling guidelines. For example, waste collectors have an additional obligation to prepare a written assessment to explain circumstances when they cannot collect paper and card separately from plastic, metal and glass, which will take additional time and incur further costs. You can access further guidance for waste collectors here.
• Another major challenge will be preventing material cross-contamination by employees, customers or the general public where a person disposes of waste in the incorrect bin—for example, a milkshake in the paper recycling bin. This will be difficult to monitor and prevent and may necessitate the adoption of deterrents
• Finally, the reforms could place additional pressure on already overstretched trading standards teams, which will be required to enforce the new regulations. You can access further guidance for workplaces here
• DEFRA has also launched a Simpler Recycling Communications toolkit which will be continually updated and contains helpful resources for affected organisations to use and understand the regime.

All businesses should prepare by understanding the new regulations, ensuring they have the necessary infrastructure for collection, and educating their staff and, in the case of retail businesses, also their customers, about the changes.

How Can Retail Businesses Effectively Communicate the Changes Brought About by the Simpler Recycling Reforms to Their Customers?

We would suggest retail businesses adopt a multi-faceted approach to communicate the changes brought about by the Simpler Recycling reforms to their customers.

• Firstly, in-store signage can be an effective way to inform customers about the new recycling rules. This could include posters, leaflets, and stickers placed near relevant products or recycling points
• Secondly, businesses could use their online platforms such as websites, social media, and email newsletters to reach a wider audience. These platforms can provide more detailed information, including the reasons behind the changes and the benefits of recycling
• Thirdly, staff training is crucial. Well-informed staff can answer customer queries and provide clear guidance on the new recycling rules.

Remember, the key to effective communication is consistency and clarity. Make sure all messages are clear, concise, and aligned with the new recycling guidelines. This will not only help customers adapt.

What Infrastructure Changes Might All Businesses Need to Implement to Comply with the Simpler Recycling Reforms?

We would recommend several infrastructure changes that retail businesses might need to implement to comply with the Simpler Recycling reforms.

• Firstly, businesses may need to update their waste management systems to accommodate the new recycling categories. This could involve purchasing new bins or modifying existing ones to separate different types of recyclable materials
• Secondly, businesses should consider improving their storage facilities for recyclable materials. This could involve creating designated areas for storing different types of recyclables before they are collected
• Thirdly, businesses may need to invest in training and equipment for their staff. This could include training staff on the new recycling guidelines and providing them with the necessary equipment to handle recyclable materials safely and efficiently. Additionally, small businesses may wish to consider asking their employees to take their waste home with them rather than depositing it in office bins
• Lastly, businesses should consider working with waste management companies that can handle the increased volume and variety of recyclable materials. This could involve renegotiating contracts or seeking new service providers.

These changes may require upfront investment, but they can lead to long-term cost savings, improved environmental performance, and enhanced reputation among customers and stakeholders. It’s important for businesses to view these changes not as a burden, but as an opportunity to contribute to a more sustainable future.

DEFRA’s October 2024 update included a statement that it has removed the provisions from the draft regulations that relate to the introduction of mandatory labelling/provision of recycling information, which means that it will not be a mandatory requirement to label packaging to indicate recyclability when these regulations come into force—which remains on track for January 2025.

Local Authorities have expressed disappointment as this was to be one of the key changes to be introduced via the Simpler Recycling Reforms—to make it easier for consumers to know what waste to recycle—and without the labelling, this key aim is not being achieved.

However, in a statement emailed to industry stakeholders, DEFRA added that it will include mandatory labelling across the UK, likely via an amendment to the forthcoming legislation in 2025.