Since 31 March 2025, most workplaces in England have had to separate their recyclable waste and food waste instead of putting everything into one general waste bin. The reforms are known as Simpler Recycling, and they come out of the Environment Act 2021. A second deadline arrives in March 2027, when the smallest businesses are brought in. If you collect, skip or haul commercial waste, your customers will be asking you what the rules mean for them, and you need an answer that is accurate and specific.
This guide covers which premises are caught, which materials must be kept apart, how the deadlines work, and what it changes in practice for waste carriers and their paperwork. Detail around exemptions and enforcement has been updated more than once, so treat this as a working summary and check the current gov.uk Simpler Recycling guidance before you advise a customer on a borderline case.
What Simpler Recycling actually is
Simpler Recycling is Defra's name for a set of rules that make recycling collections more consistent across England. The aim is that a business in Carlisle and a business in Canterbury have to separate the same core materials, instead of depending on whichever service their local collector happens to offer.
The rules apply in England only. Wales has had its own workplace recycling regulations in force since April 2024, and Scotland and Northern Ireland run separate regimes. Our article on how waste regulations differ across England, Scotland and Wales sets out the wider picture. If you work across borders, do not assume a customer in Wrexham follows the same rules as one in Chester.
Simpler Recycling builds on duties that already existed. Regulation 13 of the Waste (England and Wales) Regulations 2011 already required waste collectors and producers to take steps to collect paper, metal, plastic and glass separately where that was technically, environmentally and economically practicable (often shortened to TEEP). What has changed is that the new rules turn separation into the default expectation for a defined list of materials, with a narrower set of exceptions.
Which workplaces are covered
The rules apply to what Defra calls non-household municipal premises. In plain terms, these are workplaces that produce waste similar in nature and make-up to household waste. Typical examples are:
- Offices, shops and other retail premises
- Restaurants, cafes, pubs, hotels and takeaways
- Schools, colleges, nurseries and other education settings
- Hospitals, GP surgeries and care homes
- Leisure centres, gyms, community halls and places of worship
- Charity premises and public buildings
Industrial premises, construction and demolition sites and agricultural land sit outside the definition. A building contractor clearing a site is still bound by the general duty of care and the waste hierarchy, but the Simpler Recycling workplace duty is aimed at the offices, shops and catering businesses that produce household-like waste. Our guide to construction site waste management covers the rules that do apply on site.
Mixed-use sites can be awkward. A farm shop on an agricultural holding, or a canteen inside a factory, may be caught for the part of the operation that produces household-like waste. If a customer is unsure, ask them to read the current guidance or contact their waste collector, and make a note of what you advised.
What must be separated
There are two groups of materials. The first is the dry recyclables, the second is food waste.
- Glass: bottles and jars
- Metal: cans, tins, foil and similar packaging
- Plastic: bottles, pots, tubs and trays
- Paper and card: including cardboard packaging
- Food waste: separately collected so it can go to anaerobic digestion or composting
Plastic films and flexible plastic packaging are due to be added to the list at a later date, with the plan pointing to 2027. Check the current position before you tell anyone that films must go in the recycling bin.
The rules do not necessarily require five different bins. Collectors have some flexibility in how they arrange the collection. In England the expectation is that paper and card are kept separate from the other dry materials, with glass, metal and plastic able to go together, though exceptions exist where separate collection is not practicable. The detail of permitted bin combinations has been refined in the secondary legislation, so confirm the current arrangement with the collector or in the gov.uk guidance rather than quoting a combination from memory.
Deadlines and the micro-firm exemption
The timetable for workplaces has two steps.
- 31 March 2025: workplaces with 10 or more full-time equivalent employees were required to separate the core materials.
- 31 March 2027: micro-firms, meaning businesses with fewer than 10 full-time equivalent employees, are brought in.
A full-time equivalent is a way of counting hours rather than people. Two part-timers each working half a full week count as one. A small cafe with eight staff on varied hours may find it has fewer than 10 FTEs and falls in the later group, but the count is for the business, not for one site, so a shop that is part of a chain should not assume it is a micro-firm on its own.
Households follow a separate timetable, with new household requirements arriving from 31 March 2026. That matters for you if you also run a household collection round or a council contract, because the dates for each customer type differ.
Because the micro-firm date is still a year away, many of your smallest customers have not yet changed anything. It is worth raising the subject with them now. A customer who finds out in March 2027 that they need a food waste caddy and a separate card collection has a lot less time to arrange it than one who starts planning this year.
What it means for waste carriers and skip firms
For a business that collects commercial waste, Simpler Recycling changes the service you offer, the vehicles you run and the notes you write.
The collection service
If you collect from offices, shops or restaurants, you are likely to need to offer separate collections of the core materials, or to arrange for a partner to do it. Some collectors run split-body vehicles that take two streams on one round. Others contract out food waste to a specialist. Whichever route you take, the customer needs a clear picture of what goes in which container and what you do with it afterwards.
Contamination
Separation only works when the material is clean enough to recycle. If a customer puts nappies in the card bin or a skip firm tips a mixed load into a recycling stream, the whole load can be downgraded or rejected. Tell customers plainly what is acceptable, and keep a record when you reject or report a contaminated container.
Mixed loads and skips
A mixed skip of general waste is not itself banned by the workplace rules, because a skip on a building site is outside the definition. But if you hire skips to shops or offices that are caught by Simpler Recycling, the customer should not use a general skip as a way of avoiding the separation duty for packaging and food waste. For many small firms the practical answer is to talk to the customer about what is going in the skip, and to be ready to say no to a load that clearly includes separable recyclables.
Paperwork: transfer notes still apply
Separating waste does not remove your duty of care paperwork. Every transfer of controlled waste still needs a waste transfer note, or a season ticket covering repeat transfers, as set out in our guide to what a waste transfer note is. The difference after Simpler Recycling is that you will hold several notes for a single customer instead of one, because each material is a separate waste stream with its own description and EWC code.
Common codes for workplace streams include:
- 15 01 01 for paper and cardboard packaging, or 20 01 01 for paper and cardboard that is not packaging
- 15 01 02 for plastic packaging
- 15 01 04 for metallic packaging
- 15 01 07 for glass packaging
- 15 01 06 for mixed packaging, where a co-mingled dry recycling collection is permitted
- 20 01 08 for biodegradable kitchen and canteen waste
Our EWC codes guide explains how to choose between the 15 and 20 chapters. The code and the description on your note should match what is in the container, not what the customer hoped would be in it.
For regular weekly collections of the same material from the same customer, a season ticket is usually the sensible route. One note per stream per customer, valid for up to 12 months, keeps your admin manageable even when each customer now has three or four streams. You can build one for free with the QWTN note creator.
Records still need to be kept for two years for transfer notes. If a customer disputes what you collected, the paperwork is your evidence, so each stream needs a clear description and a signed or confirmed transfer.
Enforcement and what to expect
Regulators can use compliance notices and civil sanctions where businesses or collectors fail to meet the new duties, and non-compliance can end up as an offence. The mix of regulators and the way enforcement is shared out has been changing, so check the current guidance for the body that deals with each duty.
In practice, the first thing most small collectors will see is customers asking for help. The second is local authority or Environment Agency officers asking how a business is separating its waste and what evidence it holds. Having a record that says what was collected, from whom and where it went is the best answer to both questions.
A short checklist for waste businesses
- Work out which of your customers are non-household municipal premises and which fall outside the definition.
- Record each customer's FTE count and note whether the 2025 or 2027 deadline applies.
- Decide how you will collect each stream, or which partner will take it, and tell customers in writing.
- Set up a transfer note or season ticket for each separate stream, with the right EWC code and description.
- Check your registration covers what you carry. If you are unsure, read our guide to upper tier and lower tier waste carrier registration.
- Keep records for two years and review the gov.uk guidance every few months, because the detail is still moving.
Try it yourself
Create a one-off transfer note without an account.