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Workplace Recycling in Wales: The Separation Rules

By QWTN team · · 7 min read

On 6 April 2024, Wales became the first part of the UK to require every workplace to separate its recycling. The rules apply to businesses, charities and public sector bodies alike, and they cover waste that is presented for collection and waste that is sent for treatment afterwards. If you run a business in Wales, serve customers there, or collect waste from Welsh premises, this is the set of rules that decides how your bins are set up.

This guide explains what has to be separated, who is responsible, what the bans on disposal mean, and what to put in place if your premises are not yet compliant. The regulator for these rules in Wales is Natural Resources Wales (NRW), and the instrument itself is published on legislation.gov.uk and summarised on the Welsh Government website. Check both for the current wording before you rely on any summary, ours included.

Who the Rules Apply To

The requirements apply to non-domestic premises. That includes offices, shops, restaurants, pubs, hotels, factories, farms with commercial activity, schools, hospitals, charities, and public buildings. There is no small business exemption in Wales based on staff numbers or turnover, unlike the phased approach taken in England, where the equivalent obligations are set out in our article on Simpler Recycling for workplaces in England.

Responsibility is shared. The occupier of the premises has to separate waste and present it correctly. Waste collectors and carriers have to collect the separated materials separately and must not mix them again. Businesses that process or dispose of waste have to keep to the disposal restrictions that came in alongside the separation rules.

What Has to Be Separated

The core list of materials is:

  • Paper and card, kept apart from other recycling.
  • Glass, kept apart from other recycling.
  • Metal, plastic and cartons, which may be collected together as a single dry mixed stream.
  • Food waste, where a premises produces more than 5 kg of food waste a week.
  • Unsold small waste electrical and electronic equipment (small WEEE), such as unsold kettles, toasters and electric toothbrushes, which should be kept separate from other waste.
  • Unsold textiles, such as clothing and bedding that a retailer cannot sell.

Everything that is not covered by those streams is residual waste. Read the current Welsh Government guidance for your sector, because the detail of what counts as each stream is set out there.

Two details catch people out. The first is that paper and card must be kept out of the mixed dry stream, so the single wheelie bin that used to take everything from the office is not enough on its own. The second is that the food waste threshold is measured per week at the premises, not per business, so a small café that produces more than 5 kg on a typical week is covered.

The Disposal Bans

Alongside separation, Wales introduced restrictions on what can happen to waste after collection. Separately collected recyclable waste is not allowed to be sent to landfill or to incineration, and food waste is not allowed to be put down the drain by non-domestic premises, which in practice means no food waste macerators discharging to the sewer. Operators of macerators and similar units needed to change their arrangements.

There is a practical consequence for waste carriers. If you collect a properly separated stream, you cannot tip it into a residual waste skip at the transfer station because it is convenient. The material has to go to a facility that will recycle or otherwise treat it appropriately. A carrier who takes separated material and sends it for disposal is exposed in the same way as a business that failed to separate it in the first place.

Setting Up Your Premises

Start with an honest look at what your premises throw away, not with the bin supplier's brochure.

  1. Audit your waste. Spend a week noting what goes in the general waste. Most workplaces find paper and card, glass or food waste making up the bulk of it.
  2. Match containers to streams. You need a separate container (or compartment) for each stream you produce. Small premises can use stackable or split containers, as long as the materials stay apart until collected.
  3. Label clearly. Bins with clear labels, preferably bilingual in English and Welsh for public-facing areas, reduce contamination.
  4. Brief staff and cleaners. Contract cleaners often empty everything into one sack. If they do, the separation is lost before the collector arrives.
  5. Agree the collection. Ask your collector in writing what streams they take, how often, and where each goes.

For shared premises, such as a unit in a business park or a floor in a managed office, the landlord or managing agent often controls the bins. Tenants are still occupiers, so sort out in writing who provides the containers and who arranges the collection.

Practical tip: If you only have room for two bins, cover the biggest streams first, usually paper and card and the mixed dry stream, and arrange food waste and glass collections separately. Do not mix streams simply because the space is tight.

Unsold WEEE and Textiles

These two streams matter mainly for retailers, but they affect others too. A shop that cannot sell returned or damaged small electrical items must keep them out of general waste and send them for reuse or recycling. The same applies to unsold clothing and textiles. For the wider picture on electrical waste, including the producer and distributor obligations, see our article on WEEE waste for businesses.

Batteries and anything classified as hazardous waste are subject to their own rules, and must not go in the new streams. If an item contains a battery that cannot be removed, treat it as WEEE and tell the collector.

Waste Transfer Notes and Carriers in Wales

The separation rules sit on top of the existing duty of care. You still need a waste transfer note for each transfer of non-hazardous controlled waste, or a season ticket for regular collections, and your carrier still needs to be registered. In Wales that registration is with NRW, and you can check it on the public register before the first collection.

Waste descriptions matter more than they used to. A transfer note that reads “mixed waste” for a load that is supposed to be separated paper and card tells a regulator exactly the wrong thing. Describe each stream accurately, give the correct EWC code, and keep the notes for two years. If your waste is collected on a regular schedule, a single season ticket can cover each stream for up to twelve months.

The transfer note must also carry the declaration that the waste hierarchy has been applied, which sits in the Waste (England and Wales) Regulations 2011. A business that has set up proper separation can give that declaration with a straight face. One that has not is signing something it cannot support.

Enforcement and What to Expect

NRW has powers to inspect premises and waste, to ask for records, and to take action where the rules are broken. Check the current guidance for whether your local authority also has a role. The specific enforcement tools, including notices and fixed or civil penalties, are set out in the regulations and NRW guidance, so check the current position rather than relying on a figure from a blog post.

In practice, the regulator is likely to look first at carriers and operators who mix separated material, and at larger premises with obvious non-compliance. A smaller business with a sensible set of bins, labelled containers, and a collector who can show where each stream goes is in a strong position. A business that has done nothing, and cannot show it has even asked its collector what to do, is not.

If You Work Across the Border

Businesses that operate in both England and Wales face two sets of rules, and the details do not match. In England, micro-businesses have longer to comply and the list of materials differs in places. Scotland has had its own business recycling rules since 2014. Our overview of waste regulations in England, Scotland and Wales compares the three regimes.

For carriers, the practical point is simple: set up your vehicles, rounds and paperwork according to where the waste is collected, not where your office is. A van that collects food waste in Cardiff and Bristol on the same day is working under two sets of expectations.

Quick Compliance Checklist

  • Separate bins for paper and card, glass, and mixed metal, plastic and cartons.
  • A food waste bin if you produce more than 5 kg a week, and no food waste going down the sink.
  • A plan for unsold small electricals and textiles if you sell goods.
  • A written arrangement with your collector for each stream.
  • Transfer notes or a season ticket that describe each stream accurately.
  • Staff and cleaner briefings, repeated when people change.
Describe Each Stream Properly
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Disclaimer: This article is general information and not legal advice. The Welsh workplace recycling rules and their guidance may be updated. Check the Welsh Government and Natural Resources Wales websites for the current requirements for your premises.

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