Simpler Recycling in England: what your workplace must do

Since 31 March 2025, businesses in England with 10 or more employees have been legally required to separate their waste before collection. This is "Simpler Recycling" — and if you have not yet set up separate bins for food waste and dry recyclables, you are already in breach of the law. Here is what you must do, which EWC codes apply, and what happens if you do not comply.

Does Simpler Recycling apply to my business?

Simpler Recycling is England-wide and applies to businesses, charities, schools, hospitals and all other relevant non-domestic premises. It is introduced by the Separation of Waste (England) Regulations 2024 (SI 2024/666), made under section 160A of the Environmental Protection Act 1990 as amended by the Environment Act 2021. Compliance is enforced by the Environment Agency.

Businesses with 10 or more FTE employees: mandatory from 31 March 2025. Micro-firms (fewer than 10 FTEs): must comply by 31 March 2027.

What waste streams must I separate?

Food waste must always be kept separate from all other streams. Dry recyclables (glass, metal, plastic, paper and card) can be collected together in a single container — they do not need to be sorted into separate bins at the workplace — but they must be separate from food waste and residual waste.

Each separately collected stream must have its own waste transfer note (WTN) with the correct EWC code. If your carrier collects all four dry recyclables together, they will typically record this as 20 01 99 on the WTN. Keep a copy of every WTN for at least two years — your duty of care requires it.

Can paper and card go in the same bin as plastic and glass?

The Separation of Waste Regulations 2024 explicitly allow any combination of the four dry recyclable materials to be collected together. The key separation is between food waste, dry recyclables and residual waste — those three must always be in distinct containers.

What EWC codes apply under Simpler Recycling?

EWC codes on waste transfer notes are a legal requirement of the duty of care under the Environmental Protection (Duty of Care) Regulations 1991. When you have multiple separately collected streams, each collection needs a WTN — or an annual WTN per stream if your carrier issues season-ticket notes for regular collections.

What happens if I do not comply with Simpler Recycling?

The EA's enforcement approach moves from advice to compliance notice to escalated penalties. Members of the public have been able to report non-compliance to the EA since April 2025, so the risk of detection is not purely theoretical. The £118/hour charge is on a time-and-materials basis and applies to any regulatory work required as a direct result of non-compliance.

Does Simpler Recycling apply in Scotland, Wales and Northern Ireland?

Wales introduced mandatory workplace recycling requirements ahead of England, under the Waste (Separate Collection) (Wales) Regulations. If your business has premises across multiple nations, you will need to follow the rules applicable in each nation. The Simpler Recycling rules under SI 2024/666 apply only to premises in England.

Simpler Recycling (SI 2024/666) applies in England only. Wales, Scotland and Northern Ireland each have their own recycling regulations.

How does Simpler Recycling connect to Digital Waste Tracking?

Classifying your waste streams correctly now — 20 01 08 for food waste, 20 01 01 for paper and card, 20 01 99 for commingled dry recyclables — means the transition to Digital Waste Tracking will be straightforward. The data you capture for your WTNs today is the same data Digital Waste Tracking will require from your carriers and receiving sites tomorrow.

• →Set up separate labelled containers for food waste, dry recyclables and residual waste — this is the physical requirement.
• →Arrange separate collections from a registered waste carrier and confirm they will issue a WTN with the correct EWC code for each stream.
• →Keep a copy of every WTN for at least 2 years and produce it on request from the Environment Agency.
• →If you are a micro-firm, act now anyway — the 31 March 2027 deadline is approaching and many waste collection contracts require notice periods.

This guide is general information about Simpler Recycling requirements and is not legal advice. For your specific obligations, check the current GOV.UK guidance or consult a professional waste advisor.