Retail businesses are managing more changes to commercial waste law than any other sector right now. The Simpler Recycling legislation places new separation and collection obligations on every waste stream, and there are more new rules on their way – Extended Producer Responsibility for packaging and a Deposit Return Scheme. This guide covers all of it.
Your waste streams under Simpler Recycling
Since 31 March 2025, all businesses with 10 or more full-time equivalent (FTE) employees must separate and arrange collection for all of the following streams. Micro-firms with fewer than 10 FTE have until 31 March 2027.
The rules apply to all retail and wholesale businesses, including supermarkets, pharmacies, convenience stores, garden centres, and service station forecourts. If you’re a multi-site retailer, be aware of how the FTE count works: the number applies across your whole business, not per location. So if you have five stores each employing two full-time staff, you have 10 FTE in total. Part-time employees count pro-rata. Contractors and self-employed workers don’t count towards your total.
The macerator ban
One major practical change for food-handling retailers is that it is now illegal to dispose of food waste via macerators, dewatering systems, or enzyme digesters that discharge into sewers. All food waste must be collected in a dedicated container and removed by a licensed waste carrier.
What this means for retail businesses
Retail isn’t a one-size-fits-all sector. A large grocery superstore generates very different waste volumes from a pharmacy, a garden centre, or a convenience store. The compliance obligation remains the same: separate every stream, and have it collected by a licensed carrier.
Cardboard and packaging
For most retailers, cardboard is the number one waste stream by volume. Delivery boxes, display packaging, packing materials – retailers generate 1.1 million tonnes of waste per year, with cardboard and packaging representing the largest share. Cardboard is also one of the most valuable recyclable materials when kept clean and dry, with strong end-market demand and consistent recycling rates above 80%.
That means cardboard must be kept dry and uncontaminated. Flattening boxes before collection reduces bin capacity pressure and collection costs. A regular, dedicated cardboard collection prevents forecourt or loading bay build-up, which is one of the most common compliance and safety issues for retailers.
Food waste in retail settings
Depending on your format, food waste in retail is likely to include:
Fresh produce: unsold fruit, vegetables, and herbs approaching or past their use-by date; Prepared and deli foods: sandwiches, salads, and ready meals from in-store counters; Bakery waste: unsold bread, pastries, and cakes at end of trading day; Damaged stock: split packaging or goods contaminated during handling; Staff facility waste: tea bags, coffee grounds, and lunch leftovers from staff rooms; Customer-area waste: if you provide bins for customers or visitors, you must ensure they’re separated before collection.
Garden centres are required to recycle or compost garden waste in a way that delivers the best environmental outcome – though garden waste collection is a specialist stream outside standard commercial waste arrangements, so this will need to be arranged separately with an appropriate contractor. Retailers with forecourts need to be particularly aware of how customer bins are managed, with the Guild of Fine Food’s chief executive advising that these areas require close attention as different waste streams are more likely to become contaminated.
Dry mixed recycling and glass
Glass bottles and jars are a major stream for drinks retailers, off-licences, and any retail format with a chilled drinks section. Under Simpler Recycling, glass must be collected in a dedicated container, separate from your dry mixed recyclables. The Government’s legal framework acknowledges that waste collection arrangements can vary in certain circumstances, but most waste processors do not currently have the facilities to separate glass from other dry recyclable materials. A separate glass bin is therefore required.
Paper and card can typically be collected with plastic and metal in a single dry mixed recycling (DMR) bin. You do not need a separate paper and card container. Looking further ahead, soft plastic film collection may become a separate requirement from 2027, but the Government has not yet finalised this.
This arrangement – glass collected separately, paper and card combined with plastic and metal in DMR – isn’t more than just a compliance requirement. It’s the most likely way your materials will be recycled. Co-collected loads where glass is mixed with other dry recyclables can be reclassified as general waste if the processor is unable to separate them, which increases disposal costs and the volume of material sent to landfill. The waste collection arrangements 360 Waste Management uses are designed to maximise diversion from landfill while keeping your waste setup straightforward.
Another change that’s coming in 2027 is the Deposit Return Scheme (DRS), which will cover single-use PET plastic, aluminium, and steel drinks containers between 150ml and 3 litres. This will change how those specific containers flow through your waste system. Retailers will need to accept returns, with handling fees payable by the Deposit Management Organisation. Glass is excluded from the England scheme at launch. See ‘The bigger picture’ section below for more on the DRS.
Multi-site retailers
If you operate multiple retail locations, the compliance requirement applies at every site, regardless of how many staff work there. You cannot combine obligations across sites. Each location must have its own containers and a collection arrangement with a licensed waste carrier for every stream it produces.
Enforcement and the cost of non-compliance
If you haven’t yet put compliant systems in place, you’re overdue. The financial stakes rose considerably in February 2026 when the Environment Agency started applying a time-and-materials charge of £118 per hour for any regulatory work it carries out in connection with Simpler Recycling non-compliance.
The charge is applied on a time-and-materials basis only where a business is found to be non-compliant. The rate is a flat £118 per hour regardless of business size, which means smaller retailers feel the impact proportionally harder than large chains.
As well as the hourly charge, the Environment Agency can issue a formal compliance notice. Failure to comply with that is a criminal offence, which carries the risk of an unlimited fine. Members of the public can also report a non-compliant business directly to the Environment Agency. That means customer-facing retailers with visible waste handling areas carry a reputational risk as well as a regulatory one.
Why a weekly food waste collection is the right choice
You have flexibility over the size of your containers and how frequently they’re collected. However, 360 Waste Management supplies a 240-litre food waste container as any heavier becomes unmanageable. We also recommend a weekly food waste collection as the standard starting point for retail businesses. Here are some of the reasons why:
Hygiene and pest risk
Food waste goes off quickly, particularly during warmer months. Food waste collections more than a week apart create genuine hygiene risks, including odours and vermin-friendly conditions. In a retail setting where customers are present and health and safety standards are paramount, this is a major operational concern.
Compliance assurance
A regular weekly collection keeps your waste pipeline moving and reduces the risk of overflow or contamination incidents that could trigger a compliance investigation. It also demonstrates to the Environment Agency that you have a solid, functioning waste management arrangement in place.
Financial benefits
Evidence from WRAP
Research from WRAP, the Waste and Resources Action Programme, confirms that separate weekly collections are the most effective method for food waste recovery. Mixed fortnightly collections are the worst-performing option for keeping waste out of landfill.
The bigger picture: EPR, DRS, and digital tracking
Simpler Recycling is the happening right now, but three other regulatory developments will directly affect how retailers manage waste over the next two to three years.
Extended Producer Responsibility for packaging (pEPR)
The UK’s pEPR scheme has been live since October 2025. It shifts the full cost of managing household packaging waste from local authorities to the producers and retailers who place packaging on the market. If your business has a turnover above £1 million and handles more than 25 tonnes of packaging per year, you’re likely to have reporting obligations.
In Year 1 (2025–2026), fees are flat base rates per tonne of material – for example, £423 per tonne for plastic and £192 per tonne for glass. From Year 2 (2026–2027), fees are adjusted based on recyclability, using a red–amber–green rating system. The government estimates this will shift approximately £1.2 billion annually from local authorities to producers.
Deposit Return Scheme (DRS) – October 2027
From October 2027, the UK’s Deposit Return Scheme will add a refundable 20p deposit to single-use PET plastic, aluminium, and steel drinks containers between 150ml and 3 litres. Consumers will return empty containers to retail return points to reclaim their deposit.
Larger retailers will have an obligation to host return points. Retailers with less than 100m² of retail space in urban areas are exempt from the RVM requirement, though they may volunteer.
The DRS will have a knock-on effect on your waste streams: high-value PET, aluminium, and steel containers will move out of your mixed recyclables collection and into the DRS return network. Planning now for how that affects your container provision and back-of-house logistics is worthwhile.
Mandatory digital waste tracking – from October 2026
Paper waste transfer notes will begin to be replaced by a digital tracking system from late 2026. Start cleaning up your waste data now (site addresses, EWC codes, tonnages, and carrier permit numbers) so you’re ready when the system goes live.
Getting compliant: a practical checklist
If you’re reviewing your current waste management setup, or putting collection arrangements in place for the first time, there are certain things you can do.
Confirm your FTE count
Add up all employees across all sites. Count part-timers pro-rata. Exclude contractors and volunteers.
Audit all your waste streams
Identify where food waste, cardboard, mixed recyclables, and general waste are generated: back-of-house, prep areas, bakery counters, staff rooms, and customer-facing bins.
Choose the right containers for each stream
Food waste containers must be entirely separate. Cardboard ideally has its own dedicated collection. Glass must go in its own dedicated bin and can’t be mixed with dry recyclables. Paper, card, plastic, and metal can share a single dry mixed recycling (DMR) bin.
Appoint a licensed waste carrier
Only an Environment Agency-registered carrier can legally transport food waste. Check the EA’s public register to verify your waste provider.
Set up a weekly food waste collection
Agree a waste collection schedule that reflects your trading pattern. Retailers with fresh produce, bakery, and deli operations should default to weekly collections as a minimum.
Train your team
Staff need to know which stream each material goes into. Clear, visible signage on bins is essential, especially in customer-facing areas.
Maintain duty of care documentation
Keep up-to-date waste transfer notes specifying materials, carrier details, and destination. With digital tracking arriving in late 2026, building good data habits now will save effort later.
Beyond compliance: reducing your waste
Separate collection is the legal floor, not the ceiling. Retailers that measure their waste volumes often find opportunities to reduce what they generate in the first place.
Redistribution first
Before food waste goes into your collection caddy, consider whether any surplus food is still suitable for donation. Multiple retailers, including Aldi and Iceland, are signed up to the Food and Drink Pact under WRAP’s Food Waste Reduction Roadmap, which targets a 50% reduction in food waste by 2030. At the end of 2025, only around 7% of food surplus in the UK retail and manufacturing sectors was being redistributed.
Packaging design
With EPR fees now linked to recyclability from 2026–2027 onwards, there’s a direct financial incentive to review the packaging your products use and whether your suppliers are moving towards more recyclable formats. Poorly recyclable materials will attract higher fees.
Waste tracking data
Once your separate waste collections are in place, keep your own records of volumes by stream – how frequently bins fill up, which streams are generating more waste than expected. This gives you a baseline to work from, helping you identify where in your operation the most waste is generated and where changes to ordering, stock rotation, or prep processes could reduce volumes and costs.
How 360 Waste Management can help
360 Waste Management provides commercial waste collections for retail businesses across England. Whether you’re a single-site convenience store getting your collections in place for the first time or a multi-site retail group looking to standardise compliance across your estate, we can help you design a solution that works.
Food waste collections as standard – weekly, with flexible scheduling to fit your trading hours; Cardboard and mixed recyclables collections, with containers in a range of sizes and no bin rental fees; Collections seven days a week in many areas; Full duty of care documentation and waste transfer notes; Advice on multi-site compliance and EPR obligations; Zero-to-landfill processing: food waste goes to anaerobic digestion, producing renewable energy and natural fertilizer.
If you’re not sure whether your current arrangements are compliant, or you’d like to talk through what a weekly food waste collection would cost for your site, contact us today for a free quote.
