Wales Workplace Recycling regulations: A comprehensive guide for businesses
Welcome to our comprehensive guide to the new Wales Workplace Recycling regulations, due to take full effect from 6th April 2024.
These regulations, in accordance with section 45AA of the Environmental Protection Act 1990 are designed to enhance waste management practices across Wales by emphasising high quality recycling. Applying to all premises excluding domestic properties and caravans, with hospitals granted an extra two-year compliance window, these regulations mandate the separation of specified recyclable materials at the source.
To comply, your premises will need to demonstrate that specified recyclable materials are separated at source, kept separate and then placed into collection containers by type. This will mean that you will need to ensure you have internal receptacles such as bins and containers to effectively sort your material at source.
We’ve covered everything you need to know with a tailored list of Frequently Asked Questions (FAQs) that will explain what this means for you and your business:
What needs to be separated?
Specified recyclable waste materials need to be separated for collection, stored separately, and kept separate after collection. The six specified waste types include:
When will this happen?
The new external service will commence the week beginning 6th April 2024. However, we encourage all businesses to start segregating recyclable items immediately to be equipped and familiar with the upcoming changes.
Is my business obligated?
Almost certainly, yes. The separation requirements apply to controlled waste from non-domestic premises, including commercial, industrial and public sectors.
What are my obligations as an occupier of a non-domestic premises?
Your business must comply with the specified separation requirements when you present waste for collection, with the nine specified recyclable waste materials presented for separate collection in a minimum of six separate recyclable waste streams specified within the regulations. This means that if your site produces all of the types of waste specified, it must be presented for separate collection, as a minimum, in six separate containers. These containers can be bins, bags, boxes, skips or other type of container as appropriate, taking into account the nature and quantity of the waste produced.
A waste management company like Forward Waste Management will be able to advise you of any additional waste items or materials that can be recycled beyond those specified by the Regulations. If this is the case, you are encouraged to also recycle these materials.
You must ensure that the packaging items placed in each recyclable waste stream are empty of their contents and are clean. Other non-packaging items need to be free of significant contamination.
Compliance with the separation requirements should be facilitated by providing clear information to staff (including any contractors) and the provision of clear signage explaining what should and should not be put into the different waste containers.
Residual non-recyclable waste collections may still be required alongside the collection of recyclable waste as part of an overall integrated waste management solution.
Do I have to provide a separate bin for each recyclable waste stream within my premises?
When presenting your waste for collection, you will need a separate container for each recyclable waste stream, however this is not the case in respect of internal bins for occupiers, staff, visitors etc. as it is recognised that this will not always be practical or achievable.
It is considered good practice to provide separate containers for each recyclable waste stream wherever waste is collected on your premises. This will help simplify any sorting requirements upon collection and also reduces the risk of contamination between different recyclable waste streams.
If there are waste bins on your premises where waste from more than one recyclable waste stream is mixed, you will need to separate out the materials into the specified separate streams in accordance with the separation requirements when you present them for collection.
What key steps can my business take to comply?
Take adequate measures and provide training to your staff so that they can meet the separation requirements and facilitate high quality recycling.
Ensure effective, accessible and inclusive information and clear signage is provided to staff and visitors so that they understand the waste materials that should and should not be separated for recycling.
Keep a record of the operating procedures and other documentation you have in place for staff, contractors and visitors to ensure the premises you occupy is compliant with the separation requirements. These records could help if or when inspected by the regulator, Natural Resources Wales.
What does this mean for my premises and what changes do I need to make?
If you are a Forward Waste Management client, your site will already operate specific source segregation facilities for various materials listed within the Wales Workplace Recycling regulations.
Your Customer Account Manager will have arranged a waste audit at your site, followed up by a compliance action plan, tailored to waste streams produced, reflecting the Workplace Recycling regulations and the needs of your business.
What will happen to waste collections from my site?
A separate collection will take place for each of the items by type listed in point 1.
What obligations do waste management companies such as Forward have as your waste and resource management partner?
As the link between your business as a waste producer and the reprocessing sector, waste management companies have an obligation to ensure that recycling services are designed and operated to yield waste of sufficient quality to support the priority high quality recycling outcomes.
We are bound to specific Collector’s separation requirements that mean through collecting or arranging for collection of one or more of your recyclable waste streams, we must comply with the Collector’s separation requirements. This means we must collect each recyclable waste stream separately. Collection and subsequent handling of these waste streams must be sufficient to ensure that separation is maintained throughout.
Wherever we receive, keep, treat or transport waste materials, we are obligated to comply with the Handler’s separation requirements. This means the separately collected recyclable waste streams must not be mixed with any other recyclable waste stream or with other types of waste.
What if the recyclable waste stream is highly contaminated?
If a recyclable waste stream is presented for collection that is so contaminated (either the recyclable materials are significantly contaminated and/or if incorrect items have been placed in the container) that it would be unacceptable for recycling, the collection could be refused.
What about residual general dry waste (GDW)?
A well operated recycling system should ensure a high capture rate with very little, if any, of the specified recyclable materials left in the residual stream.
Under section 45(1)(b) EPA. 22 8.9 we can still provide residual waste collections if required, but you should not put any of the recyclable waste sub-fractions into the residual waste stream.
When collecting waste, it may be apparent that recyclable waste is being placed into the residual stream, or placing recyclable items into the incorrect recyclable waste stream. This is not compliant with the requirements set out in the Regulations and we will provide advice and further support of non-compliance in writing if necessary.
If prompt action is not taken by the waste producer to rectify compliance problems, we may be required by law to refuse to collect any waste streams / containers that do not comply with the requirements.
What about existing Dry Mixed Recyclable (DMR) collections?
The new Workplace Recycling regulations apply equally to any existing DMR (Dry Mixed Recyclable) collections, which will need to be segregated at source.
How should my business demonstrate compliance?
As the regulator responsible for ensuring compliance with Regulations, Natural Resources Wales can visit or contact you to assess your compliance. You may be asked to provide information and evidence relating to your waste collection arrangements, and it is advisable for relevant records to be kept to help demonstrate compliance. This evidence could be documents that you already have a legal requirement to keep, such as under the waste duty of care which requires you to produce and keep waste transfer notes, which will show when, how and who collected the waste and waste types.
Under Duty of Care regulations, if you are a client, Forward will continue to maintain records to demonstrate compliance. The notes must be kept for at least two years. Other evidence could include your Forward waste service contract, which will help demonstrate that waste is being separately collected in a compliant way.
What happens if we do not comply with the new Wales Workplace Recycling regulations?
Failure to comply with the separation requirements is an offence with no upper limit on the courts’ power to fine. A civil sanction may be issued for failure to comply with the separation requirements, in place of criminal prosecution.
What do you need to do next?
If you are a current client of Forward Waste Management, your appointed Customer Account Manager will be in contact soon to speak to you or if necessary arrange a site survey meeting in order to inspect the different waste streams generated at your site and to discuss best options to enable alternative collection arrangements.
If you have an immediate query, please contact Forward Waste on 029 2048 7504 or contact our Customer Service helpdesk directly on 029 2048 7504 option 1.
If not, further information can be found in the link below:
If you are unsure on what you or your business need to do amidst these changes, or if you’re looking for advice on how you can improve your recycling practices within your organisation, get in contact here. We can ensure that your business is equipped with strategies to improve your waste management while keeping in line with changing regulations.
For any immediate concerns or queries, please do not hesitate to get in touch.
Together, let's embrace these changes to create a more sustainable future for businesses and the environment alike.