Defra releases FAQs for Simpler Recycling

The document has been exclusively shared with letsrecycle.com by the ESA and can be viewed here.  

It was originally shared with the ESA, UROC and several local authority networks. 

Following the start of Simpler Recycling for businesses on 31 March 2025, the document aims to clarify the requirements for waste collectors and support discussions with customers who are looking to implement changes.  

The guidance will be further updated over summer 2025. 

This is the second version of the FAQ document and includes several key changes.  

Disposal of commercial waste in public litter bins 

The document clarifies that it is it is a criminal offence for workplaces to dispose of commercial waste via public litter bins, as a breach of their duty of care. 

All workplaces must have appropriate waste collections in place to comply with Simpler Recycling – meaning they must separately collect residual waste, dry recycling and food waste.  

They also have the option to separate paper and cardboard from other dry recycling such as plastic, glass and cans. 

Food waste collection frequency 

The document clarifies that there is no minimum number of food waste collections the business must organise per month (or other timeframe).  

The ESA clarified that some businesses have been asking waste collectors for a monthly collection, which is not feasible to deliver on the ground – due to the potential issue of pests at the workplace, but also because of the permit issues for the receiving site (e.g. local resident complaints about rotten smelling food waste etc).  

To address this, the document now refers to the need to “mitigate issues arising from pests or odours” when considering food waste collection frequency. 

Staff removal of food waste from workplaces 

The document states that staff should not be taking any waste home that is generated by workplace, for example tea bags or coffee grounds that are provided by the workplace. 

If businesses choose not to have a food waste collection in place and instead make 

alternative arrangements with staff, they should be satisfied that these are compliant with the legislation and may need to seek legal advice. 

University accommodation 

The document sets out several ways to identify whether private student accommodation forms part of the university:  

• Is the accommodation managed and controlled by the educational establishment, or a contractor on its behalf? 

• Is the accommodation provided in partnership with an educational establishment primarily for the use of the university students? 

• Is the accommodation for the exclusive use of the university and its students during term time (only available to students at the university)? 

• Does the university (independently or through its contractor) have a duty of care over the occupants of the building, e.g. maintenance of facilities, provision of services such as cleaning? 

• Does the university set expectations and hold jurisdiction over the behaviour/conduct of students on the accommodation premises? 

The document asserts that if private student accommodation forms part of the university it is the intention of the policy that it is in scope of the non-household requirements.