How to comply with the separate collection requirement for waste
Since 1 January 2015 waste paper, plastic, metal and glass must be collected separately.
Separately collecting these materials apart from other wastes will improve the quality of recycled material by reducing contamination at the point when the recyclable material is collected. This should increase the total quality, quantity and value of recyclable materials produced across the UK.
The separate collections requirements implement the European revised Waste Framework Directive. The European Commission guidance on the Directive states that the separate collection of these materials could take the form of comingled collections (collection of mixed dry recyclable materials in a single collection) provided that the outcome from the sorting process results in material for recovery is of no worse quality than that resulting from separate collection of the materials.
Who has to comply with the separate collection requirement
These requirements are from the Waste Regulations (England and Wales) 2011, as amended. Waste collection operators including private companies, social enterprises and local authorities will need to provide their customers with separate collections for paper, metal, plastic and glass.
This applies to wastes from all sources:
- industry (including construction and demolition)
- commerce (including retail, hospitality and offices)
If these four materials are collected comingled, the waste collection operator needs to demonstrate that it has assessed whether the recyclable materials it collects and the outputs from the ensuing sorting process are of the required quality for the receiving reprocessing industries (the “Necessity Test”), and that it is not technically, environmentally and economically practicable (TEEP) for it to collect waste paper, glass, plastics and metals separately.
Once the four waste materials for recycling have been separately collected either through separate collections or a comingled collection followed by the necessary materials sorting process at a Material Facility, the regulations require the materials to be kept separately and not mixed with other wastes or other materials with different properties.
Guidance on the necessity test and the TEEP process is published by Welsh Government.
This requirement sits alongside the waste hierarchy in part 5 of the regulations.
We are responsible for ensuring that waste collectors and permitted waste management facilities in Wales comply with these new requirements.
We have written to all the upper tier registered waste carriers and environmental permitting regulations permitted waste facilities in Wales to advise them of the regulatory requirements.
The outcomes from comingled waste collections will be monitored through the Materials Facilities regulations under the Environmental Permitting regulations 2014.
Welsh Government’s role
The Welsh Government have published Guidance on the separate collection of waste paper, metal, plastic and glass which will help you understand the requirements.
It also sets out the method which Welsh Government believes will enable local authorities, private waste management companies and social enterprises that collect, transfer or receive waste paper, metal, plastic and glass to comply with their duties under the regulations.
Waste producers' role
Whilst these requirements place a duty on the waste collection and management operators, there is no specific duty on the producer.
However waste producers are reminded of their obligations under the pre-treatment requirements for landfill waste and should either:
- Treat their own waste and provide information about the treatment for subsequent holders; or
- Ensure that a subsequent holder will treat the waste before it is landfilled
Participating in separate collection would be considered a form of pre-treatment and would contribute to delivering better quality materials for recovery.
Waste producers must also comply with the requirements of ‘Duty of Care’ and apply the waste hierarchy.