From 31 March 2025, England's healthcare facilities must comply with new Simpler Recycling regulations that require the separation of household-like recyclable materials, including paper, plastics, metals, glass, and food waste. Paul Sanderson, chief executive of The Recycling Association, outlines the key changes, legal responsibilities and practical steps organisations must take to ensure compliance.
New rules are set to change the way healthcare facilities manage the recycled materials collected in everyday activities in England.
From 31 March 2025, the Simpler Recycling regime kicks in, meaning that there will be new requirements for businesses and public sector organisations.
The only exemption from this is if you have less than 10 full-time equivalent employees and you have until 31 March 2027 to be ready. Although be aware that if you have eight staff members on one site and two on another for example, then the regulations apply this year.
Simpler Recycling only applies to household-like material such as paper and cardboard, plastic bottles, glass jars and bottles, aluminium and steel cans and food waste. Clinical and medical waste should be treated no differently as before.
But any household-like material generated by staff, kitchens, restaurants, coffee shops and brought in by patients will fall under Simpler Recycling.
Separation of waste
Essentially, this means that any of the following need to be separated out for recycling from general waste: food waste including leftovers and food waste generated from preparation in kitchens and canteens etc – even if you only have a small amount of food waste such as from staff leftovers from brought in meals, this needs to be separated; glass drinks bottles and rinsed empty food jars; metal cans, rinsed food tins, empty aerosols, aluminium foil, aluminium food trays and tubes; plastic bottles and rinsed food containers; and paper and cardboard including cardboard boxes, newspapers, envelopes and any other paper-based or cardboard packaging.
There is a legal duty on businesses and organisations to collect paper and cardboard separately from other dry recyclables including glass, metal and plastics. Food should always be kept separate from dry recyclables.
This may mean having separate bins for recycling paper and cardboard, a dry recyclables bin, one for food and another for any residual waste.
Exceptions
However, there is a provision in the legislation where a waste contractor can make a decision that it isn’t technically, environmentally or economically practicable to collect these separately so that the recycling can all be commingled together, although still separate from residual waste and food. They need to produce a written assessment of this and have it ready for inspection by the Environment Agency if requested.
For any facilities based on say a busy, built-up street in a city, this might be a feasible option. But if a site has plenty of space available to separate these materials, then this written assessment is unlikely to be acceptable to the Environment Agency.
If your waste contractor suggests that it will continue to commingle all dry recyclables, it is your legal duty to see if there is alternative provision that would separate the paper and cardboard from the other dry mixed recyclables. You should assume your default position will be to separate the paper and cardboard, unless it is absolutely clear that this isn’t possible.
Where you do separate paper and cardboard from other materials, cartons (such as Tetrapak) that are largely paper-based and used for food and drinks should be collected with plastics. This is because these contain high volumes of plastic, and sometimes metals, that requires specialist recycling rather than at standard paper and cardboard mills.
I’d recommend that you speak to your waste contractor as soon as possible to ensure you are separating the right materials for them to collect. If they tell you they have produced a written assessment that notes it isn’t possible to separate these materials, ask for a copy of it. You should also investigate if any other contractors in your area will collect these materials separately.
It may be that your existing contractor will collect the residual waste and most dry recyclables, while you use a specialist local paper and cardboard merchant and a company that deals with food waste. Don’t just assume your contractor will meet your legal requirements, but check to see if you can arrange alternatives that meet your duty of care under the new legislation.
At The Recycling Association, we welcome these new rules. Sorting technology these days has improved vastly, with many recycling facilities using AI technology to identify and remove materials in the process. Very high quality can be achieved at these state-of-the-art facilities that produce a secondary commodity for use as new products in the circular economy.
But keeping paper and cardboard separate where possible should help raise overall quality. These fibre-based materials are both easily contaminated and a contaminant. Excessive plastics or food waste for example can damage the structure making it harder to recycle. While wet paper and cardboard can attach itself to glass, metals and plastics making these harder to recycle.
The simpler we can keep things, the better to ensure these materials are recycled efficiently.
Guidance
If you need more information, WRAP has produced useful guidance for health and social care workplaces which can be found here.
For those that also offer hospitality-like restaurants and coffee shops, it is probably worth looking at the guidance here.
WRAP are also providing downloadable communication resources to promote recycling in your workplace, and these can be found here.
These new regulations are also an opportunity to assess your overall waste management and recycling provision.
Next is reuse, so can you replace something disposable with something that can be used again and again?
Then recycle, and if that isn’t possible, send to an energy-from-waste facility, and finally landfill.
One other consideration is your sensitive and confidential documents and electronics that store this data.
Firstly, it might be worth considering the waste hierarchy and moving whatever you can up this.
At the top of the hierarchy is prevention, so identify ways not to create waste in the first place, or at least minimise it.
Security
The Recycling Association also runs the United Kingdom Security Shredding Association (UKSSA) that represents companies that offer security shredding services. UKSSA members represent the gold standard of security shredding.
This is because they undergo a strict auditing process every two years to ensure they meet the BS EN 15713:2023 standard when it comes to dealing with your confidential documents and electronic devices. You can be assured that these will be dealt with professionally, data will not escape, and they will be treated in the most sustainable way once destroyed.
If you are offered or use a security shredding service that is not operated by an UKSSA member, then I suggest you ask them to join UKSSA to be audited or choose another contractor.
Overall, it is clear we have done a huge amount to improve our recycling in the UK over the last couple of decades. But we need to take the next steps to ensure we produce less waste, recycle more and send less to energy-from-waste facilities and landfill.
To be a full part of the circular economy, it is essential that the materials we produce for recycling are clean and easy to recycle. These Simpler Recycling reforms in England will go a long way to help with that, and mean we catch up with provisions already in place in the rest of the UK.
