The Waste Separation Requirements (Wales) Regulations 2023 raise an interesting issue for businesses and waste collectors alike.
Workplaces must separate the specified recyclable waste streams and those streams must be collected separately. Welsh Government guidance is equally clear that putting everything into a single bin is not permitted where the specified recyclable materials are present.
This guidance does not mean that a waste contractor cannot offer a residual-waste-only service.
A business might legitimately use one contractor for its separated recycling streams and another contractor for the residual waste left after that separation has taken place.
Identifying a business as a “general waste only” customer of a particular collector tells one very little about whether that business is complying with the Regulations.
The more interesting regulatory question is what is actually being accepted in the general-waste bin.
If the waste stream is residual waste, that is one thing.
However, if prescribed recyclable materials that should have been separated at source are routinely being accepted in that bin on the understanding that they will simply be sorted out down the line at a transfer station, that is quite another.
For waste businesses, this makes the evidence important:
- What EWC/List of Waste code is used for the general-waste service?
- How is the waste actually described on the transfer note?
- What do the customer terms say may and may not go into the bin?
- Are instances of incorrectly presented recyclable material identified and recorded?
- What action is taken with the customer when this happens?
- What do drivers and waste-reception staff do when obvious recyclable material is found?
- Are rejected loads and customer warnings documented?
Good regulatory compliance is increasingly about being able to demonstrate not simply where waste ultimately goes, but what should have been separated before collection, what the collector agreed to accept and what controls actually operated when the waste was collected and received.
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