waste-separation

---
name: waste-separation
description: Produces one dated bin plan for an English hospitality site - which waste streams the law makes you separate, whether the micro-firm exemption still covers you and until when, what may lawfully go in one bin together, where the food caddies go, and what to ask a waste collector before signing. Use before you renew a waste contract, when a collector tells you that you need a new bin, or when you do not know whether the March 2025 rules already apply to you.
---

# The bins the law actually requires, and no collection you are not required to buy

You give this your site address, your employee numbers, your current waste contract and what you throw away in a normal week. You get back one dated file: whether the duty applies to you today or from 31 March 2027, the streams you must separate with the statutory wording beside each, which bins may lawfully be combined so you do not pay for four collections where three will do, the questions to put to your collector in writing, and what enforcement looks like if you do nothing. It does not tell you that you comply. That is the Environment Agency's call, not a document's.

## What it does

1. **Settle the micro-firm question first, because it decides whether anything else in this file applies to you yet.** The exemption is in regulation 4 of the Separation of Waste (England) Regulations 2025, and it is narrower than it sounds: "Sections 45AZA and 45AZB of the Act do not apply in relation to arrangements for the collection of waste from businesses which are micro-firms until 31st March 2027." The test date is fixed, not rolling: "A business is a micro-firm if, at the time these Regulations come into force, its full-time equivalent employee number is less than ten", and those Regulations came into force on 31 March 2025. So the question is how many full time equivalent staff you had on 31 March 2025, not how many you have this morning. Write that number, the date, and where it came from, into the file.

2. **Calculate the full time equivalent number the way the regulation calculates it, and count the whole business, not the site.** Regulation 4(3) adds the total number of full time employees to, for each part time employee, "a fraction which represents the sum of the total number of hours worked over the previous twelve weeks divided by the number of weeks in which that employee worked at least one hour, as a proportion of the number of contracted hours per week of a full-time employee". GOV.UK adds two things owners get wrong: the count is across the business, so "a business with 3 locations and 5 employees in each location is not a micro-firm (as it has 15 employees in total)", and "Volunteers, contractors and self-employed workers do not count towards the total". There is nothing to apply for.

3. **Write out the streams the statute names, and separate the three things GOV.UK says you must always separate.** Section 45AZB of the Environmental Protection Act 1990, inserted by section 57 of the Environment Act 2021, lists the recyclable waste streams as glass, metal, plastic, paper and card, and food waste. The duty that lands on you as the business is subsection (8): "The person who presents relevant waste from the premises for collection under the arrangements must present it separated in accordance with the arrangements." GOV.UK puts the same thing in bin language: you must always separate "dry recyclable materials (plastic, metal, glass, paper and card)", "food waste", and "non-recyclable waste (also called residual waste)". Three separations is the floor. How many bins that becomes is step 4.

4. **Find out what may lawfully share a bin before you agree to buy another one.** Regulation 3(3) of the 2025 Regulations disapplies the separate-stream condition "in respect of the collection together of any combination of the recyclable waste streams" metal, glass and plastic. So one mixed container for those three is lawful. Paper and card is the exception that costs money: GOV.UK states "Paper and card must be collected separately from plastic, metal and glass. However, if this is not technically or economically practicable, or has no significant environmental benefit, the waste collector can complete a written co-collection assessment." That assessment is the collector's document, not yours. Ask for it by name and keep a copy, because it is the only thing that makes a single dry bin defensible. Dry recyclables may never be collected with food waste.

5. **Test borderline items against the prescribed descriptions rather than against instinct, because several obvious ones are excluded.** Schedule 1 to the Separation of Waste (England) Regulations 2024 does the prescribing. Nothing in the glass, metal, plastic or paper streams counts unless "the waste item is empty" and "not heavily contaminated by other substances", and glass and plastic must "measure a minimum of 40mm by 40mm". The paper and card stream excludes "greaseproof, siliconised or waxed paper", "fibre-based composite cups", "stickers" and "paperback and hardback books", which between them cover much of what a kitchen and a coffee counter produce. Plastic film is in the plastic stream only from 31 March 2027, so it is not yet in force. Food waste is wide: it includes bones, eggshells, fruit and vegetable skins, tea bags and coffee grounds.

6. **Put a food caddy wherever food is generated, and fix the collection frequency in the contract.** GOV.UK is explicit that the food duty does not depend on having a kitchen: "You must collect food waste, even if the workplace does not serve food or have a kitchen. This rule applies no matter how little food waste you have. You should not ask members of staff to take food waste home." Best practice is a caddy in staff rooms and service areas as well as the prep line. A weekly or fortnightly collection is recommended, "It is not recommended that you store food waste for more than 2 weeks", and cooking oil goes with food waste in small amounts or through a used oil collection: "You must never put cooking oil down the drain."

7. **Cover the front of house, because a customer's rubbish is your waste.** The duty reaches "any waste produced by employees, customers and visitors", and GOV.UK says that where you provide bins for customers "you need to separate this before collection too". That is the part that fails in practice, and it fails as contamination rather than as a missing bin. The guidance names the fix: "provide clear instructions, including clear signs on or near bins" and "try to solve recurring contamination issues by monitoring behaviour and making changes to signs, bin locations, or the number of bins". If a dry bin is badly contaminated before collection you "should dispose of it as general waste", and expect a contract clause allowing the collector to refuse it or charge more.

8. **Buy the collection you need, not the one you are quoted, and check the carrier on the register before you sign.** GOV.UK leaves the sizing to you: "You can decide on the size of containers and frequency of collections based on the volume of waste you produce", the collector "can be a private company or your local authority, and you can use multiple providers", and "You must make sure that the company is registered on the Public Register of Waste Carriers, Brokers and Dealers." So volume-count a normal week per stream first, then price it. Put three questions to the collector in writing: which streams they collect separately, whether they hold a written co-collection assessment for paper and card, and their registration number so it can be checked on the register.

9. **Record who enforcement lands on, then date the file and diary the two dates that will change it.** Section 45AZF of the Environmental Protection Act 1990 lets the Environment Agency give a compliance notice, and subsection (4) is short: "A person who fails to comply with a compliance notice commits an offence", liable "on summary conviction or conviction on indictment to a fine". There is a right of appeal to the First-tier Tribunal under section 45AZG. GOV.UK warns that a notice "may also be issued against the landlords or facilities management companies that are presenting waste on behalf of the waste producer", so a leased site needs the responsibility written down. Two dates go in the diary: 31 March 2027, when the micro-firm exemption ends and plastic film joins the plastic stream.

## Then it checks

1. The file states the full time equivalent employee number as at 31 March 2025, how it was calculated, and therefore whether the duty applies now or from 31 March 2027, with no answer given as "about ten" or "we are small".
2. Every stream in the plan is one of the five named in section 45AZB, and the plan shows at least three separations: dry recyclables, food waste and non-recyclable waste.
3. Any bin holding two or more dry streams together is either metal, glass and plastic only, or is supported by a written co-collection assessment held by the collector and named in the file with the date it was obtained.
4. No dry recyclable bin is shown as also taking food waste, and a food caddy is listed for every area of the site where food is generated, including staff areas.
5. The collector's carrier registration number is recorded and has been checked against the Environment Agency public register, with the date of the check.
6. Every requirement in the file quotes its source and the date that source was read, and nothing in the file states that the site complies or that it is exempt as a matter of law.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is. A letter to a waste collector goes out over the name of the person who will have to answer the reply.
- Never tell an owner they are compliant or exempt. Those are conclusions for the Environment Agency and the owner's own adviser, and an owner told "you are fine" by a document stops asking the body that could actually tell them.
- Never state a benchmark for how much waste a venue of a given size produces, a typical cost per lift, or a percentage saving from separating bins. No published figure exists for a single independent UK venue, and an owner who budgets from a borrowed number will conclude their own site is failing when it is not.
- Never treat a collector's verbal assurance as the co-collection assessment. The assessment is a written document with an author and a date, and if it cannot be produced it does not exist.
- Never carry the micro-firm answer forward without re-reading it. The test is frozen at 31 March 2025 but the exemption expires on 31 March 2027, so a file written today is wrong on a known date.
- Refuse to write a bin plan that puts food waste into a dry recycling container, or that relies on staff taking food waste home. Both are contrary to the guidance and the second is named in it.
- This output is a working document prepared for the owner to check with their waste collector, their landlord and their local authority or the Environment Agency before it is relied on. It is not legal advice and it does not certify compliance with anything.

## Built from
- GOV.UK, Department for Environment, Food and Rural Affairs, "Simpler recycling: workplace recycling in England", https://www.gov.uk/guidance/simpler-recycling-workplace-recycling-in-england, published 29 November 2024, last updated 3 October 2025, read 16 September 2026: the three mandatory separations in step 3, the paper and card co-collection assessment in step 4, the food waste duty, frequency and cooking oil wording in step 6, the customer bins and contamination wording in step 7, the sizing, providers and register wording in step 8, the whole-business counting example and the exclusion of volunteers, contractors and self-employed workers in step 2, and the landlord and facilities management point in step 9.
- The Separation of Waste (England) Regulations 2025, SI 2025/140, regulations 3 and 4, https://www.legislation.gov.uk/uksi/2025/140/made, made 10 February 2025, in force 31 March 2025, read 16 September 2026: the micro-firm exemption and its fixed test date in step 1, the full time equivalent formula in step 2, and the metal, glass and plastic co-collection exemption in step 4.
- Environment Act 2021, section 57, as enacted, https://www.legislation.gov.uk/ukpga/2021/30/section/57/enacted, read 16 September 2026: the inserted section 45AZB of the Environmental Protection Act 1990 including the five recyclable waste streams and the subsection (8) duty to present waste separated, used in step 3, and the section 45AZF compliance notice offence and section 45AZG appeal right used in step 9.
- The Separation of Waste (England) Regulations 2024, SI 2024/666, regulation 3 and Schedule 1, https://www.legislation.gov.uk/uksi/2024/666/made, made 20 May 2024, read 16 September 2026: the empty and not heavily contaminated conditions, the 40mm minimum, the paper and card exclusions, the contents of the food waste stream, and the 31 March 2027 commencement for plastic film, all in step 5.
- Environment Agency, "Register of Waste Carriers, Brokers and Dealers", https://environment.data.gov.uk/public-register/view/search-waste-carriers-brokers, no publication date shown on the page, read 16 September 2026: the register the carrier check in step 8 and check 5 is made against.

This is a working document prepared for the owner to check with their waste collector, their landlord and their local authority or the Environment Agency before it is relied on. It is not legal advice and it does not certify compliance.

# waste-separation

## You are given
One English hospitality site's waste position, already judged by Claude. Specifically: the site name and address; the business's full time equivalent employee number as at 31 March 2025 with the working behind it and the judgement of whether the micro-firm exemption applies; a list of every waste container currently on site with its stream, size, collection frequency and price; the current waste contract or quotation; the collector's name and carrier registration number; a list of the waste items the site actually produces in a normal week, each already assigned by Claude to a stream; the statutory stream descriptions and the quoted guidance wording Claude relied on, each with its source URL and the date it was read; whether a written co-collection assessment for paper and card has been supplied, and if so the document; and the site's tenure, naming the landlord or facilities management company where one presents the waste. Where a judgement is missing it arrives as the word `not supplied`.

## Produce
Write into a `./waste-separation-output/` folder:

1. `micro-firm-test.csv` with these columns in this order: `business_name`, `test_date`, `full_time_employees`, `part_time_fte_added`, `fte_total`, `sites_counted`, `volunteers_contractors_excluded`, `exemption_applies`, `exemption_end_date`, `source_url`, `source_read_date`. One row. `test_date` is always `31 March 2025`. `exemption_applies` is exactly one of `yes`, `no`, `not supplied`. `exemption_end_date` is `31 March 2027` where the exemption applies and empty otherwise. `volunteers_contractors_excluded` is `yes` or `no`.
2. `streams-required.csv` with columns: `stream`, `statutory_basis`, `must_be_separate_from`, `may_share_container_with`, `container_on_site_today`, `container_size`, `collection_frequency`, `gap`. `stream` is exactly one of `glass`, `metal`, `plastic`, `paper and card`, `food waste`, `non-recyclable`. `gap` is exactly one of `none`, `no container`, `wrong combination`, `frequency not stated`, `not supplied`.
3. `item-routing.csv` with columns: `item`, `where_produced`, `assigned_stream`, `prescribed_description_matched`, `empty_condition_met`, `minimum_40mm_met`, `excluded_by`, `not_yet_in_force_until`, `source_url`. `excluded_by` is empty or names the Schedule 1 exclusion verbatim. `not_yet_in_force_until` is empty or a date in DD Month YYYY form. Every row's `assigned_stream` is copied from the input and never changed.
4. `co-collection.csv` with columns: `container`, `streams_combined`, `lawful_without_assessment`, `assessment_supplied`, `assessment_author`, `assessment_date`, `verdict`. `lawful_without_assessment` is `yes` only where the combination is any of metal, glass and plastic and nothing else. `verdict` is exactly one of `lawful combination`, `needs a written co-collection assessment`, `assessment supplied`, `food mixed with dry recyclables`, `not supplied`.
5. `collector-check.csv` with columns: `collector_name`, `registration_number`, `register_checked`, `register_check_date`, `streams_collected_separately`, `assessment_held`, `contract_end_date`, `questions_outstanding`. `register_checked` is `yes` or `no` and is never set to `yes` unless a check date was supplied.
6. `enforcement-exposure.md` - a short file naming, in plain sentences, who presents the waste at this site, who a compliance notice would be served on, the appeal route, and the two diary dates. Every statement carries the source it came from. No conclusion about whether the site complies.
7. `gaps.md` - a numbered list of: any stream with no container; any container mixing food waste with dry recyclables; any dry combination beyond metal, glass and plastic with no assessment supplied; any item whose assigned stream is contradicted by a Schedule 1 exclusion; any collection frequency longer than two weeks for food waste; any carrier registration number not checked; any missing source URL or read date; and the micro-firm test if any input to it was `not supplied`.

## Rules
- Codex measures, records, routes and checks. It never invents, never reassigns an item to a different stream than the one supplied, never rewords the owner's or the collector's wording, and never makes the micro-firm judgement that was supplied to it.
- Never write `yes` into `exemption_applies`, `register_checked` or `assessment_supplied` on inference. Each is `yes` only where the input says so and names a date or a document.
- Never state that the site complies, that it is exempt as a matter of law, or that a compliance notice will or will not be issued. Those go nowhere in any file.
- Never write a benchmark, an industry average, a typical cost per lift, a typical weekly tonnage or a percentage saving. No such figure exists for a single independent UK venue and none is to appear in any file.
- Never record a statutory requirement without its source URL and the date that source was read, both copied from the input.
- A rule that has not commenced is recorded in `not_yet_in_force_until` with its date and is never counted as a current gap.
- Quantities are counted or read from a supplied document, never estimated. Where a weight or volume was estimated by the site, the cell says `estimated by site`.
- Use British English, GBP for money and DD Month YYYY for every date. No em dashes in any file you write, and any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with this line: this is a working document prepared for the owner to check with their waste collector, their landlord and their local authority or the Environment Agency before it is relied on; it is not legal advice and it does not certify compliance.

## Return
The absolute path of each file written, the row count of each CSV, the full time equivalent total and whether the exemption was recorded as applying, the number of streams with a container and the number without, the number of containers judged `lawful combination` against those needing an assessment, the count of items whose routing was contradicted by a Schedule 1 exclusion with each item named, the food waste collection frequency as recorded, whether the carrier registration number was checked and on what date, the two diary dates written into `enforcement-exposure.md`, and the `gaps.md` item count.