If you run a takeaway, a cafe or a small restaurant in England, you have a waste deadline in March 2027 and there is a reasonable chance nobody has told you about it. Worse, some of what is circulating about it is wrong in a way that will leave people non-compliant while believing they are fine.
Here is the short version, checked against GOV.UK rather than against what other waste companies have written about it.
What Simpler Recycling actually requires
Every workplace in England has to separate its waste into three streams:
- Dry recyclable materials: plastic, metal, glass, paper and card
- Food waste
- Everything else, as residual waste
That is it. It is not a recycling target, there is no reporting, and nobody is asking you to weigh anything. You arrange collections for the separated streams and you stop putting everything in one bin.
The dates, and which one is yours
31 March 2025 was the deadline for all businesses, charities and public sector organisations with 10 or more full-time equivalent employees. That date has already passed. If you are in that group and you have not sorted it, you are not waiting for a deadline, you have missed one.
31 March 2027 is the deadline for micro-firms, defined as fewer than 10 full-time equivalent employees. Most independent takeaways, cafes and single site restaurants sit here.
One useful detail that saves a phone call: you do not need to register or apply for the temporary exemption that runs until 2027. There is no form. If you are under ten FTE, the later date simply applies to you.
The trap: the count is your whole business, not each site
This is the part that catches people, and it catches exactly the sort of operator who assumes they are safe.
The employee count is business-wide, not per site. GOV.UK gives the worked example itself: a business with three locations and five employees in each is not a micro-firm, because it has 15 employees in total.
So if you run three small shops, each with a handful of staff, you are a 15-person business. Your deadline was March 2025, not March 2027. Each individual shop feeling small does not change the arithmetic.
Two related points on counting:
- Part-time staff count pro rata. Add a fraction based on their hours rather than counting heads. Two people on half hours are one FTE.
- Volunteers, contractors and self-employed workers do not count towards the total.
That last one matters for anywhere running on volunteers. A community kitchen with two paid staff and fifteen volunteers is a two-employee business for this purpose.
The myth: there is no 5kg-a-week exemption
You will find it repeated across a number of commercial waste company websites: that if you produce under 5kg of food waste a week, the food waste rules do not apply to you.
It is not in the guidance. GOV.UK states plainly that the rule applies no matter how little food waste you have. There is no minimum quantity threshold anywhere in Simpler Recycling.
Where the idea probably comes from is that a very small producer may be able to arrange a much less frequent collection, which is a commercial conversation with your waste contractor and not a legal exemption. If somebody has told you that you are under a threshold, ask them to point at the paragraph. There isn’t one.
Where used cooking oil sits in all this
Used cooking oil is not food waste for these purposes and does not belong in the food waste bin. It is its own waste stream, it has its own classification code (20 01 25, edible oil and fat), and it comes with its own paperwork obligations under the waste duty of care that have applied for years and are unaffected by any of this.
Pouring it into a food waste caddy causes two problems. It contaminates a load that is going for anaerobic digestion or composting, and it throws away something that is worth money to you, because oil separated properly is a feedstock for biofuel rather than a disposal cost.
This is the one point in the whole Simpler Recycling story where the answer makes a kitchen money instead of costing it. Every other stream you are arranging is a bill. Oil is the stream that pays.
What to do before March 2027
You have time, so this does not need to happen this week. What it does need is someone to own it.
- Work out your FTE count across the whole business. If it lands anywhere near ten, work it out properly, because the difference between nine and ten is a deadline that has already passed.
- Ask your current waste contractor what they are providing. Many will already have a compliant three-stream service and simply have not told you. Some will treat the deadline as a reason to sell you something.
- Sort the oil separately, now. It is the easiest of the streams, it is the only one that pays, and if you are not already handing it to a registered carrier with proper paperwork, that is a duty of care problem sitting underneath the recycling one.
- Check your bin store has room for three streams. In a lot of London back yards this is the actual constraint, not the rules.
The other change coming, and what is not yet settled
Something else is moving in roughly the same period, and it is worth knowing about because a lot of people are describing it inaccurately.
Defra is replacing waste carrier, broker and dealer registration in England with a standard rules environmental permit or, for some operators, a registered exemption. Permits will be tiered by activity, scale and waste type, and evidence of technical competence will be required, with continued competence checked at renewal every three years.
Here is the part that is usually reported wrong. Existing registrations do not all expire on one date. The government’s published response describes a staggered transition: upper tier registrants apply for the relevant permit when their existing registration comes up for renewal, which spreads the changeover over about three years. The Environment Agency will write to current upper tier registrants. At the time of writing, the go-live date has not been confirmed, so anyone quoting you a hard deadline for this is guessing.
None of it creates work for you as a waste producer. What it does mean is that at some point the collector taking your oil will need a permit rather than a registration, and it is a fair question to ask them. A collector with no answer at all is telling you something.
Until then the check that matters is the current one: how to check a waste carrier is registered takes about two minutes on the public register.
The honest summary
If you are a single site with under ten staff, you have until March 2027, you do not need to register for anything, and there is no minimum-quantity get-out. If you run more than one site, add up your staff across all of them before you assume the later date applies.
And separate the oil regardless of any of the above, because that obligation predates Simpler Recycling entirely and it is the only part of your waste that comes with a cheque rather than an invoice.
This describes the position in England. Scotland, Wales and Northern Ireland have their own arrangements. It is general guidance rather than legal advice. The Simpler Recycling requirements, dates, employee counting rules and the absence of a quantity threshold are all taken from GOV.UK’s own guidance, and the carrier permit reform from Defra’s published government response, as at the date of this post. We review this page whenever either is updated.