Simpler Recycling: Are your proposed development designs compliant?

At the end of last year, DEFRA (Department for Environment, Food and Rural Affairs) published its Simpler Recycling regulation with the aim of driving consistency and raising England’s performance in recycling across businesses and homes. [1] In its most basic form, the Simpler Recycling regulations require that waste must be separated into four separate waste streams for collection (food waste, paper and card, other mixed recyclables, and residual waste). These regulations will be coming into force for businesses from 31st March 2025 (31st March 2027 for micro businesses) and for homes from 31st March 2026.

The deadline for businesses is looming

DEFRA (the creator of the legislation) and the Environment Agency (the regulator) are delivering various engagement events and roadshows to raise awareness about the impending Simpler Recycling regulations, and the implications for businesses of 10 or more full time equivalent staff (FTEs) as we speed towards the first of several Simpler Recycling implementation deadlines.

Awareness raising activities by the government and regulator, alongside information from a business’s existing waste management contractor, will hopefully drive compliance over the coming months, even if a (potentially significant) proportion of businesses fall short of achieving compliance with the Simpler Recycling regulations by the March 2025 deadline.

But what if a building does not exist yet?

What if the building is yet to be occupied, yet to be constructed or yet to be designed? What then are the implications of Simpler Recycling, and have the requirements been considered in the design process?

A building could be undergoing fit out, in construction, post planning consent mobilisation, in the planning system, or on the architects ’drawing board’. No matter the stage of the project, these buildings should have appropriate space allocated to satisfy the waste management needs of the users of the building. However, did the design team consider the impacts of Simpler Recycling, and if not, how flexible are the waste management interfaces and spaces which have been designed into the building?

Space in any building or larger development scheme is always at a premium, especially when it comes to ground floor or basement level (which tends to be where waste management space will be located). Waste management provision can often be one of the latter thoughts in the building and scheme design development process, and the space made available is often squeezed to the absolute minimum.

This approach can impede the effectiveness of a building’s operation. It can also reduce the building’s future flexibility to respond to changes in waste management requirements (e.g. the Simpler Recycling requirements coming into force) or a building user’s desire to strive for reduced environmental impact by segregating additional material types (beyond the minimum requirements).

Defining the waste management needs of a building’s user(s) is often undertaken by architects, transport consultants (as part of ‘access and servicing’), or specialist waste management consultants. Although local authorities will often publish a waste management design guide for architects and developers, these documents can often be out of date (thus not defining the Simpler Recycling requirements) and potentially misleading. Furthermore, published guidance documents tend not to consider more recent trends in types of accommodation offerings such as build to rent, purpose-built student accommodation, or co-living, and the nuances surrounding the associated operational waste management requirements.

Early use of specialist waste management advice is recommended

Bringing a specialised waste management consultant on to the project design team can help to ensure that the client and architect are fully aware of the latest (and any forthcoming) legislative changes. It also allows liaison between waste management specialists and local authority waste officers (to clarify points, argue for deviations from the design guide, and obtain agreement in principle on proposals prior to planning submission). Some projects could benefit from more innovative methods of waste management to create improved amenity and reduced environmental impact; a waste management specialist can highlight the options and respective pros / cons of the alternative solutions.

Early consideration of the waste management requirements and options available can help to ensure that a scheme will be fully compliant when it comes to a planning application submission and consider forthcoming changes in waste management requirements (such as Simpler Recycling). But more importantly, early consideration and input by a specialised waste management consultant will deliver improved and future proofed buildings for the developer and ultimately the occupants.

Now is the time to ensure your projects can adapt

Confirming a building’s compliance, or identifying how (and how easily) a building currently in the development process can be adapted, should be undertaken as soon as possible to achieve the requirements of Simpler Recycling for businesses (from 31st March 2025) and residential users (from 31st March 2026, unless the local authority has obtained a derogation).

If you are you a developer, an architect, or part of the design team for a new building or larger development scheme, we recommend that waste management and future proofing the waste management aspects of your project are added to the agenda of your next design team meeting.

How SLR can help

SLR provides multi-disciplinary support to Built Environment projects. Our specialised and experienced Sustainable Waste Management team works across the residential (including high rise), commercial, leisure, care, and industrial sub-sectors providing high level strategic advice on waste management options through to detailed design development with architect teams, to ensure building designs consider waste management interfaces and include waste management solutions which are compliant and future proofed. Our team works across development and redevelopment projects of all sizes, from single buildings to large scale masterplans.

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References

1. https://www.gov.uk/government/publications/simpler-recycling-in-england-policy-update/simpler-recycling-in-england-policy-update