wrap Workplace Recycling Regulations Guide Instructions
- June 1, 2024
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Table of Contents
wrap Workplace Recycling Regulations Guide
Workplace Recycling Regulations – a guide for caravan parks and campsites
This guide, prepared by WRAP Cymru, should be read in conjunction with the Separate Collection of Waste Materials for Recycling: A Code of Practice for Wales (www.gov.wales/workplacerecycling). This guide provides supplementary advice and should not be read as standalone guidance. This guide is aimed at caravan parks and campsites but may also be useful for those managing other forms of holiday accommodation including holiday parks and resorts. The guide applies to organizations that operate either all year-round or seasonally and whether they are within the private, public or third sectors.
Why you need to recycle?
From 6 April 2024, the new law will mean all workplaces, including caravan
parks and campsites, will have to present the following materials separately
for collection for recycling and arrange for the waste to be collected
separately from other waste. The occupiers of individual caravans that present
their waste directly for collection from their caravan by an authorized waste
collector do not fall within the scope of the Regulations. All sizes of the
site are included, regardless of onsite services provided. If you dispose of
visitors’ or customers’ waste – e.g. by providing bins on a caravan park or
campsite, the regulations apply to this waste too.
…and what to recycle?
- Paper and card;
- Glass;
- Metal, plastic, and cartons and other similar packaging (for example coffee cups);
- Food – all premises that produce 5kg or more of food waste in any seven consecutive days;
- Unsold small waste electrical and electronic equipment (sWEEE); and
- Unsold textiles.
This law only applies to household-like waste produced by workplaces, that is waste that is usually found at home and routinely collected from the kerbside. A full list of recyclable materials that should be presented separately for recycling is available here: The Separate Collection of Waste Materials for Recycling: Code of Practice. (www.gov.wales/workplacerecycling)
How to better understand your waste and recycling
To understand the different types of waste your caravan park or campsite
produces, undertake a waste audit by walking through the different areas
within your site. This may include caravan and camping areas, guest facilities
such as washing up areas and shower blocks, offices, on-site facilities such
as cafes, shops, or lounge areas, to examine the contents of general waste
bins, and to highlight any waste reduction or recycling efforts that are
already in place. In addition, think about the people who will be using your
facilities and the types of waste that they may produce.
Within your site, the areas most likely to generate waste will include:
- Guest and holiday accommodation – food (spoilage, preparation, and plate waste), packaging waste such as drinks cans, plastic and glass bottles, drinks cartons, cardboard, and paper.
- Kitchens and any on-site cafés:
- Food preparation areas – food (spoilage and preparation waste), packaging such as metal, glass, cardboard, plastic films and wrapping.
- Food consumption areas – food (plate waste), packaging waste such as drinks cans, plastic and glass bottles, drinks cartons, cardboard, and paper;
- Staff room/mess room/office – paper, food, and packaging materials;
- Public areas such as washing up areas and shower blocks – uneaten food, packaging waste such as drinks cans, plastic and glass bottles, drinks cartons, cardboard, and paper;
- On site facilities such as shops or lounge areas – paper and packaging materials such as cardboard, plastic films and wrapping; and unsold textiles and unsold small electricals.
Depending on the specific nature of your business and the services you provide, you may produce different types of waste, for example, cooking oils and fats, disposable camping gas cylinders or batteries that will require a specialised waste collection service.
Preventing waste in the first place
Reducing or preventing how much waste you produce will help to save money and
reduce the size of bins you will need.
Here are a few tips to reduce your waste:
- Provide site information and maps for guests/ visitors which are accessible on smartphones rather than printed copies.
- Set up a collection point or donation station for any unwanted or surplus items your guests may want to donate at the end of their stay, this could include unopened, non-perishable food, children’s toys and games, buckets and spades, or tourist information on local destinations. These can be used by other guests or donated to local charities.
- Donate surplus or unsold stock from any onsite catering premises – donate surplus food to charity or have an employee fridge for products that they can eat or take home free of charge. Guidance is available on How food businesses must dispose of food and former foodstuffs – (www.gov.uk).
- Use paperless marketing and communication methods, email welcome packs, and site information.
- Purchase recycled, refillable or reusable products wherever possible.
- Provide water fountains for staff and guests to use.
- Use reusable cups, crockery, and utensils in catering services.
- For take-away drinks encourage customers to bring their own reusable cup by charging for single-use cups.
- Ensure that packaging on your takeaway food and drink is minimised and that what packaging is used, can be recycled, or reused.
There may be some costs to making these changes for some sites but increasing how much you recycle could reduce your waste disposal costs in the medium to long run. As this law applies to all food and drink caterers, it will be factored into business and management models.
How to comply with the new recycling law
We recommend that you read The Separate Collection of Waste Materials for Recycling: Code of Practice (www.gov.wales/workplacerecycling) to double check you are doing everything you need to. This includes a list of all the specific types of things that have to be recycled. The occupiers of individual caravans that present their waste directly for collection from their caravan by an authorised waste collector do not fall within the scope of the Regulations. However, where caravan parks or campsites have communal waste collection arrangements, the waste must be separated in accordance with the Regulations. (See section 5 of the Code of Practice for full detail).
How to arrange a new recycling service
- Speak to your existing waste collector about your recycling needs and how they can work with your current collection service;
- Your recycling collection service, including the number of bins and how often they need emptying, may need to be flexible to take account of peaks and troughs in the tourist season.
- Speak to your collectors to decide it if is worth having recycling collections on certain days of the week e.g. after busy weekends or ‘changeover days,’ this will help prevent waste and recyclables building up;
- Maybe little and often works better for you. Most waste collectors offer different container sizes, including sacks for some waste. Once you start recycling you might be able to reduce the size of your general waste bin;
- You could also get quotes from a range of collectors to get the best price and the most suitable service for you.
If requested, councils must arrange waste and recycling collection services for you. There is a charge for these services. In rural areas you may find that options for waste and recycling are more limited, and that only councils will provide a collection service to you, especially if you do not produce a lot of waste.
Space for your bins?
It is understood that space is at a premium in caravans and other types of
holiday accommodation. There is no expectation or requirement to provide
individual recycling bins for each stream in each caravan or accommodation
type. The Regs do not set out requirements for bin configurations – the
requirement is only to separate at the point of presentation for collection
(refer to paragraphs 7.14 – 7.16 in the Code of Practice). How a premise
collects the specified materials is down to the owners of the site. There is
no set way of how to collect the materials. The specified materials collected
communally from a caravan site must be presented to the waste collector
separately for recycling. It cannot be presented mixed to be sorted by the
waste collector later. The method used to organise this within the units would
need to be arranged on a case-by-case basis.
Options to collect materials from caravans include:
- Providing recycling stations at central and easily accessible locations across the site and ask visitors to take their recyclables to these locations;
- Providing small, stackable containers in accommodation units; or
- Providing clearly labelled coloured bags to assist guest with storing and transporting their recyclables to the recycling stations.
Ensure that containers and waste storage areas:
- Are clearly labelled to avoid contamination. You can use labels from the Business of Recycling Wales website (businessofrecycling.wrapcymru.org.uk).
- Are safe and accessible for people, including users with disabilities, and your waste collector.
- Are not in locations that cause an obstruction, a fire hazard or block escape routes.
- Provide sufficient capacity to cope with the types and amounts of waste and recyclables you produce and store between collections.
- Are not located near food preparation or storage areas for food safety and hygiene reasons.
- Close to where the waste and recycling is generated, i.e. in areas with high footfall at the entrances or exits, communal areas, concourses, next to concessions, food preparation areas, next to the facilities at campsites.
- Are tidy, clean, and free from clutter or loose waste.
- Are secure with close fitting lids, and do not allow waste or recycling to escape.
Engaging with clients, visitors, and employees
Engaging with visitors and guests:
- include messaging about your recycling system on your website and any social media channels, green and sustainable tourism is very popular;
- any recycling initiative should be a part of the experience and not seen as an ‘add on‘;
- communicate clearly with your guests before, during and possibly after their stay;
- To keep recycling bins free from contamination ensure they are clearly labeled with what can and cannot be placed in the bins and can be easily located on your site via site maps or on-site signage;
- Provide clear information on your website and as part of the welcome pack provided to holidaymakers on the recycling schemes in place and any other ‘green’ initiatives you are developing or implementing;
- Promote any successes, e.g. any increase in recycling rate;
- Ask guests for feedback on their stay and include how the recycling collection worked or could be improved.
When engaging with employees:
- Ask for ideas on how a scheme may work, as they may have spotted opportunities or issues that you have not considered;
- Provide clear instructions on what they should do with different waste streams or recyclables to help you meet your new recycling obligations;
- Provide training to permanent, seasonal, and temporary workers. Use orientation training to ensure new starters can recycle from day one, with regular training and reminders for all employees;
- Share information about recycling via regular updates at team meetings and on staff noticeboards so that employees hear about the differences their actions are making and
- Ask for feedback if recycling systems are not working well, ensure employees feel listened to and that issues are identified promptly before they cause bigger problems.
There are posters and resources available to download from the Business of Recycling Wales site that lists clearly which items are recyclable. We would suggest including recycling information on materials you provide for visitors and staff. (businessofrecycling.wrapcymru.org.uk)).
Managing the system
Some holiday businesses have expressed concern that their guests will not
comply with the recycling systems and that their staff will then have to sort
through bags of waste. This is not the intention of the new laws.
- You will need to ensure that the recycling bins are clearly labeled, the recycling system in place is communicated to staff and visitors and sufficient containers are provided for your staff and guests to use it correctly.
- You are advised to monitor the effectiveness of your recycling system and make any changes needed to ensure it is working well.
- You are advised to speak to your waste collector about contamination tolerance and the procedures they have for dealing with contamination.
- The Code of Practice (paragraph 7.37) contains more detail on steps you are advised to take about contamination.
Compliance
- You will need to be able to demonstrate to the regulators that you are taking all reasonable steps to comply with the new regulations.
- Where non-compliance occurs, Natural Resource Wales (NRW) may provide advice and guidance as a first response where appropriate.
- For more serious incidents or persistent non-compliance, NRW has the power to take a firmer approach where necessary, including both civil sanctions (fixed and variable monetary penalties) and criminal proceedings.
- The fixed monetary penalties will be either £300 or £500 depending on the breach for each incident.
Product Information
Specifications
- Target Audience: Caravan parks, campsites, holiday parks, resorts
- Applicable Organizations: Year-round or seasonal operations in private, public, or third sectors
Frequently Asked Questions (FAQ)
Q: Who does the law apply to?
The law applies to all workplaces including caravan parks and campsites
that must separate specific materials for recycling starting from April 6,
2024.
Q: What types of waste are included for recycling?
The law covers household-like waste commonly found at home and routinely
collected at the curbside. Refer to the provided list of recyclable materials
for details.