Guide
Commercial Recycling Compliance: What EHOs and Auditors Actually Ask For
Most commercial recycling audits are not lost on intent. They are lost on paperwork nobody can find and a bin store that contradicts it. This is what gets asked for, from the operator that supplies the containers and the data.
Commercial & trade only — not a domestic service.
The short answer
- Three things get asked for: your waste transfer documentation, evidence that the required streams are actually separated, and a carrier licence check for whoever takes the material away.
- Under Simpler Recycling, workplaces in England with 10 or more full time equivalent staff must separate dry recyclables and food waste from general waste. Businesses under that threshold follow from 31 March 2027.
- Waste transfer documentation has to be kept for two years and has to describe the waste accurately. A folder of vague notes is where most audits come unstuck.
- Separation is the evidence. A site with the right containers, labelled and used properly, passes on sight. A site with one bin and a good explanation does not.
This is a practical guide, not legal advice. Rules change and exemptions exist, so check your own position against the current government guidance or your regulator.
What actually gets asked for
Six things come up again and again, whether the visitor is an environmental health officer, a client auditor or a landlord doing a site inspection.
Waste transfer documentation you can actually put your hand on
Under the waste duty of care, every transfer of business waste needs documentation describing what the waste is and who took it, kept for two years. In practice the failure is never the existence of the paperwork, it is that nobody on site can find it or the description says something useless like general waste. We keep the documentation on file for every stream we collect, so producing it is a request rather than a search.
A licensed carrier, checked rather than assumed
You remain responsible for your waste after it leaves your yard. That means checking the registration of whoever collects it, and being able to show you checked. Ask any provider for their waste carrier registration number and verify it on the public register. It takes a minute and it is the single easiest thing to get wrong by assumption.
The required streams, separated in practice not on paper
Simpler Recycling requires dry recyclables and food waste to be kept separate from general waste in most English workplaces. An inspector does not read your policy, they look at your bin store. Containers that are present, correctly labelled, sized for the volume and visibly used for the right material are the evidence.
Food waste in a sealed container, not in with the general
For food businesses this is the one that draws attention fastest. Food waste in a general waste bin is a hygiene issue and a separation issue at the same time. A sealed caddy or bin on a frequency that matches output resolves both, and gives you a clean line on your paperwork.
Diversion and tonnage figures if anyone above you asks
Landlords, clients, framework agreements and ESG reporting increasingly ask for numbers, not intentions. Recycling and diversion reporting is where a lot of providers go quiet. We treat the reporting as part of the service rather than an extra, because a figure you cannot produce is a claim you cannot make.
A bin store that is clean, proofed and someone's responsibility
Environmental health officers pay attention to the store itself, not only the bins in it. Waste on the floor, overflowing containers and no obvious owner for the space all read as poor control. On shared or multi tenant sites this needs to be somebody's named job, usually the landlord or managing agent.
Separation is the evidence, not just the rule
It is worth understanding why separation gets so much attention on an inspection. It is not only that the law requires it. A properly separated store is self evidencing. Cardboard in the cardboard container, food in a sealed caddy on a short cycle, glass kept out of the mixed stream, and the general waste bin visibly smaller than it used to be. Someone walking the site can see the system working without reading a single document.
The reverse is also true. One overflowing general waste bin tells an inspector that either the separation is not happening or the collection frequency is wrong, and both are your problem to explain. Getting the streams and the container sizes right is the fastest route through an audit, which is why we start every site with an assessment of what you actually produce rather than a standard package.
The part recycling does not cover: a documented pest programme
Separating your streams properly removes most of what attracts pests to a commercial bin store, because it takes food out of the container that sits longest between collections. It does not, on its own, satisfy an inspector who wants to see pest control being actively managed. For food businesses in particular, a documented programme with inspection records is a separate line item from your waste paperwork, and the two get looked at together.
For commercial sites in London we point customers at JG Pest Control’s London commercial team. They cover every London borough and are open 24 hours a day, with technicians attending every day except Christmas Day, including nights, weekends and bank holidays, so visits can be scheduled around trading hours. Their technicians are RSPH (BPCA) Level 2 certified, and they produce the audit ready documentation that environmental health and Food Standards Agency inspections ask for. They are rated 4.8 out of 5 from more than 26,000 Trustpilot reviews, which is checkable rather than something you have to take on trust.
Being straight about the connection
JG Pest Control is a separate company. FJL is not part of their group and they are not part of ours. The connection is James Gale, director of JG Pest Control (JG Environmental Ltd), who also works with FJL’s managing director on marketing and strategy. It is worth stating rather than presenting this as an arm’s length recommendation. Every claim above is published on JG’s own site and their public Trustpilot profile.
Where we do this
FJL Recycling covers West London, South West London, Surrey, Berkshire and the Thames Valley, including:
- Slough
- Ealing
- Hayes
- Hounslow
- Uxbridge
- Wimbledon
- Maidenhead
- Twickenham
- Wandsworth
- Acton
- Ruislip
- Kingston
Choosing a provider rather than fixing an audit? See how to pick a commercial recycling company.
FAQ
Commercial recycling compliance, common questions.
Do I legally have to separate food waste at my business?
In England, workplaces with 10 or more full time equivalent employees have had to separate dry recyclables and food waste from general waste since 31 March 2025 under the Simpler Recycling rules. Smaller businesses come into scope on 31 March 2027. There are limited exemptions, so check your own circumstances, but for most commercial premises the answer is yes.
How long do I need to keep waste transfer documentation?
Two years for business waste transfers, and three years for hazardous waste consignment notes. Keep it somewhere a manager on shift can reach it, not in a director's inbox. An auditor asking for last quarter's documentation does not want to wait for someone to come back off leave.
Can my bins cause a food hygiene inspection problem?
Yes. Waste storage falls squarely within food hygiene inspection, because it sits at the point where pests, odour and contamination risk meet. Overflowing containers, food waste in general waste, waste bags on the floor and an unclean store are all things an environmental health officer will note.
Who is responsible for waste compliance in a shared building?
You remain responsible for the waste your business produces, even if the store is shared. In practice the workable arrangement is for the landlord or managing agent to own the store itself, with each tenant responsible for their own containers, streams and documentation. Get that written down, because it is the first thing that becomes unclear when something goes wrong.
What does an auditor look for that most businesses miss?
Consistency between the paperwork and the yard. If your documentation says separated dry mixed recycling and food waste, and the store has one general waste bin with cardboard sticking out of it, the paperwork becomes evidence against you rather than for you. Match the two and most of the audit takes care of itself.
Do you provide the reporting I need for ESG or client requirements?
Yes. Diversion and tonnage reporting is part of the FJL Recycling service, so you can put real figures in front of clients, landlords or an ESG report rather than describing your intentions.
Get the streams right and the audit gets easy.
Tell us what you produce and where. We will assess the site, set up the streams and containers you actually need, and keep the documentation and diversion reporting on file. Most new sites start within a week.