Commercial waste management for hospitality businesses

Your duty of care for waste

Every hospitality business produces commercial waste, from food scraps and packaging to cooking oil and cleaning chemicals. Under section 34 of the Environmental Protection Act 1990, you have a legal duty of care to ensure your waste is stored, transported, and disposed of properly.

This duty applies to all waste your business produces. Unlike household waste, commercial waste is not collected by your local council as standard. You must arrange your own waste collection through a licensed waste carrier, and you remain legally responsible for your waste even after it leaves your premises.

If your waste causes pollution or is found fly-tipped, you can be held liable unless you can demonstrate you took reasonable steps to prevent it. Fines for breaching your duty of care are unlimited.

Choosing a waste carrier

You must use a waste carrier registered with the Environment Agency (or the equivalent body in your nation). It is a criminal offence to allow an unregistered carrier to remove your waste.

Before contracting a waste carrier:

• Check registration: Search the Environment Agency public register at environment.data.gov.uk to verify your carrier holds a valid upper-tier or lower-tier registration
• Get a written contract: Agree what waste types will be collected, how often, and where waste will be taken
• Complete waste transfer notes: Every time waste is collected, you and the carrier must complete and sign a waste transfer note describing the waste type, quantity, and Standard Industrial Classification (SIC) code
• Keep records for 2 years: You must retain waste transfer notes for a minimum of 2 years. Hazardous waste consignment notes must be kept for 3 years

If your carrier cannot show a valid registration number, do not hand over your waste. Using an unregistered carrier is an offence even if you did not know they were unregistered.

Cooking oil and fat disposal

Used cooking oil and fat from commercial kitchens must never be poured down drains. Fat, oil, and grease (FOG) solidify in sewers, causing blockages that can lead to flooding and environmental damage. Water companies can pursue prosecution and seek costs for sewer repairs.

To dispose of used cooking oil properly:

• Collect in sealed containers: Allow oil to cool, then pour into dedicated collection drums. Never mix with other waste
• Use a registered collector: Specialist waste oil companies collect used cooking oil, often at no charge or even paying for large volumes. The oil is typically converted to biodiesel
• Install grease traps: Grease traps or interceptors prevent FOG entering the sewer system. Many water companies require them as a condition of trade effluent consent
• Maintain grease traps regularly: Empty and clean grease traps according to manufacturer instructions. Overflowing traps defeat their purpose and can result in enforcement action

Food waste and Simpler Recycling (England)

The Environment Act 2021 introduced requirements for businesses to separate recyclable waste streams, including food waste. These requirements apply in England only and are being phased in under the Simpler Recycling regulations:

• From 31 March 2025: Workplaces with 10 or more full-time equivalent employees must arrange separate collection of food waste for recycling or composting
• By 31 March 2027: Micro businesses (fewer than 10 full-time equivalent employees) must also separate food waste

Food waste must be collected separately from general waste and other recyclables. Your waste carrier should provide dedicated food waste bins or caddies. Hospitality businesses typically generate significant food waste, so starting separation early and training staff on what goes where will ease the transition.

Reducing food waste also saves money. Audit your food waste to identify where savings can be made through better stock management, portion control, and menu planning.

Trade effluent from kitchens

If your kitchen discharges liquid waste (trade effluent) into the public sewer, you need trade effluent consent from your water company. This applies to most hospitality premises with commercial kitchens.

Trade effluent from kitchens includes water contaminated with food residues, cleaning chemicals, fats, oils, and grease. Discharging trade effluent without consent is a criminal offence under the Water Industry Act 1991, with unlimited fines.

Your water company may require you to install pre-treatment equipment such as grease traps, grease recovery units, or settling tanks before granting consent. Consent conditions typically specify maximum discharge volumes and pollutant concentrations.

Contact your local water company to apply for trade effluent consent before you begin trading. Processing applications can take several weeks.

Packaging waste obligations

The Extended Producer Responsibility for packaging (pEPR) scheme has two tiers of obligation:

• Small producers — turnover of £1 million or more and handling more than 25 tonnes of packaging per year: you must register and report your packaging data annually (by 1 April)
• Large producers — turnover of £2 million or more and handling more than 50 tonnes of packaging per year: full obligations apply, including six-monthly data reporting, recycling obligations, and disposal fees invoiced through PackUK, the scheme administrator

Most small hospitality businesses fall below these thresholds. However, larger hotel groups, catering chains, and food manufacturers may need to:

• Register as an obligated producer with the Environment Agency (or the equivalent body in your nation)
• Purchase packaging waste recovery notes (PRNs)
• Submit packaging data returns
• Pay pEPR disposal fees to fund local authority collection costs

Even if you are below the thresholds, good practice is to minimise packaging waste and choose recyclable or compostable materials where practical.