If your business has fewer than 10 full-time equivalent employees, you have until 31 March 2027 to comply with Simpler Recycling. That sounds far away, but compliant waste contracts usually take 2–4 weeks to set up, staff need training, and bin storage often needs reorganising. This guide walks a London micro-business through the practical steps in the order they actually need to happen – from confirming your FTE count, through choosing a waste carrier, to the Waste Transfer Note paperwork an Environment Agency officer might ask to see.
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Are You Actually a Micro-Business?
The Simpler Recycling regulations define a micro-business as one with fewer than 10 full-time equivalent (FTE) employees. The maths is easier than it sounds:
- One full-time staff member (35+ hours per week) = 1 FTE.
- One part-timer at 17.5 hours per week = 0.5 FTE.
- Volunteers, agency contractors not employed by you, and unpaid family members generally don’t count.
- Add up across all sites of the same legal entity, not per site.
Examples in plain numbers:
- Coffee shop, two co-owners, six part-timers at 20 hours each. Owners count as 2 FTE; part-timers = 6 × (20/35) = 3.43 FTE. Total = 5.43 FTE. Micro-business, 2027 deadline.
- Solo electrician, no employees. 1 FTE. Micro-business, 2027 deadline.
- Two-office consultancy, 12 staff across both sites. 12 FTE. Not a micro-business – deadline was 31 March 2025.
If the answer hovers around 9–10, treat yourself as 10+. The penalty for being on the wrong side and miscounting is being non-compliant two years earlier than you thought.
The 2027 Compliance Checklist
The path most London micro-businesses follow has six steps, in this order:
- Audit your waste. Spend a week logging what fills your bins. Most micro-businesses are shocked how much is food waste (cafes, restaurants, busy offices) or paper/card (retail, schools).
- Pick your stream set-up. The regulations require collection of all five streams, but several can be co-mingled. Paper and card may go together. Plastic, metal and glass may go together as ‘mixed dry recyclables’. Food waste is always separate.
- Choose a licensed carrier. Check the Environment Agency’s public register. An unlicensed carrier puts you in breach even if you didn’t know.
- Order bins. A typical small shop or office needs a 240L general waste bin, a 240L mixed dry recyclables bin, optionally a 240L glass bin, and a 240L external food waste bin with internal kitchen caddies.
- Train staff. A single A4 sheet of ‘what goes where’ near every bin cuts contamination dramatically. Repeat at any starter induction.
- File the Waste Transfer Note. After every collection your carrier issues a Waste Transfer Note (WTN). Keep them for two years – this is the document an Environment Agency inspector will ask for.
Realistic timeline: book a free site audit Jan–Feb 2027, accept a quote by mid-February, service starts in March. Don’t leave the call until the last week.
Choosing a Waste Carrier – What to Ask
Most London micro-businesses get quotes from two or three carriers. The right questions cut through marketing copy quickly:
- What’s your Environment Agency licence number? A real carrier will have a CBDU number. Look it up on the public register before signing.
- Do you issue a Waste Transfer Note after every collection, or quarterly? The law accepts a season ticket WTN (covering up to a year of regular collections), but it must be in writing and on file before the first collection.
- What’s the minimum contract term? Three-year contracts with auto-renewal are common and aggressively defended. A one-year rolling agreement is fairer for a small business.
- What are the ‘extras’? Fuel surcharge, environmental levy, congestion charge pass-through, missed-collection fee, container rental, container exchange fee. Get the all-in monthly figure in writing.
- What happens if my volume changes? Most carriers will upsize for free, but downsizing tends to cost. Ask before signing.
Cheapest quote isn’t always the lowest real cost – surcharges and contract-end penalties matter more than headline price.
Bin Set-Up by Business Type
What ‘compliant’ looks like in practice depends on what your business produces. Three common London scenarios:
Coffee shop or small café (3–6 staff)
- 23L food caddy at the counter for cups, wastage, coffee grounds.
- 240L food waste wheelie bin, weekly collection.
- 240L mixed dry recyclables (cardboard boxes, plastic bottles, milk cartons), fortnightly.
- 240L glass bin (wine bottles, jars), fortnightly.
- 240L general waste, weekly.
Small office (5–9 staff)
- 23L food caddy in the kitchen.
- 240L mixed dry recyclables, fortnightly.
- 240L general waste, fortnightly.
- Confidential paper destruction either via a lockable console (collected monthly) or batched into the recycling stream after on-site shredding.
Salon or barber (4–8 staff)
- 240L mixed dry recyclables (product boxes, bottles).
- 240L general waste (hair, gloves, tissue).
- Optional 23L food caddy for staff lunches.
- Hazardous waste (developer, peroxide) collected on a separate run by a licensed hazardous carrier.
Storage matters. Bins need a screened, level area outside the front door. A pavement bin lock or wheelie bin enclosure stops fly-tipping in yours.
Waste Transfer Notes and Duty of Care
Every UK business has a legal ‘duty of care’ for the waste it produces from creation to disposal. The Waste Transfer Note (WTN) is the paperwork that proves you discharged that duty.
A WTN records:
- Who produced the waste (you).
- Who carried it (your carrier’s licence number).
- What it was (EWC codes – six-digit European Waste Catalogue codes such as 20 03 01 for ‘mixed municipal waste’).
- Where it went (the receiving site).
- The date.
Keep WTNs for two years – that’s the legal minimum and what an Environment Agency officer will ask for. Email WTNs are fine; printed and filed is also fine; lost WTNs are not fine.
From October 2026, the Defra Digital Waste Tracking system starts taking over from paper WTNs for receiving sites. Carriers and brokers join in October 2027. Both deadlines are post your 2027 compliance date, so paper or PDF WTNs are still valid for now.
What It Actually Costs in London (2026 Rates)
Compliant collection for a London micro-business is cheaper than people expect, especially compared to the alternative of an Environment Agency case. Indicative rates as of mid-2026:
- Small office (1–2 bins, fortnightly): £40–£90 per month all-in.
- Café or salon (3–4 bins, weekly food + fortnightly dry): £110–£220 per month.
- Small shop or restaurant (4–5 bins, weekly): £180–£360 per month.
What moves the figure up: weekly vs fortnightly (the lorry costs the same to send), evening or out-of-hours collection, narrow or restricted access, and add-on services (confidential shredding, hazardous, sanitary).
What moves it down: combining streams (co-mingled dry recyclables instead of separate paper / plastic / metal), reducing general waste by recycling more, and a sensible contract length.
Common Mistakes That Get Small Businesses in Trouble
Five patterns we see at almost every audit of a non-compliant London micro-business:
- Using domestic bin bags in a council wheelie bin. The council bin is for the residents above your shop, not for your business. Putting business waste in residential bins is fly-tipping, and councils prosecute it.
- No paperwork. A ‘mate who comes in his van’ with no licence doesn’t generate a Waste Transfer Note, and if he fly-tips your rubbish, the trace comes back to you.
- Mixing confidential paper into general waste. Two breaches in one: a Simpler Recycling breach (paper not separated) and a UK GDPR breach (personal data not destroyed). Use a lockable console and a certified shredder.
- No food waste in a food business. Highest-risk gap. An EA officer at a restaurant with no food caddy and a heavy general waste bin is an instant compliance notice.
- Auto-renewing contracts. Some low-cost carriers lock you into three years and raise prices yearly. Always check the term and termination clauses.
Frequently Asked Questions
Yes, as long as that’s nine FTE across the whole business including yourself. If you employ nine part-timers totalling fewer than 10 FTE, you’re a micro-business. Hire one more full-timer or expand FTE past 10, and you join the 10+ band immediately and the rules apply from that moment, not from the next 31 March.
Yes. A two-director limited company is a micro-business under the threshold. The 2027 deadline applies; until then, you should still be managing your waste responsibly under the general duty of care, but the five-stream requirement isn’t yet enforceable against you.
A typical compliant set-up: a 23L kitchen food caddy plus a 240L external food waste bin (weekly collection), a 240L mixed dry recyclables bin (fortnightly), a 240L glass bin (fortnightly), and a 240L general waste bin (weekly). One licensed carrier can run all four. Typical cost £130–£200 per month.
No. Residential bins are paid for by Council Tax and are for household waste only. Business waste in a residential bin is fly-tipping under the Environmental Protection Act, regardless of whether anyone notices. Most London councils run duty-of-care checks on mixed-use buildings.
Yes if you generate food waste – staff lunches count. A 23L kitchen caddy that gets emptied into a 240L external food bin weekly will satisfy the regulation. Volumes are small, so some carriers run it as part of a combined contract at little marginal cost.
Co-mingled mixed dry recyclables (paper + card + plastic + metal in one bin), a separate glass bin, a separate food caddy, and a small general waste bin. Fortnightly collections everywhere except food waste (weekly). That’s the minimum number of containers and the lowest number of lorry visits, and it’s fully compliant for almost every micro-business.
