(GUF) IS IT RECYCLING - OR JUST MASS BALANCING?

(Inspiration - René Magritte - link)

From April 2027, the UK government will introduce one of the most important and potentially controversial changes yet to the Plastic Packaging Tax (PPT).

On the surface, it sounds technical. Chemically recycled plastics will be allowed to count toward the 30% recycled content threshold needed to avoid PPT and businesses will be permitted to use a ‘mass balance accounting’ system to allocate recycled content across plastic outputs but underneath the accounting language lies something so much bigger:

The UK is quietly redefining what counts as recycling.

From 1 April 2027, chemically recycled plastic will officially count as ‘recycled content’ for Plastic Packaging Tax purposes. Businesses will be able to use mass balance accounting to allocate recycled content across plastic production systems.

Pre-consumer waste such as factory offcuts, trim waste and in-house production scrap will no longer count as recycled content for PPT purposes and that final point is more significant than it first appears.

For years, manufacturers could effectively count portions of their own production waste as ‘recycled content’. From 2027, the government is drawing a philosophical line: - Reusing your own manufacturing waste is now being treated as normal good practice; not recycling and that is a notable shift toward rewarding genuine post-consumer recovery rather than internal process efficiency.

Why Is Government Supporting Chemical Recycling?

The answer lies in the uncomfortable reality of modern packaging design. Some packaging formats were never realistically designed for mechanical recycling in the first place. Flexible films, laminated pouches, multi-layer barrier packaging, food-grade plastics contaminated with oils, residues or adhesives - these materials create major operational problems within traditional recycling systems; contamination, difficult separation, expensive washing requirements, weak resale value and complex polymer mixes.

While simple packaging formats such as aluminium cans, steel and cardboard often retain strong intrinsic recovery value, many modern plastic packaging systems do not, so rather than redesigning all packaging into simpler mono-material formats, governments are increasingly supporting technologies designed to recover value from difficult plastics through chemical processes such as pyrolysis and depolymerisation and that’s the real significance of the 2027 PPT reforms.

What Is ‘Mass Balance Accounting’?

In many chemical recycling systems, recycled and virgin feedstocks are mixed during production. The recycled content is then allocated mathematically through an accounting model across different plastic outputs which means a plastic product may legally qualify as containing ‘30% recycled content’ even though the molecules within that specific item may not physically contain 30% recycled material.

In effect, the system tracks recycled content through paperwork as much as through polymer.

· Supporters argue this is a practical and necessary way to scale chemically recycled plastics within existing petrochemical infrastructure.

· Critics rightly argue in my opinion that it risks creating a system based partly on accounting allocation rather than direct physical traceability.

That tension sits at the centre of the debate. To supporters, mass balance accounting is simply the next evolution of recycling infrastructure. It may (in theory) unlock investment in advanced recycling; help process difficult plastics previously destined for energy recovery or landfill, support food-grade recycled plastic applications; even accelerate recycled-content targets but critics worry the system could (will) become increasingly difficult for consumers and even businesses to meaningfully understand.

If recycled content is being allocated mathematically across production systems, then the question begins to emerge - are we measuring actual recycling or confidence in accounting systems? That does not necessarily make the system illegitimate, but it does move recycling into a far more complex territory than the traditional public understanding of ‘this bottle became another bottle’.

The Bigger Packaging Question

The reforms also expose a deeper issue within the modern packaging economy. Over the last two decades, packaging has increasingly evolved toward lightweight composites, laminated barriers, convenience-focused flexible films, highly engineered shelf-life optimisation via multi-material formats difficult to separate mechanically. Many of these innovations improved product performance, reduced transport emissions and extended food life but they also made recycling significantly more complicated.

Chemical recycling may ultimately become part of the solution however there remains a difficult question underneath the tax reforms and accounting systems - are we now redesigning packaging to fit recycling or redesigning recycling policy to accommodate problematic packaging?

That debate is only just beginning.

The nervousness surrounding wider recycling support mechanisms such as PRNs hints at an even larger issue sitting quietly behind the sector.

None of this means chemical recycling is unnecessary. Without technological and financial intervention, large parts of the modern plastics stream may remain commercially or technically difficult to recycle at all but the 2027 PPT reforms represent something far larger than a tax adjustment; they signal a transition in how governments may increasingly approach circularity itself: not purely as a physical process of recovering materials but as a system supported by chemistry, policy, accounting models and economic intervention and that raises one final question:

· At what point does circularity remain a physical process of recovering materials?

· At what point does circularity become a mathematical allocation model designed to compensate for packaging that was never circular to begin with?

More like this (PPT) – link – more like this (chemical recycling) – link – more like this (recycling) - link - more like this (mass balancing) - link

(GUF) £600 MILLION P/A TO RECYCLE SOFT PLASTICS

(Inspiration - Man Ray - link)

One of the biggest misconceptions surrounding 'soft plastics' is the idea that all flexible packaging has an equal chance of being recycled. It really doesn’t. In reality, the UK’s future flexible plastic system will almost certainly logically favour the materials that are easiest to identify, easiest to wash, easiest to process and easiest to turn back into usable polymer.

The preferred materials will be ones that the recycling infrastructure already understands. So, hypothetically, but logically (in my opinion) here are the four materials and packaging types I think are most likely to dominate successful collection and recycling under Simpler Recycling from March 2027 onwards.

Carrier Bags & Retail Bags - (Likely Polymer: LDPE)

Examples:- supermarket carrier bags, shopping bags and convenience store bags; due to the fact that they’re already widely collected through retailer take-back schemes; they're a relatively clean polymer stream, usually mono-material LDPE and established recycling routes already exist.

They'll most likely become refuse sacks, agricultural films, the ubiquitous plastic lumber/outdoor furniture and lower-grade film products. This is probably the 'golden egg' of future soft plastic recycling.

Stretch Wrap & Pallet Wrap - (Likely Polymer: LLDPE / LDPE)

Examples:- pallet wrap, transit protection film, warehouse stretch film and shrink wrap around bulk goods.

They'll most likely become a commercially valuable, high-volume stream due to being relatively clean when segregated and already widely recycled commercially so easily turned back into new stretch film, refuse sacks and industrial plastic products,

Of all flexible plastics, this is arguably the material the industry most wants. Clean pallet wrap is practically the recycling equivalent of finding copper pipe in a builder's skip.

Bread Bags & Bakery Film - (Likely Polymer: LDPE)

Examples: - sliced bread bags, bakery packaging films, rolls and pastry bags.

These are especially promising because they're lightweight mono-film which is a relatively simple polymer structure and they're already accepted in many retailer collection schemes.

They'll most likely become bin liners, film products and composite plastic goods. This is one of the clearest examples of household film that could genuinely become recyclable at scale.

Multipack Bottle Wrap & Toilet Roll Outer Wrap - (Likely Polymer: LDPE)

Examples: - bottled water multipack wrap, soft drink shrink film, toilet tissue outer packaging and kitchen roll packaging.

These are especially likely because they're cleaner than food-contact films, of a reasonably consistent polymer composition and easy for optical sorting systems to recognise so the MRFs like them.

They'll most likely become non-food grade films, bags and plastic sheeting and are likely to become a major part of the kerbside flexible plastic stream.

The Cost ~ £250 - £600 Million per Annum

Hypothetically, but using existing FlexCollect trial data, WRAP modelling and current local authority collection economics, the national collection and processing of just these four of the UK’s most 'recyclable' soft plastic streams (carrier bags, stretch wrap, bread bags and multipack bottle wrap) could potentially recover around 300,000 tonnes of additional material annually.

On paper, that sounds transformational. In reality, however, this might only increase the UK’s household recycling rate from roughly 44% to just over 45%. 

The even more fascinating figure is the likely cost. Depending on contamination levels, sorting complexity and collection systems, the nationwide collection and processing bill could realistically sit somewhere between £250 million and £600 million per year.

In other words, Britain may soon spend the equivalent of a minor space programme teaching the public how to empty bread bags in order to gain roughly one additional percentage point of recycling performance; a reminder that modern recycling is no longer chasing the easy materials like cans and cardboard, but increasingly expensive, lightweight and operationally awkward plastics that were never truly designed for circularity in the first place. More like this (recycling at cost) - link - more like this (Simpler Recycling) - link - more like this (rubbish) - link

(CGN 13) CLINICAL WASTE

I have worked in waste management for over forty years and there are very few waste streams that create as much confusion, contradiction, myth and nervousness as clinical waste.

Mention a yellow bag and suddenly perfectly sensible people begin speaking in hushed tones while pointing at things with pens from a safe distance.

Part of the problem is that 'clinical waste' is often treated as one giant category when in reality it is a mixture of:

• infectious waste
• anatomical waste
• medicinal waste
• offensive hygiene waste
• sharps
• cytotoxic materials
• non-hazardous healthcare waste

This new Circular Guidance Note (CGN 13) was created to cut through some of that confusion. My aim was simple; to produce a practical, visually clear operational guide that takes somebody from 'I’ve got this waste - now what' through to the likely waste stream, colour coding, EWC classification, ADR considerations and treatment route without needing a three hour webinar.

Unlike many simplified internet diagrams, this guidance has been heavily reviewed against:

• HTM 07-01
• The List of Wastes Regulations
• ADR transport requirements
• real-world operational practice

In clinical waste, tiny wording errors can create very large compliance problems. One of the biggest lessons from producing this CGN is that waste classification is rarely about where something came from and more about risk, contamination, composition, intended treatment and legal description.

The final document is therefore intentionally cautious in places and includes formal disclaimer references to the official legislation and NHS technical guidance. As always with the CGN series, the purpose is not to replace competent professional advice or legal assessment. The purpose is to help people ask better questions, segregate more correctly and understand why these distinctions matter because in waste management the description creates the destiny. CGN 12 (batteries) - link - more like this (clinical research) - link - more like this (compliance) - link

From a waste management viewpoint, you cannot subcontract your responsibilities - this document should be used in conjunction with (amongst others) - List of wastes - link - and Health Technical Memorandum 07-01: Safe and sustainable management of healthcare waste - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(GUF) COMING SOON - GREENWASHING

(Inspiration - Leonora Carrington - link)

Greenwashing - who's good at it and why organisations don't care - link - more like this (greenwashing) - link

(CON) NIGERIA, RUBBISH AND FASHION

Workers load plastic waste into bags, Nigeria. Pius Utomi Ekpei/AFP via Getty Images

On any street in Lagos, Abuja or Port Harcourt, you’ll find abandoned plastic bottles lying around. Each year, about 2.5 million tonnes of plastic waste are produced in Nigeria and much of it winds up in landfills or in the environment.

But plastic waste can be useful. In some places it’s converted to textiles and clothing. Adidas, a global shoe and apparel maker, uses ocean plastics to produce sneakers, and the clothing brands H&M and Patagonia have put their money into recycled polyester collection. They collect post-consumer plastic waste (like used plastic bottles), clean it, shred it into flakes, melt it down into pellets, and then spin these pellets into polyester yarn, which is used to make new sportswear and footwear.

We’re a team of sustainability researchers and social scientists with expertise in circular economy, ethics and plastic waste management. In a recent study, we reviewed the opportunities and challenges of using recycled polyethylene terephthalate (PET) plastics (the type of plastic used in beverage bottles) in Nigeria’s fashion industry.

Evidence from other regions, such as Europe and North America, shows that producing polyester fibres from recycled PET rather than unused materials can cut carbon emissions by over 45%. But little is known about its potential in Nigeria.

Our review mapped and analysed academic studies, industry reports and policy documents to identify technical, economic, environmental, social and regulatory factors shaping the adoption of recycled PET in Nigerian fashion.

We developed a theoretical model showing how knowledge from local crafts, industrial design, environmental science and policy frameworks interact to influence this emerging practice. And we made some proposals about how to foster a socially inclusive, ethically responsible and environmentally sustainable textile industry in Nigeria.

We believe that incorporating plastic waste into the Nigerian textile industry could reduce pollution, generate employment and cut a niche in the world of sustainable fashion.

Barriers beyond technology

Plastic bottles don’t have to be a social or environmental hassle. They can be a source of economic power. The concept of “waste to wealth” is more than a catchphrase – it has the potential to revive the textile industry.

But there are a number of obstacles.

Poor infrastructure: Nigerians do not have large recycling plants. Recycling tends to be small scale or informal. Recovered PET bottles are typically exported or down-cycled into low-grade products like mats or stuffing.

Consumer perceptions: In a recent survey conducted in Lagos only 18% of consumers had heard about recycled textiles. Nigerians think of recycled clothes as a sign of poverty or as second-hand goods, not as quality clothing.

Comfort: Recycled polyester is often uncomfortable to wear in hot, damp climates, as the fabric tends to retain moisture and heat. Nigeria’s average daily temperatures range from 25°C to 35°C with high humidity. The uptake among consumers will not improve until these technical problems are addressed.

Policy gaps: In Europe, companies must assume responsibility for the end of their products’ lives. In Nigeria there are no comparable regulations, incentives or infrastructure supporting sustainable textiles. This leaves local brands with little motivation to innovate.

Lessons from global and local experiments

Other countries and brands have shown what’s possible. Adidas has transformed thousands of tonnes of plastic taken from the oceans into sneakers and sportswear. H&M operates a take-back programme worldwide which gathered over 14,768 tonnes of worn garments in 2022. Patagonia has a programme called Worn Wear which invites customers to repair and reuse their clothes.

Nigeria can learn from these examples, but also has its own sources of innovation. Startup enterprises such as Chanja Datti in Abuja are testing community-based recycling and recovery. Circular fashion – where clothing is designed to be reused, repaired and recycled instead of discarded – can also be cultural fashion, as designers in Nigeria like Maki Oh are incorporating traditional textures and sustainable practices. More of this article (The Conversation) – link – more like this (Nigeria) – link – more like this (PET) - link

(GRI) MARDI GRAS' RUBBISH

Brian Lawdermilk / AP Photo

When cleaning crews dug deep into New Orleans’ clogged drains in 2018, they pulled up leaves, mud and 46 tons of Mardi Gras beads.

The sheer magnitude of waste accumulated over decades of Carnivals — and its impact on the flood-prone city’s drainage system — shocked many residents and city officials. “Once you hear a number like that, there’s no going back,” then-Public Works director Dani Galloway said at the time. “So we’ve got to do better.”

But nearly a decade later, New Orleans is generating more Mardi Gras garbage than ever. During the roughly five weeks of this year’s Carnival season, crews collected 1,363 tons of beaded necklaces, beer cans, plastic cups, and other refuse along the city’s parade routes — a 24 percent increase from the year before and the highest total on record. The trash tonnage is the equivalent of 741 cars. In New Orleans terms, it’s roughly the weight of the Steamboat Natchez or more than 1 million king cakes.

“To see the waste go up that much, it’s just absurd,” said Brett Davis, founder of Grounds Krewe, a nonprofit group trying to make Mardi Gras more sustainable through recycling and waste reduction efforts.

It’s a century-old tradition for riders on parade floats to shower crowds with beaded necklaces, toys, and other items — collectively known as “throws.” Most are cheap plastic trinkets. The beads are often laden with toxic chemicals, including unsafe levels of lead. Many throws are dropped moments after they’re caught, then crushed under feet and eventually swept up and hauled to landfills.

City officials initially blamed the rise in rubbish on the popularity of this year’s festivities, which ran from January 6 to February 17 and included more than 30 float parades. An estimated 2.2 million people visited downtown New Orleans during the Carnival season, about 10 percent more than in 2025, according to the Downtown Development District, which drew on data from location analytics company Placer.ai. “The increase from last year was directly associated with the larger crowds,” Matt Torri, the city’s sanitation director, told the City Council in March. “Anybody who was out at this year’s parades definitely took note that there seemed to be more people enjoying the Carnival season, which is great for the city.”

But a Verite News analysis of annual attendance and city cleanup records shows no clear relationship between crowds and trash levels. Overall, Mardi Gras waste tonnage has trended upward over the past decade, regardless of the year-to-year changes in attendance. The Mardi Gras season in 2020, for instance, drew more people — about 2.4 million — but produced roughly 241 fewer tons of garbage than in 2026.

In the early 2010s, trash tonnage hovered around 880 tons. It spiked in 2017, surpassing 1,320 tons, and has not fallen below 1,000 tons since. The only exception was 2021, when no trash was recorded because the city canceled parades and most Carnival festivities due to the COVID-19 pandemic. more of this article (Grist) - link - more like this (New Orleans) - link - more like this (plastic beads) - link

(CGN 12) BATTERIES

Batteries are one of the smallest items we throw away, and potentially one of the most dangerous.

For years, waste batteries were treated as little more than an inconvenience: a few AA cells in a drawer, an old mobile phone battery, a disposable vape tossed into a bin. Today, however, batteries sit at the centre of one of the fastest-growing safety and compliance challenges facing the waste and recycling sector.


From fires in refuse vehicles and recycling plants, to exploding vapes and damaged lithium-ion batteries entering general waste streams, the risks are becoming very real, very costly and increasingly difficult to ignore.


CGN 12 – Batteries - has been created to provide practical, straightforward guidance on:

• the main battery types,
• what legally constitutes a waste battery,
• why lithium batteries are different,
• safe storage and segregation,
• transport considerations,
• why simple actions like taping battery terminals genuinely matter.

As with all Circular Guidance Notes, this document is designed to be useful rather than overcomplicated - focusing on practical handling, safety, compliance and common sense rather than technical jargon because in waste management, one incorrectly discarded battery doesn’t just disappear into a bin, sometimes, it starts a fire.

I hope you find this CGN useful. CGN 11 - link - more like this - (EU) - link - more like this (batteries) - link - more like this (the waste files) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(CGN 11) PERSISTENT ORGANIC POLLUTANTS

This CGN is one of the most important guidance notes in the series so far because it deals with a difficult truth that much of the recycling and reuse world is still struggling to fully accept. For years, we were encouraged to repair, reuse, recycle and keep materials circulating for as long as possible.

In principle, that remains absolutely correct; however, some legacy materials now present a serious legal and environmental challenge due to the presence of Persistent Organic Pollutants - better known as POPs. These chemicals, commonly found in older upholstered seating, electrical plastics, cables and insulation materials, were originally introduced to improve fire safety and product performance.

The problem is that many of them do not easily break down, they accumulate in the environment and are now tightly controlled under UK and international law which itself creates a major compliance issue for organisations attempting to recycle or refurbish older furniture and WEEE items.

A sofa may look recyclable. A foam cushion may appear reusable. An old cable may seem harmless. Yet if those materials contain POPs above legal thresholds, they cannot legally be recycled back into new products and may instead require destruction through specialist high-temperature incineration routes.

The purpose of this guidance note is not to criticise repair, reuse or recycling organisations, many are acting with genuinely good environmental intentions. Rather, it is to explain where modern waste legislation places limits on the circular economy and why ‘doing the green thing’ still must remain legally compliant.

Basically, if foam or plastic contains POPs, it is not a recycling product; it is a destruction waste.

This CGN summarises the current UK guidance surrounding:

• upholstered domestic seating containing POPs
• WEEE plastics and cables
• legal disposal obligations
• the growing operational impact these rules are having across universities, businesses, charities and the wider waste industry

Relevant guidance referenced within this CGN includes: Manage waste containing Persistent Organic Pollutants – link - Manage waste upholstered domestic seating containing POPs⁠ - link - Classify some waste electrical devices, components and wastes from their treatment⁠ - link - CGN 10 - link - more like this (POPs) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(MOT) ROUNDUP - GOING STRONG IN CALIFORNIA

An artist's rendition. But some locals fear spraying Roundup in the Lassen National Forest and vicinity threatens their “little slice of heaven.” Billie Carter-Rankin; George Rose/Getty

In remote Northeast California, about 10 miles outside the lumber mill town of Chester and a half-hour’s drive from the old hunting cabin I bought and fixed up about a decade ago, I steer my old Toyota Tacoma down a bumpy dirt road to where the Lassen National Forest gives way to private timberland. Lilly rides shotgun.

We’d come to this exact spot seven years ago. Lilly, my sharp-eyed border collie, had jumped out of the truck and chased a rabbit through a meadow of knee-high grass, returning covered in mud and burrs. The landscape was straight out of an L.L.Bean catalog: a flower-dotted meadow buzzing with life. Douglas firs, incense cedars, and some of the tallest sugar pines on the planet sheltered protected species ranging from gray wolves to Pacific fishers and northern goshawks. The Sierra Nevada red fox, one of California’s rarest mammals, was known to live nearby, amid the vast patchwork of private and public lands. The Lassen area is where I come to reset, forage for wild mushrooms, and let stress evaporate.

But today, I’m looking out over a barren, sun-bleached expanse that stretches across the former meadow and up the sides of denuded mountains as far as the eye can see. No birds. No animals. No insects. No big trees. Just some waist-high piles of volcanic rock, a nod to the still-active Lassen Peak nearby. It is eerily quiet—desolate. The Dixie Fire roared through here in July 2021, burning nearly 1 million acres. The Park Fire three years later took out another 430,000 acres nearby. But the fires aren’t directly responsible for what I’m seeing today. People did this.

Just a few minutes down the road, nature has crept back to life. There, I saw vibrant green mountain whitethorn bushes, rabbitbrush, and purple-tinged bull thistles, with energetic bees bopping from flower to flower. The towering trees were gone, but new saplings abounded—cedars, pines, firs, and more—scattered randomly amid the greenery, already a foot or two high. No such verdant revival is visible on the private timberland before me. No bees, no flowers—it’s a virtual dead zone where the only life consists of row upon row of manually planted, tightly packed conifer saplings, all less than a foot tall.

This is because, unbeknownst to most people, logging companies and the US Forest Service have been spraying massive amounts of herbicide in clear-cut and fire-ravaged forests of California—and throughout the nation. And not just any herbicide, but glyphosate, a potent and problematic weed killer best known by the brand name Roundup. More of this article (Mother Jones) - link - Melissa Lewis - link - more like this (glyphosate) - link - more like this (California) - link

(CGN 10) EXTENDED PRODUCER RESPONSIBILITY

CGN 10 takes on one of the biggest changes currently reshaping the waste and packaging sector - Extended Producer Responsibility (EPR).

For years, packaging producers could place almost anything onto the market with very little financial connection to what happened afterwards. If it was difficult to recycle, contaminated the recycling stream, or simply ended up being burned or buried, the costs usually landed elsewhere - councils, taxpayers, waste contractors and ultimately the environment itself. EPR is supposed to change that.

In this Circular Guidance Note, we explore:

• why EPR matters
• how the RAM (Recyclability Assessment Methodology) could become one of the UK’s most important waste policy tools
• why procurement decisions now carry long-term financial consequences
• how “cheap packaging” may become expensive packaging
• why some producers may simply pass additional costs straight back to customers instead of redesigning poor packaging

We also touch on the increasingly controversial debate surrounding glass packaging, along with comparisons between the UK’s approach and the far more ambitious direction being taken under the EU’s Circular Economy Action Plan (CEAP) and Packaging & Packaging Waste Regulation (PPWR).

Importantly, this CGN is not anti-EPR. In fact, parts of the framework, particularly RAM may finally begin linking packaging design to real-world recyclability and real-world financial consequences which, being honest, the industry has needed for a very long time.

More than ever, with the introduction of pEPR, good recycling starts in procurement. CGN 09 - link - more like this - (pEPR) - link - more like this (CEAP) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(CGN 09) LITTERING

Littering is often dismissed as a minor nuisance; a dropped can, a cigarette end, a takeaway wrapper left on a wall but in reality, littering sits at the very front line of waste management, public behaviour and environmental responsibility.

Every piece of litter has a cost: someone has to clean it up, someone has to pay for it and somewhere downstream, it impacts communities, wildlife, drainage systems and public perception.

CGN 09 explores the legal and operational framework surrounding littering and fly-tipping in England and Wales, including the legislation commonly used by councils and enforcement officers, the difference between littering and fly-tipping, Fixed Penalty Notices (FPNs), enforcement powers and the wider practical implications for businesses, local authorities and the public.

Importantly, this guidance note is intended to inform rather than instruct. As with all CGNs, I have aimed to keep the document grounded in publicly available legislation, guidance and operational practice while remaining accessible to everyday readers. Report littering - link - CGN 08 - link - (still in writing) - CGN 07 - link - more like this (littering) - link - more like this (FPN) - link

TCGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves, and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(CGN 08) FOOD WASTE

For years, most organisations treated food waste as little more than “wet general waste” - something scraped into a black bag and forgotten about but under the UK’s new Simpler Recycling reforms, that approach is rapidly disappearing.

Businesses with more than ten full-time employees at a single location are now required to separately collect food waste, with household collections expanding across England in the years ahead. In other words, food waste is no longer simply a sustainability choice, it's becoming standard operational compliance.
But unlike many environmental obligations, this one actually makes genuine environmental sense.

When separated correctly and sent to Anaerobic Digestion (AD), food waste becomes a renewable energy source capable of generating electricity, biogas and agricultural digestate while significantly reducing greenhouse gas emissions compared to landfill or residual disposal.

This latest Circular Guidance Note (CGN 08) explores:

• the legal requirements behind food waste collections,
• the environmental benefits of Anaerobic Digestion,
• the difference between AD and In-Vessel Composting (IVC),
• the growing industry frustration around so-called “compostable” packaging.

One of the biggest myths in modern waste management is that “compostable” automatically means environmentally beneficial which isn't always the case. 

As always, the aim of the CGN series is not greenwashing, jargon or virtue signalling — but practical circular thinking grounded in real-world waste operations and compliance. CGN 07 - link - more like this (Anaerobic Digestion) - link - more like this (food waste) - link - please note - website address is incorrect. 

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(CGN 07) CREAM CHARGERS

CGN 07 focuses on a growing problem quietly making its way through the waste industry: nitrous oxide cream chargers.

Used widely by coffee shops, bakeries, catering outlets and commercial kitchens, these large gas canisters are increasingly being discarded into general waste and recycling streams despite still containing residual pressure and oxidising gas hazards.

The problem is simple: They look empty. They are often not.

Once inside compactors, balers, MRFs or incinerators, these cylinders can cause fires, explosions, equipment damage and significant operational disruption.

This Circular Guidance Note explains:

• why cream chargers remain hazardous after use
• their correct technical classification
• why they should never enter routine waste streams
• and the correct route for compliant treatment

Like all CGNs, the aim is not greenwash or jargon — just practical circular thinking based on real operational realities within the waste industry.

Because pressure vessels belong in specialist treatment - not general waste. RPS 289 - link - More like this (aerosols) - link - more like this (CGN 06) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(CGN 06) COMING SOON - THE CARBON SLEDGEHAMMER

 More like this (CGN 05) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.

(CGN 05) EPR - THE FULL SET

Over the next few years, a series of new Extended Producer Responsibility (EPR) schemes will fundamentally change who pays for waste management, how materials are designed, collected and recycled, and ultimately what businesses are allowed to place on the market.

For decades, the true cost of dealing with difficult, non-recyclable and waste heavy products has largely fallen on local authorities, businesses and taxpayers. The new EPR framework aims to reverse that model by shifting the financial and operational responsibility back onto the producers placing materials onto the market in the first place.

Packaging is only the beginning.

The UK is now moving towards wider producer responsibility schemes covering sectors such as batteries, electrical equipment, textiles, tyres, furniture and other hard to recycle waste streams; many of which have historically escaped meaningful end of life accountability.

Alongside Simpler Recycling, Digital Waste Tracking, the Deposit Return Scheme and future carbon legislation, EPR will become one of the defining drivers shaping procurement, packaging design, recycling systems and disposal costs throughout the late 2020s and beyond.

In simple terms:

The era of “someone else will deal with it at the end” is slowly coming to an end.

This document provides an overview of the proposed and emerging UK EPR schemes, what they are intended to achieve and what organisations should now be preparing for. more like this (EPR) - link - more like this (tyres) - link - more like this (CGN 04) - link

CGN Disclaimer & Community Review

As with all documents within the CGN (Circular Guidance Note) series, every effort has been made to ensure the information provided is factual, practical, and helpful at the time of writing however, legislation changes, guidance evolves and occasionally mistakes happen. If you spot anything within this CGN that is incorrect, misleading, outdated or could be better explained, please leave a comment below together with supporting information or clarification. Following review and verification, corrections or revisions will be made where appropriate and contributors will happily be credited for their input should they wish. The aim of the CGN series is not simply to publish information but to build a growing, reliable, real-world resource library for everyone involved in waste, recycling, compliance and circular economy discussions.

I have always believed that in waste management, getting it right matters more than pretending to already know everything.