Coming Full Circle

After many years of gestation, the legislative changes included in the EU’s “Circular Economy Package” came into force today (4 July). In his upcoming blogs, CIWM’s CEO, Dr Colin Church, will explore the implications for different aspects of our sector, starting with food waste.

Over the past few years, the EU has been discussing changes to the main bits of resource and waste management legislation in what is called the “Circular Economy Package” (CEP). Since the Brexit referendum, the position of this legislation in the UK has been unclear, however earlier this year the UK Government confirmed it would support it.

The negotiations have all now finished, and today (4 July 2018), these revisions came into force. The legislation gives the UK and other member states until 5 July 2020 to bring their national laws into line and the UK Government has said it will do so too.

With deadlines stretching out to the mid-2030s, it isn’t possible to be sure that, if the UK does leave the EU before then, it will want to comply; a lot depends on the still-to-be-determined agreement for the future relationship. However, whilst bearing that in mind, what will these changes mean for food waste recycling in the UK?

(The main pieces of legislation relevant here are the new Landfill Directive (EU) 2018/850 and the new Waste Framework Directive (EU) 2018/851.)



The CEP focuses on “municipal” waste, which alongside household waste (the previous focus) now brings in waste from other sources that is similar (broadly, the ‘C’ in ‘C&I’). It includes paper and cardboard, glass, metals, plastics, bio-waste, wood, textiles, packaging, waste electrical and electronic equipment, waste batteries and accumulators, and bulky waste.

The changes insert a simple definition of “food waste” (effectively, that food waste is food that has become waste) and amends the existing definition of biowaste to include food and kitchen waste from offices, wholesale, and canteens alongside households and restaurants. There is also a commitment to develop a common EU food waste metric by March 2019 and an associated requirement for Member States to report to that metric from 2020 onwards.


The inclusion of non-household waste probably doubles the volume of waste covered by the regime. The clarification of the food waste and biowaste definitions may bring some more material into scope.  Poor data on food waste arisings and fate across the EU is one reason why the CEP doesn’t go further on food waste reduction. These proposals seek to address that issue and will mean that next time around (after 2023) such a target is much more likely.



There will be a duty on member states to promote food waste prevention, with an indicative target of 30% reduction by 2025 and 50% by 2030. An obligation to provide incentives for diversion of surplus food at all stages of the supply chain is introduced. The Commission is also given until the end of 2023 to consider a mandatory food waste reduction target for 2030.


There will be continued attention paid to the diversion of edible surplus food as well as other waste reduction measures in the UK, reducing the overall amount theoretically available for recycling. A mandatory reduction target towards the end of the 2020s is quite likely, but if the UK has indeed left the EU by then, it isn’t clear what that might mean to us.



The requirement for separate collection of waste is strengthened and the test as to whether separate collection isn’t technically, environmentally or economically practical (TEEP) is made tougher. Member States will have to report to the Commission on implementation of this (including any TEEP derogations) by the end of 2021. The overall targets for recycling of municipal waste (which includes biowaste) are increased to 55% by 2025, 60% by 2030 and 65% by 2035.

As of 2023, member states must introduce separate collection of biowaste (if not separated and recycled at source) unless it isn’t TEEP. Suitable compostable packaging etc may be mixed in too.

Member states are also required to encourage home composting, use of biowaste based materials in new products and high quality biowaste recycling, and by March 2019 the EU will seek to establish a common methodology for measuring biowaste separated and recycled at source. Finally, the Commission has until the end of 2024 to consider setting recycling targets for municipal bio-waste.


The effect of these changes should be to see England start to catch up with the rest of the UK in terms of separate food waste collection from households and commercial properties – currently almost half of English local authorities don’t collect household food waste at all, and only 35% collect it separately, and the picture for businesses is no better.

Given the changes to treatment rules (see below), this should mean a significant increase in the demand for facilities to process this increase supply of feedstock, which with current technologies should be good news for anaerobic digestion (AD) and in-vessel composting (IVC).



The efforts to reduce the material going to landfill continue. By 2030, there should be no landfill of material suitable for recycling or recovery, and the amount of municipal waste going to landfill must be less than 10% of the total arising by 2035. A new ban on incineration of separately collected recoverable waste comes in.

AD and composting for digestate/compost will be given more benefit in calculating recycling than processing for fuel, so long as if used on land it adds value to agriculture or gives ecological benefit. And from 2027, AD and composted biowaste is recycled only if separately collected or source separated.

By the end of this year the Commission must ask the European standards bodies to develop standards for bio-waste entering organic recycling processes, for compost and for digestate.


Alongside the changes to collection rules, this will push much more material towards AD and IVC.


The overall impact of the changes in the CEP will be to make the case for separate collection of food waste far stronger for English local authorities. Once collected separately, this waste will need to be recycled (not landfilled or incinerated), which will drive demand for AD and IVC until and unless food waste reduction actions bite or new technologies (such as biorefineries, etc) come along.


The key dates therefore for biowaste (including food waste) are:

  • 2020: Transposition
  • 2021:Separate collection reporting
  • 2023: Separate biowaste collection; possible proposal for a binding food waste reduction target
  • 2024: Possible proposal for recycling targets for municipal biowaste
  • 2025: 55% recycling of all municipal waste; indicative reduction of food waste by 30%
  • 2027: Separate collection of feedstock for AD and composting for it to count as recycling
  • 2030: 60% recycling of all municipal waste; no landfill of material suitable for recycling or recovery
  • 2035: 65% recycling of all municipal waste; indicative reduction of food waste by 50%; maximum 10% of municipal waste to landfill.
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