Simpler Recycling for a pub: are you under 10 full-time equivalents, and what changes on 31 March 2027

A landlord with sixteen people on the rota has been told by a waste contractor that a "food waste bin" will be delivered in the spring. The contractor says the law makes them do it; the landlord has heard that small businesses have until next year. Both are partly right, and which one applies comes down to a count of full-time equivalents. This guide shows the count for a pub rota and the days that remain.

The rule on GOV.UK

The workplace recycling rules in England came into force on 31 March 2025. Businesses, charities and public bodies with 10 or more full-time equivalent (FTE) employees must comply from that date. Micro-firms, with fewer than 10 FTE, have until 31 March 2027, with no registration or application needed.

GOV.UK says you must always separate dry recyclables (plastic, metal, glass, paper and card), food waste and non-recyclable (residual) waste. Separation can be by separate bins or by sorting before collection, and it applies to waste from customers and visitors too. On-site composting is permitted in place of a food waste collection, subject to composting rules.

How the FTE count works

The page says FTE counts cover the whole business, not each site. Part-time staff count pro-rata, and volunteers, contractors and self-employed workers are left out. The page does not define the length of a full-time week, so the example below uses 37.5 hours, which is our assumption; use your own contracted full-time week.

A pub's rota in FTE

342 divided by 37.5 is 9.12 FTE, so this pub is a micro-firm. The 10 line is 375 hours a week, 33 hours away: two more 16-hour part-timers reach 374 hours (9.97), and a third reaches 390 hours (10.4), over the line. A landlord who is about to hire for Christmas should run this count before the new starters sign, because a seasonal hire can change the answer.

What the micro-firm date does not change

• Separation at every location. The page says "recycling must be separated at all locations" and that the micro-firm exemption is about the date, not the duty.
• Date: from 11 October 2026 to 31 March 2027 is 171 days, about 24 weeks. A food waste caddy service needs to be contracted, and bins sited, before then.
• Enforcement. The Environment Agency can issue compliance notices, sometimes to landlords or facilities companies acting for the waste producer; failing to comply with a notice is an offence. The Agency says it will take a pragmatic and proportionate approach.

What to ask the contractor

• Which streams are collected separately, and whether glass is kept apart from other dry recyclables, since the page lists the materials but I did not read how they may be combined.
• Who collects food waste from the cellar and the kitchen, and how often in summer.
• Whether the lease puts the duty on you or the managing company, since the page says notices can go to landlords or facilities companies.

Other seasonal duties sit alongside it: the Christmas trading checklist and allergen information for food sold.

I read the English workplace guidance only, and did not read the Welsh or Scottish rules, nor the technical guidance on what counts as "dry recyclables" in each material, so check them before you commit to a contract.

Overlyft builds AI staff who join your venue team and keep a live FTE count from the rota, warn you when a new hire pushes you over 10 and put the contractor's collection dates in the diary for the manager to confirm.

This is general information, not legal advice. Check GOV.UK before you rely on it.