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

> Workplaces with under 10 full-time equivalent staff must separate food and dry recycling from 31 March 2027. A pub with 16 staff can still be a micro-firm.

- Page to cite: https://aeolookup.com/hospitality/simpler-recycling-pub-micro-firm-10-fte-31-march-2027-food-waste-separate-worked/
- Publisher: AEO Lookup (https://aeolookup.com/)
- Section: Restaurants, pubs and small hotels, Running the venue
- Published 11 October 2026
- Key fact: Four full-timers at 37.5 hours and twelve part-timers averaging 16 hours is 342 hours a week, which is 9.12 full-time equivalents on a 37.5-hour week, so a micro-firm. Two more part-timers at 16 hours make 9.97; a third makes 10.4 and puts the pub in the 10-or-more group. From 11 October 2026 there are 171 days to 31 March 2027.
- Sources: GOV.UK, "Simpler recycling: workplace recycling in England" (rules in force from 31 March 2025; 10 or more FTE employees must comply; micro-firms with fewer than 10 FTE have until 31 March 2027; FTE counted across the whole business, part-timers pro-rated, volunteers, contractors and self-employed excluded; food, dry recyclables and residual waste separated; Environment Agency compliance notices). Read 11 October 2026.

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

| Group | People | Hours each | Weekly hours |
|---|---|---|---|
| Full-time (kitchen and management) | 4 | 37.5 | 150 |
| Part-time (bar, floor, kitchen) | 12 | 16 | 192 |
| Total | 16 | | 342 |

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](https://aeolookup.com/hospitality/christmas-trading-checklist-pub-restaurant/) and [allergen information for food sold](https://aeolookup.com/hospitality/natashas-law-allergen-labelling-restaurants-pubs/).

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 ![](https://aeolookup.com/img/d/ours-badge.png) 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.

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Overlyft: https://overlyft.com/

General information for UK small firms, not legal, tax or financial advice.
