188ÌåÓý

This guidance is for waste collection authorities and other waste collectors in England who collect waste from any of the following: 

• ³ó´Ç³Ü²õ±ð³ó´Ç±ô»å²õÌý

• ²ú³Ü²õ¾±²Ô±ð²õ²õ±ð²õÌýÌý

• residential homes, such as care homes  

• universities, schools or other educational establishments 

• hospitals or nursing homes 

• places of worship 

• penal institutions 

• charity shops selling donated goods coming from domestic premises 

• residential hostels which provide accommodation only to people with no other permanent address, or who are unable to live at their permanent address 

• premises used wholly or mainly for public meetings 

When you can collect paper and card together with other dry recyclables  

You should collect paper and card separately from other dry recyclable waste (plastic, metal and glass), unless it:  

• is not ‘technically practicable’ Â�

• is not ‘economically practicable’Â�

• has ‘no significant environmental benefit’Â�

You must prepare a written assessment to explain why one or more of these options apply.  

Written assessment: what you need to do 

In the written assessment you should include the: 

• name of waste collector or waste collection authority 
• waste carrier number 
• geographical area, collection route or type of premises the assessment covers  
• other dry recyclable waste you will collect with paper and card 
• reasons and evidence for why one or more of the following apply - it is not ‘technically practicableâ€�, not ‘economically practicableâ€� or there is ‘no significant environmental benefitâ€� to collect paper and card separately 

You can use the template written assessment to record your reasons and evidence, or you can choose to use a different format.

Keeping a record of the written assessment 

You should retain a record of your written assessment and any evidence. The Environment Agency can ask to see a written assessment to understand your reasons for collecting paper and card with other dry recyclables. Citizens may also ask to view this information for waste collection authorities and other public bodies under the Environmental Information Regulations 2004. �

Reviewing the written assessment regularly   

You should regularly review written assessments to make sure they stay relevant. For example, you could do this annually or when circumstances change, such as when: 

• collection, treatment or recycling contracts end or are changed  
• vehicles are replaced 
• you get access to a new recycling facility or technology 

Assessing different services  

Sometimes, it makes sense to provide a different recycling collection service for different: 

• geographical areas 
• collection routes 
• type of premises or housing stock 

This is not a complete list - there could be other cases where you provide different services.  

Defra recommends that you complete a separate written assessment for each different service where you plan to collect paper and card with plastic, metal and glass, unless the reasons for doing so are the same.  

In your written assessment you should specify which areas, routes or premises the assessment covers.   

When collecting separately is not ‘technically practicable’ �

To make the case that separate collection is not ‘technically practicable�, you should show that your local circumstances justify collecting paper and card with other dry recyclable materials. This could mean there are technical barriers or there is not a system for collecting paper and card separately that works in practice. 

You may want to consider: 

• appropriate waste management space - for example, depot and storage space, and any access or planning requirements for this space 
• space to accommodate more containers in the premises or on the street, as well as any relevant access or planning requirements 
• other relevant technical factors  

Some factors may be technical issues in the short term, but in the longer term could be considered economic issues, as they could be fixed by investment. For example, local re-processing capacity, the availability of suitable containers or vehicles, or existing contracts. Therefore, you may want to decide if these factors fit under not ‘economically practicable� rather than not ‘technically practicable�.  

When collecting separately is not ‘economically practicable’ �

To make the case that it is not ‘economically practicable� to collect paper and card separately, you should show that it would cause excessive costs compared to collecting with other dry recyclables. 

You may want to compare costs between collecting separately and together for: 

• container costs 
• vehicle costs, including purchasing or leasing, and running costs 
• management costs 
• overhead costs, including depot and transfer costs 
• gate fees and income from sale of materials 
• cost of contractual changes 
• cost savings and efficiencies 
• other relevant economic factors  

Waste collection authority contracts 

There may be cases where it might not be ‘economically practicable� because the waste collection authority or the linked waste disposal authority would break a contract and incur a financial penalty. Waste collection authorities should reassess again when the contract allows. 

When collecting separately has ‘no significant environmental benefit’�

To make the case that there is ‘no significant environmental benefit� to collecting paper and card separately from other dry recyclables, you should use environmental data to show that this is the case.  

You may want to consider: 

• carbon impacts for the whole route of waste including collection and bulking of materials 
• quantity and quality of materials collected 
• vehicle emissions from collection and haulage 
• materials recovery facility (MRF) emissions  
• quantity of material rejected at MRFs (also known as ‘contaminationâ€�)  
• other relevant environmental factors