Setting the Scene
On Wednesday 17th September, CIRQLR CEO David Palmer-Jones took to the stage at RWM’s new Commercial, Industrial and Hazardous Waste Theatre to outline six pieces of legislation that are reshaping the UK’s commercial and industrial (C&I) waste market, and how they are impacting CIRQLR. Simpler Recycling, Extended Producer Responsibility (EPR), Waste Tracking, Landfill Tax, the Deposit Return Scheme (DRS), and the Emissions Trading Scheme (ETS) are all playing a key part in shaping the future of the sector, alongside the work of the Circular Economy Task Force, who are leading the co-development of a national circular economy strategy for England. With legally binding requirements such as Simpler Recycling and packaging EPR now in place, regulation has become a principal driver in the waste industry, redefining investment, operations, and customer behaviour.
CIRQLR: A Rising Force in Waste Management
Founded just 24 months ago, CIRQLR launched as a UK-based C&I waste and resource management group with a mission to “give waste a second life.” To achieve this, it connects a network of sustainable local waste companies that prioritise resource recovery and closing resource loops, focusing on innovation rather than residual waste. To date, CIRQLR has completed eight acquisitions, continuing to rapidly expand with an emphasis on geographical cohesion and building towards a national capability. Operating over 19 recycling facilities, CIRQLR is emerging as a rising force in the waste industry, driven by insight informed by data and a commitment to regulatory progress and circular economy innovation.
This blog is the first in a three-part series on these six key legislative drivers. Each article will explore how regulation is influencing the sector, what it means for CIRQLR, and why.
In Part One, we look to two pieces of legislation that are already in effect: Simpler Recycling and Extended Producer Responsibility (EPR). Both pieces of legislation signal a significant change in how waste is segregated, managed, and funded, with clear impacts for producers and service providers.
Simpler Recycling: Segregation at the Source
Simpler Recycling came into force for businesses at the end of March this year, requiring workplaces to separate waste into a minimum of four streams: residual (non-recyclable waste), food waste, paper and card, and dry mixed recyclables (DMR) - including plastic, metal, and glass. Paper and card must be separated from other dry recyclables, unless your waste collector accepts them as being co-collected.
At its core, Simpler Recycling is about segregation at the source - at the point of disposal. As David emphasised: “It’s about segregation. If you want quality, you’ve got to segregate.” He went on to highlight the UK’s cost-oriented focus in the market, and the significance of transforming increased segregation from an aspirational objective into a legal requirement for businesses - a shift he described as critical to selling to C&I customers.
Simpler Recycling: Early Effects for CIRQLR
In practice, Simpler Recycling has already impacted CIRQLR in several ways. Customers have embraced food collection, and as the biggest contaminator of the DMR stream this has been a particularly important success. That said, this transition is still ongoing - culture changes take time - and the full impact of the requirement is yet to be seen.
Greater segregation has meant adjustments in the form of increased collections, additional containers, and public education efforts, all of which have contributed to an overall reduction in residual waste. Food and glass volumes have risen by 20-30% and 5-10% respectively - a significant increase in a short period - and evidence so far shows that the quality of DMR is improving as a result. However, with greater levels of extraction, additional MRF investment and expanded sorting capacity will be required.
Extended Producer Responsibility: Shifting Ownership
In the UK, packaging EPR - known as pEPR - is now in place. It requires producers to report on their packaging data, which will determine modulated fees based on the recyclability of packaging materials. The first invoices, calculated using 2024 data, are set to go out in October. While pEPR has begun with a domestic focus, regulations will eventually expand to cover the C&I market.
Significantly, EPR will inject “a lot of new money in the system… it gives lots of opportunity for the whole of the [waste] sector to develop. It gives a lot of confidence in terms of longevity of the legislation [and for] investing in the right equipment and the right facilities,” commented David. EPR is expected to operate as a self-funded system, with investment in the C&I industry for adaptive measures likely to be driven by the UK’s cost-oriented market.
“However, I think we’re seeing a shift in ownership in the UK, from local authorities to producer responsibility organisations,” David added, referencing PACK UK specifically. Over the next 24 months, there will be a strong push to develop and extract as much value as possible before performance criteria comes to the fore. Beyond that point, local authorities and service providers will face growing pressure to improve efficiency. As David highlighted, EPR is certainly not a “blank cheque” but rather a regulation that “will become successively more challenging in terms of the demands and the cost structures that will be expected.”
EPR and CIRQLR: Unlocking Opportunity
In terms of impact, local funding will sustain the EPR system, bridging the domestic and commercial markets. Crucially, modulated fees will instil greater responsibility for producers, as costs will be tied directly to recyclability. David noted how this will influence the DMR stream: the ‘purer’ the material, the greater its extractability and its potential to flow into the C&I market.
Even though the initial focus is on domestic waste, there will be a clear knock-on effect. Looking ahead, David believes there may be a “general rule of principle that as producers, you have to accept responsibility, and again that is a huge shift away from where typical ownership of material has been”, a shift that generates new opportunities for CIRQLR as new streams emerge over time.
Key Takeaways
Whilst Simpler Recycling and EPR may be separate regulatory frameworks, they converge around the same fundamental goals: driving improved recycling outcomes through redefining responsibility and higher standards, which in turn create space for innovation within the C&I market. For CIRQLR, these changes are already being realised, driving behaviour change through increased segregation at the source, adaptations in service delivery to accommodate new collection requirements, and preparing for infrastructure developments that will be needed.
Legislation here is not simply about compliance, but serves as a catalyst for evolution in the waste industry. Through embracing these developments, CIRQLR continues to support customers in reducing residual waste, raising the quality of materials recovered, and looking ahead to a future where accountability and circularity work in tandem.
In Part Two of this blog series, the focus will turn to the influence and impact of Waste Tracking and Landfill Tax, building on this discussion of how regulation is reshaping the waste sector and supporting the UK's transition towards a circular economy.
Emily Nurse, CIRQLR
