The NSW Government is going to mandate commercial food waste collection (COFO). This is excellent for NSW, and the Minister Penny Sharpe and Premier Chris Minns are to be congratulated for this reform. For those of you who don’t know what we’re talking about, from July 1, 2025 large food waste generators will need to have a dedicated food waste collection system. Food waste will no longer be able to go to landfill. Food waste in landfill is a massive greenhouse gas generator, contributing most of the 11 million tonnes of greenhouse gases released from landfill each year. That is equivalent to the annual emissions of about 3 million cars.
The key businesses that are proposed to be covered by the food collection requirement will likely include:
1. Supermarkets (with a floor area > 1,000m2)
2. Institutions including:
- hospitals;
- correctional facilities;
- education facilities;
- childcare facilities; and
- seniors’ housing.
3. Hospitality including:
- hotels and motels;
- registered clubs; and
- food and drink premises including food courts.
The scheme is proposed to capture the biggest food waste generators in the NSW economy.
Interestingly, the EPA has decided to use the size of the red (residual) bin out the back of the business as the threshold test for whether they are included in the mandate or not.
This is with the exception of supermarkets, which are tested based on floor area. Why use the size of the red bin as the threshold test? I assume it is because it is easy to see and to test. So, how will it work?
From 2025 to 2029 the threshold will slowly reduce to capture more food waste generators. Excellent plan. Here is the test for premises:
- ≥3,800L of residual waste bin capacity to start on 1 July 2025;
- ≥1,900L of residual waste bin capacity to start on 1 July 2027, and
- ≥660L of residual waste bin capacity to start on 1 July 2029.
As a result, by 2029 most large businesses in NSW that generate food waste will have dedicated food collection system. Small businesses, e.g. those with a single 240 litre garbage bin, will not be included in the mandate.
The EPA is proposing part or full exemptions for some businesses in special circumstances (which makes sense). We don’t know the colour and flavour of that but having discretion is sensible.
For building complexes (think Westfields), the requirement will be on the property manager, not the individual tenants. How that is then translated to tenants is not spelled out, but I assume there will be an obligation for Westfields to get its tenants to follow suit.
Each business will need to provide enough organics bins to meet the food waste generation rate for that business and they cannot mix the food waste with general waste thereafter.
The Government hasn’t drafted the regulations yet, but they are talking about all the normal enforcement procedures and penalties for non-compliance.
Interestingly, they are asking local councils to take on most of the normal monitoring and enforcement. That aligns with council business, but I suspect local government will be asking for some funding support at least while the system is being rolled out.
What does it mean for NSW businesses?
In MRA’s view it will not have much impact on large supermarkets. Most of them have been running food waste collection systems for years. MRA has worked with all the major supermarkets to set up farmers’ food waste collection systems, food donation and composting systems. Doing so is good for the planet and generates ACCUs (carbon offset credits). It will however stimulate action by a few smaller supermarkets and those in the inner city for whom farmers programs etc have proven difficult or costly. These will be in the scheme and must introduce new food collection. That is a good thing.
For the rest of business in NSW it will mean tendering or seeking quotes for a new FO (Food Organics) collection service. Easily done and there are now plenty of waste and recycling companies offering
that service.
There are also plenty of composters and green energy generators (such as anaerobic digestion) willing to take the organics.
There is no lack of interest and investment to grow these markets.
On the downside, MRA is a bit concerned that some food waste generators might try to “game” the bin threshold test by simply replacing large bins with smaller bins collected more frequently. However, they will be captured in later years as the threshold reduces so it should not be a big problem. Time will tell.
Probably the biggest risk we see is that a business owner might decide that the inconvenience of separating food waste is too great. They could simply rent a food collection bin, put it out the back, but never use it. It would be up to a council officer to discover the rort. Currently, food waste collection and processing is generally more expensive than landfill for most businesses – this is a potential outcome at least for a small number of business owners.
Hence, we would expect the EPA using some of the landfill levy funds to support local government enforcement and training.
As smaller businesses implement commercial organics, contamination in COFO is likely to rise, therefore collectors need to work with their clients to minimise this issue. The EPA should be proactively involved by delivering relevant education programs, another worthwhile use of levy funds.
With those minor caveats, we congratulate the NSW EPA and the Minister Penny Sharpe for delivering on this reform.
It will improve resource recovery, create hundreds of jobs, reduce landfill consumption and reduce greenhouse gas emissions.
It will generate almost 500,000 t/year of additional organics for use in green energy generation and compost manufacture.
This will be great for NSW, and we hope that other States follow.