This article is written to meet the following sections of the Standards:

BRCGS Food Safety Issue 84.12 Waste/waste disposal

4.13 Management of surplus food and products for animal feed

BRCGS Packaging Issue 64.10 Waste and waste disposal
BRCGS Agents & Brokers Issue 3
4.9 Management of surplus products
BRCGS Storage & Distribution Issue 46.5 Waste and waste disposal

17 waste recovery and recycling

FSSC22000 Version 5.1ISO 22000:2018 8.2.4 d) PRP – waste and sewage disposal
IFS Food Version 74.11 Waste management
SQF Edition 911.8 Waste Disposal

Waste and surplus materials – what’s the difference?

Although surplus materials may be waste to us, they can be repurposed. Here are the terms we tend to use when talking about waste.


  • General waste – materials which are typically sent to landfill.
  • Recycling – materials which are sent for recycling.
  • Animal feed – materials which can be processed into animal feed (including pet food).
  • By-product – materials which are made as a result of processing the product, but not required. Typically, sold as an ingredient for further processing.
  • Surplus materials or product – materials (including product) which doesn’t meet the specification or isn’t needed for the order. Surplus material may be in work in progress, in finished format or even packed. Surplus materials can be reworked as good product, before they’re considered as ‘waste’.
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Streams of waste

Waste can come from the processing of product, or stock that’s not needed. Waste can also be transported, either as returns, unwanted stock or when returning product containers (such as when bringing bread baskets back from store that may contain product or other waste materials).

Waste that’s processed is typically well controlled. The process of handling waste during transportation is a subject that’s often overlooked as it’s a difficult one. Here we look at the requirements for both.

Waste handling on site

Waste procedures must be in place and trained out to all relevant staff. The procedure must include:

  • Details of staff responsibilities.
  • How to empty of waste containers and at what frequency.
  • Segregation of waste.
  • Isolation of waste that doesn’t meet specification (such as recycling that contains other types of waste).
  • What to do in the event of a spillage, including the cleaning procedures.

Waste handling areas

Waste areas must be managed to minimise the risk of contamination of product, including:

  • Identification of storage areas to ensure waste is collated only in designated areas.
  • Segregation of the area from product areas.
  • Facilities which are designed for ease of cleaning.
  • Keeping facilities well maintained.
  • Keeping external doors closed.
  • Suitable pest management.
  • Cleaning procedures, including cleaning following spills.
  • Spillages must be removed as quickly as practical (at least daily).
  • Waste leaking from compactors, must be cleared up as they occur.

Waste containers

External waste containers must be managed to minimise risk, including:

  • Clear identification that it’s a waste container.
  • Designed for ease of use and effective cleaning.
  • Well maintained to allow cleaning and disinfection (if needed).
  • Emptied at appropriate frequencies.
  • Kept closed so not to attract pests.
  • Adequate proofing.

Haulier waste handling

Where waste is carried in vehicles, a risk assessment must determine what waste is acceptable and what’s not. For waste that’s deemed acceptable, controls must be in place including:

  • The driver must be trained to know what types of materials can and can’t be carried.
  • Waste segregation to prevent contamination of product – using barriers or floor markings.
  • Vehicles must be cleaned after carrying waste and before transporting products.

When the waste arrives at site it must be suitably segregated from product. The procedure for waste handling must be available to the driver at all times (such as a handbook kept in the vehicle).

Environmental controls

Spills cause pollution, so it’s important that the environment doesn’t become contaminated. Plastic pellets, also known as nurdles are responsible for the pollution of seas around the world. Spills from manufacturing and the transit of the pellets within the supply-chain, cause them to get into the water systems and then out to sea. Marine life then digest them and once they’re consumed, they stay there – meaning that there’s less room for food.

Although the media focuses on contamination from pellets, any plastic contamination is an issue, so this includes flake, powder, dust and offcuts. Any waste which is inadvertently discharged can have a negative impact on the environment, so you need to think further than just plastic. This means you need to think about your spill procedures at site and also when the product is being transported throughout the supply-chain, to ensure that it’s effectively controlled.

Any rework, by-product, or waste that can be harmful to the environment, must be managed so that it’s not accidently released into the environment.


Where by-products, surplus product or materials for animal feed are sold, a specification should exist for the materials (such as levels of purity of waste materials). This means that the material must be assessed to make sure that it complies with the specification.

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Repurposing branded product

Where permitted by customers, good surplus product may be sold to other customers. Product must meet customer requirements for surplus product, such as removal of branded information.

Where branded products don’t meet the customer specification but meet legal requirements and are fit for human consumption – they may be sold to staff or passed on to charities, with the prior consent of the customer. The product must meet a minimum specification, to ensure that it’s legal and fit for consumption. The procedure must include responsibilities and who has authorisation to release such product.

Disposal of branded product

Where trademarked materials and equipment are put to waste, they must be rendered unusable through a destructive process, to:

  • Prevent counterfeiting.
  • Ensure that they don’t re-enter the supply-chain.

Where it’s rendered unusable by a contractor, the contractor must be approved through the supplier approval system, to ensure that they employ the necessary controls. Records of the disposal must be retained and include the quantity for traceability purposes.

Where required by the customer, the requirements for disposal must be defined in the customer contract.

Animal feed

Materials intended for further processing into animal feed must be:

  • Segregated from waste and protected from contamination.
  • Managed in accordance with relevant legislative requirements and any certification schemes (such as FEMAS).
  • Handled by an animal feed contractor who is appropriately licensed.

The law around animal feed

When sending by-product or surplus product for animal feed, there are two main routes to do this:

  1. Via a feed manufacturer (recommended option).
  2. Direct to the farm (this is much more complex).

If you do either of the above, by law you must be registered and approved (by your local authority) under the Feed Hygiene Regulations, as you’re considered to be a “Feed Business Operator”. Once registered, the local authority may come to your site to approve you and both registration and approval must occur prior to supplying product for animal feed.

Via a Feed Manufacturer

If you supply a feed manufacturer, you’ll have to provide the feed manufacturer with a specification of the material which will be supplied. In addition, the feed manufacturer will also provide you with any specific requirements that the material must meet (such as a micro specification).

Sending your product to a feed manufacturer is definitely a better option, as the feed manufacturer will advise you on the product you’re supplying, to ensure that it meets the legislation for the feed they’re making. This means you don’t need to know the detail of the legal requirements.

You must ensure though that the product you send them adheres to the agreed specification including the requirements that they specified. The feed manufacturer if approved by one of the assurance schemes (such as FEMAS or UFAS) will need to carry out an approval process of you (as their supplier) and also ongoing monitoring of you, to ensure that you’re adhering to the agreed specification and contract.

Remember product sent as animal feed must be of a food standard, so if you have a food safety contamination issue on site – make sure that product sent for animal feed isn’t contaminated. Food safety contaminated product must not to be sent to a feed manufacturer without their prior written consent. But in some cases, they may be able to accept it with prior notification – as they may be able to adapt their process to remove the risks. Your customer (the feed manufacturer) must also be notified if you find out that a food safety contamination issue has occurred after you’ve sent the product to them.

Direct to Farm

If you send material direct to the farm for consumption as animal feed, you need to ensure that you meet all the legal requirements, so this is much more complicated. Materials which contain ingredients of animal origin can’t be sold as material for animal feed for farmed animals.

Material sent as animal feed needs to be of a food standard, so you need to think about how you’re handling and storing the product, so it doesn’t become contaminated. Speak to your local authority about what standards you need to adhere to. For further details see EC Regulation 183/2005 laying down requirements for feed hygiene.


Removal of waste must be carried out by licensed contractor’s and records of removal must be retained. Where waste is governed by legal requirements, the legislation must be understood. There must be a process in place to ensure that the site is kept up-to-date with legal requirements.

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