CT COMMERCIAL Organics Recycling LAW
As of January 1, 2025, each commercial food wholesaler or distributor, industrial food manufacturer or processor, supermarket, grocery store, resort or conference center or institution, including those engaged in providing hospitality, entertainment or rehabilitation and health care services, and any hospital, public or private educational facility or correctional facility, in Greenwich that generates a projected annual volume of 26 tons or more - the equivalent of 143 lbs per day - of source separated organic material (SSOM) must comply with both the CT Commercial Organics Recycling Law and Public Act 23-170.
Learn if your business is subject to the new law and how to comply with state regulations by exploring the questions and resources below and by viewing the recording of the informational webinar.
Entities subject to the new law may complete the hardcopy version of the questionnaire sent in the mail and return it to the Land Use Department in the enclosed envelope, or fill out the digital version below.
Need help? If you have any questions about how to comply with CT’s Commercial Organics Recycling Law, please contact Waste Free Greenwich at wastefreegreenwich@gmail.com
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You can determine whether your business is, in fact, subject to the commercial organics recycling law yourself. The best way to understand your specific business's food waste generation rate is to perform a waste audit. This entails separating food scrap at each place where it is generated and measuring it over a given length of time, for example, a week. This number can then be extrapolated for the entire year. If you have a seasonal business, you might want to perform a few audits over the course of the year based on your busy seasons.
Tools to measure and track the amount, type of, and the source of the food waste can be found on the EPA's Resources for Assessing Wasted Food web page. Additionally, the Center for EcoTechnology's CT Food Waste Estimation Guide can help you estimate the amount of SSOM your business generates annually: https://wastedfood.cetonline.org/states/connecticut/connecticut-food-waste-estimation-guidance/#Corporate-Cafeterias -
Food businesses that fall within the above parameters MUST:
Separate such source-separated organic materials, such as food scraps, from other solid waste
Ensure that such source-separated organic materials are recycled at any authorized source-separated organic material composting facility that has available capacity and that will accept such source-separated material; and
Submit a report, in electronic format, to the Department of Energy and Environmental Protection (DEEP), on or before March 1, 2025. This report shall summarize the entity's amount of edible food donated, the amount of food scraps recycled and the organics recycler or recyclers and associated collectors used.
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The EPA’s Wasted Food Scale prioritizes actions that prevent and divert wasted food from disposal. Tiers of the scale highlight different pathways for preventing or managing wasted food, arranged in order from most preferred on the top left to least preferred on the top right. Within a given tier, pathways are ranked equally.
The most preferred pathways – prevent wasted food, donate and upcycle food – offer the most benefits to the environment and to a circular economy. These “top” pathways prioritize using food for its intended purpose: to nourish people. The least preferred pathways – landfilling, incineration, and sending food down the drain – have the largest environmental impacts and have limited potential for circularity.
Explore the strategies and resources available in Greenwich to reduce wasted food by clicking on the options below - preventing wasted food, food donation, food scraps to animal feed, anaerobic digestion & composting and the shell recycling program.
It is recommended that facilities use the EPA Food Waste Management Cost Calculator as a first step in this process to estimate the cost competitiveness of these strategies as opposed to disposal and help develop an alternative food waste management scenario. (Search for "EPA Food Waste Management Cost Calculator" in your browser)
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Preventing food from going to waste in the first place is the most environmentally beneficial option. When food is wasted, all the resources that went into producing, processing, distributing, and preparing that food are wasted too.
Decreasing the volume of wasted food can reduce the overall cost of business operations and increase operational efficiency.
Upcycling food into new food products usually takes place at the production or manufacturing stage of the food supply chain. Edible parts of food as well as less desirable scraps can be upcycled into new food products. For example, orange peels can flavor beverages, broccoli stems can be turned into slaw or be dried into powder, and spent grains from the brewing process can be turned into bread. Upcycling food is one of the most preferred pathways because it keeps food in the human food supply chain and avoids the wasting of food and the resources used to produce it.
Businesses can establish more efficient food service with these resources:
Food Tracking Systems:
Apps:
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Wholesome food that goes unsold or uneaten can be rescued, donated, or redistributed to feed people. Donating food is one of the most preferred pathways because it ensures that food and the resources used to produce it are not wasted and are instead used for their intended purpose - to nourish people. Food donation yields financial, environmental, and social benefits as approximately 1 in 10 people in Connecticut currently face hunger.
Businesses can partner with food recovery organizations or food banks to donate surplus food. Established in 2011, Food Rescue US, Fairfield County has diverted over 44 million pounds of edible food from incineration and landfill, enlisting volunteers to rescue surplus food from 315 donors to 225 local social service agency partners.
Food Rescue US, Fairfield County
Karen Saggese, Co-Site Director
203-918-3771
Businesses that provide or receive donated food are generally well-protected by laws designed to provide immunity from liability related to such donations. The federal Bill Emerson Good Samaritan Food Donation Act provides liability protection for food donors, and state law offers protection for donors that supply food to a nonprofit organization in good faith, provided that the donation meets state safety and labeling guidelines. Connecticut businesses are also eligible for federal tax incentives, which are available in the form of general and enhanced tax deductions, to make food donation less costly for businesses
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Food scraps nourish animals which in turn nourish humans, keeping wasted food within the human food supply chain. Feeding food scraps to animals reduces the amount of conventional animal feed that needs to be grown and processed and reduces the environmental impacts associated with that feed production. Turning wasted food into animal feed can also save businesses money as it can be cheaper than hauling wasted food to be burned or landfilled.
Several local and regional companies help businesses, primarily manufacturers and distributors, directly turn their unwanted food into high-quality, nutritious animal feed. Haulers may also transport food to these processors.
Laxmi Wordham, Chief Growth Officer
Berlin, CT
917-319-9329
Accepts food from manufacturers and distributors, as well as institutions depending on quantities
Perth Amboy, NJ
732-826-4240
Accepts only bread and grain products
Secaucus, NJ
201-826-4240
Accepts only bakery by-products
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Businesses may start an on-site compost system to manage source-separated organic material, or contract with a hauler to transport SSOM to an authorized processing facility, such as an anaerobic digestion or composting facility.
Check with your existing waste hauler if they will provide this service, or contact these specialized organics haulers licensed in Greenwich:
Sam King, Co-owner
860-266-7346
Nick Skeakas, Owner
914-646-6890
Alternatively, facilities may employ an onsite, in vessel aerobic composter which can process the food scraps within 24 hours into a nutrient rich soil amendment that can be used on your landscaped property or sold as a revenue stream. Contact the following companies for further information:973-453-1263
(332) 266-0090
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The nonprofit Collective Oyster Recycling and Restoration (CORR), in collaboration with the Greenwich Shellfish Commission, Greenwich Conservation Commission and Waste Free Greenwich, offers businesses the opportunity to divert shells from the waste stream to restore native oyster habitat. CORR will pick up source-separated shells at no cost to be cured and returned to the Long Island Sound, reducing the amount of food waste required to be recycled.
Greenwich's Shell Recycling Program is critical to the sustainable growth and rehabilitation of oyster beds, improving water quality, providing marine life habitat, and protecting shorelines by limiting erosion. In addition, the initiative addresses Connecticut’s waste crisis by diverting heavy shell from the waste stream to higher and better use.
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Where are the permitted food scrap recycling facilities located?
You can find a list of permitted food scrap recycling facilities in Connecticut on DEEP's website. For those businesses close to state borders, New York and Massachusetts, also have similar lists on their websites.
Will I be fined for not complying with the law?
There are no monetary fines (civil penalties) specifically connected with the law. However, DEEP may pursue enforcement, pursuant to its Enforcement Response Policy, against a non-compliant company that is making no good-faith effort to meet the requirements of the law. It is far better for the environment, and likely more economically feasible for the company, to recycle food scraps than to dispose of them.
Does donating edible food, or sending food residuals to animal feed manufacturers and animal farms for feed count toward compliance with the law?
Yes. The goal is to divert materials from disposal. Food recovery for human consumption and feeding animals are higher on the state and federal waste management hierarchies than other uses. If you send all of your food residuals to donation/animal feed, you are in compliance with the law. However, if you only send a portion of your residuals to donation/animal feed, and you generate more than 26 tons per year (including the portion that is donated), then the rest of your residuals need to be recycled as well in order for you to be in compliance. Please see CT DEEP’s Food Waste Reduction & Recovery webpage and Food to Animal Feed resources for more information.
If I use on-site equipment that liquefies my food scrap and sends it down the drain to the sewer, is this in compliance with the law?
No. But if you collect, transport or otherwise divert that liquefied/slurried food to a permitted food residual recycling facility, then you would be in compliance with the law. Sending concentrated waste down the drain could result in clogging or backup of the sanitary sewer line and may be prohibited by local ordinance, or require a local or state permit.
If I use on-site equipment that dehydrates my food scraps, is this in compliance with the law?
The material that exits the dehydrator is still considered to be solid waste. Only if the dehydrated material is then further composted or anaerobically digested would this be in compliance with the law. Additionally, the business's SSOM generation rate would be determined before dehydration, not after, because the law bases the quantity threshold on generation rate, not disposal rate.
If I use on-site equipment that creates energy from food scraps through the use of anaerobic digestion, is this in compliance with the law?
Yes, but only if the resulting digestate is further composted and reused.
Are biodegradable products (e.g., compostable plates and cups) included in the definition of source separated organic material (SSOM)?
No, these materials would not be included in the definition of SSOM. However, depending on where a business is sending its SSOM, it may be possible to include these materials as part of the food waste collection. A business should always check with its hauler and/or compost facility to determine whether these materials can be accepted at the destination facility.