Bones, fat, and unsold meat can become animal by-products (ABPs), but they are not automatically waste. Suitable bones kept for making stock, or fat retained for food production, remain within production.
This guide outlines how to separate animal by-products correctly, decide what is still food, and arrange a compliant collection route for your butchery.
This guide is based on APHA guidance for England, Scotland, and Wales. For businesses in Northern Ireland, refer to DAERA’s ABP guidance. Waste and recycling laws also vary between nations.
When Does Food Become an Animal By-Product?
An animal product officially becomes an ABP when it is no longer intended for human consumption. This can happen when suitable surplus stock is withdrawn for commercial reasons, or when material must be removed because it is unsafe.
Once food has been designated as an ABP, it cannot be returned to human consumption.
| Situation | Point to Explain |
|---|---|
| Bones retained for sale as stock bones | They are still intended for human consumption and handled accordingly. |
| Fat retained for a recipe | Trimming fat from a joint does not automatically make it waste if it is kept for food production. |
| Unsold sausages still suitable and legally available for sale | Being “unsold” alone does not make them ABPs. |
| Bones and fat set aside for disposal | They officially enter the ABP system and need appropriate classification, labeling, and handling. |
| Meat withdrawn because of contamination or a safety concern | You must remove it from sale immediately, establishing the correct ABP category and disposal route. |
Keep suitable trimmings retained for food production within your hygienic food-handling system. Keep material designated as an ABP separate from food.
Which Category Applies?
Under UK law, ABPs are divided into three categories based on their level of risk to public and animal health.
| Category | Examples |
|---|---|
| Category 3 | Certain bones, fat, and trimmings from animals that are fit for human consumption. This also includes some food withdrawn for commercial reasons. |
| Category 2 | Certain contaminated or unsafe material (e.g., metal contamination or floor droppings). |
| Category 1 | Specified risk material (SRM), where applicable, and other material subject to the highest controls to prevent disease transmission. |
Many routine butchery by-products fall into Category 3. However, if you mix Category 3 material with Category 2 material in the same bin, the whole bin must legally be handled under the higher-risk Category 2 rules.
Do not assume that everything removed from sale belongs in Category 3. If meat is contaminated or spoiled in a way that presents a health risk, keep it separate and confirm its classification before collection.
Separate, Label and Store the Material Correctly
To prevent cross-contamination in your prep room, establish a strict storage routine for your surplus products:
- Keep ABPs separate from food intended for sale or further preparation.
- Use clean, lidded, leakproof containers designated for ABPs.
- Keep different categories separate.
- Protect stored material from pests and other animals.
- Prevent leaks, and clean and disinfect reusable containers after collection.
For ordinary Category 3 material, your bins must be clearly labeled during storage and transport. APHA requires this wording for category identification:
CATEGORY 3 — NOT FOR HUMAN CONSUMPTION
While colour-coding your bins (e.g., using black bins for general waste and white for food waste) helps staff, colour alone is not legally enough.
Why Can’t It Go in the Ordinary Waste Bin?
Your ordinary waste collection may not cover the ABPs your business produces. Check that the collector can accept the material and that its destination is authorised for the relevant category and treatment.
Depending on the material, this may include approved rendering, incineration, composting or anaerobic digestion.
The Small-Quantity Exemption
There is a limited small-quantity landfill exemption for certain retail waste, subject to a 20 kg weekly limit and correct records. Check that your material and disposal arrangements qualify before using the exemption.
The limit concerns the total amount of the material produced that week. A business producing 50 kg of meat waste cannot send the first 20 kg to landfill under this exemption and arrange an ABP collection only for the remaining 30 kg.
Separate recycling and landfill laws still apply. These differ slightly across England, Scotland, and Wales, so always check your local environmental laws and requirements.
What Should You Check With the Collector?
When arranging or reviewing your ABP collection service, ask the contractor:
- Are you registered with APHA (or DAERA) to transport these specific ABPs?
- Which categories and materials does your service accept?
- Where will the material go, and is that facility officially authorised for it?
- Can you accept packaged products, or does the packaging need to be removed before collection? Also agree on how contaminated packaging will be handled, as the packaging may not be suitable for ordinary recycling.
- Who supplies and cleans the bins?
- What documentation will accompany each collection?
Give the collector more detail than “meat waste”. Explain whether the collection includes raw trimmings, bones, or packaged sausages, and flag any contamination, spoilage, or material that may require a different category.
What Records Should You Keep?
For normal ABP collections, you must retain the commercial document provided by the collector. This document identifies the material and provides a traceable record of its movement. It should include:
- Collection date.
- Material description and ABP category.
- Quantity or weight.
- Origin, transporter, and destination details.
- Relevant approval or registration numbers.
- Signature of the responsible person.
Keep the commercial documents and records for at least two years, and have them available for inspection.
These records are just for waste management. You can find a full guide to the documentation required for food businesses here.
Does a Shop Producing ABP Need Separate Approval?
Producing ABPs during normal shop operations does not necessarily mean the shop needs separate ABP registration. Additional activities, such as collecting material from other businesses or processing ABPs on-site, may require registration or approval.
Always check the APHA requirements before expanding your operation.
Planning Your Waste Management
When planning your preparation area, allow adequate space for food trays, clearly identified by-product containers, and a collection route that avoids contaminating food or equipment. Review those arrangements if your production volume increases.
For questions about official ABP classification and disposal, always consult APHA or your local authority.
To reduce avoidable waste before food becomes an ABP, read our guide.