How to Ensure Waste Management Compliance in the C40 Cities

C40 is a network of some of the world’s largest cities that are committed to addressing climate change. Globally, the network is made of 97 cities, representing over 700 million citizens and totaling a quarter of the global economy. The mayors of these cities are committed to delivering on the most ambitious goals of the Paris Agreement at the local level and have set various performance targets across a range of sustainability indexes, from clean air to zero waste.

Which cities in North America are part of the C40?

As of 2021, there are 14 U.S. cities and three Canadian cities within the C40 network.
In the U.S. these are:

  • Austin
  • Boston
  • Chicago
  • Houston
  • Los Angeles
  • Miami
  • New Orleans
  • New York City
  • Philadelphia
  • Phoenix
  • Portland
  • San Francisco
  • Seattle
  • Washington, DC

And in Canada the cities are:

  • Montreal
  • Toronto
  • Vancouver

What are the C40 cities’ waste-related targets and how will they meet them?

In order to advance towards zero waste, all of the cities have pledged to:

  1. Reduce the municipal solid waste generation per capita by at least 15% by 2030 compared to 2015
  2. Reduce the amount of municipal solid waste disposed to landfill and incineration by at least 50% by 2030 compared to 2015
  3. Increase the diversion rate away from landfill and incineration to at least 70% by 2030

In order to meet these targets, the cities are implementing a wide range of actions, including:

  • Decreasing food losses along production and supply chains, minimizing the production of surplus food
  • Facilitating safe food donation programs and by-products for feed production
  • Implementing source separated collections for food waste and other organics
  • Investing in treatment infrastructure that recovers nutrients and energy
  • Supporting the implementation of local and regional policies, such as extended producer responsibility to reduce or ban single-use and non-recyclable plastics
  • Increasing reduction, reuse, recovery and recycling of construction and demolition materials
  • Publicly reporting every two years on the progress they are making towards these goals

As part of their zero waste efforts, 18 of these cities have now banned or restricted single-use, non-recyclable plastics.

How Does This Impact Businesses in C40 cities?

Waste management is one of the primary services that city governments provide and is a sector over which mayors exercise significant authority.

While there are no specific targets that relate to commercial waste management, the C40 cities and particularly those who signed an additional declaration of intent to work towards being zero waste, are predominantly those with the most progressive and demanding recycling ordinances at a state or local level.

Some of the common requirements of businesses are:

Segregation of Recyclables

Most of the C40 cities have requirements for commercial businesses to segregate the principal recyclable materials from their residual waste. The most common materials are:

  • Metal, glass, and plastic
  • Cardboard and paper
  • Construction waste
  • e-Waste including batteries

In San Francisco and Los Angeles, commercial and public entities that generate four cubic yards or more of solid waste per week must arrange for separate recycling services.

In New York City, all commercial businesses are required to recycle, and to ensure to the best of their ability that those recyclable materials are properly handled by their hauler.

Seattle also requires businesses to separate out paper, cardboard, plastic bottles and jars, glass and aluminium cans.

San Diego’s city recycling ordinance (CRO) mandates recycling for commercial and special event waste. Their construction and demolition debris deposit ordinance (C&D Ordinance) requires construction firms to comply with at least a 50% diversion rate.

Segregation of Organics for Recycling

Businesses, particularly those in the food service industry that operate within one of the C40 cities, should watch out for new legislation that requires organic waste to be segregated from the general waste.

If your business has sites in Los Angeles or San Francisco producing more than 2 cubic yards of commercial solid waste per week, they must separate out the organic fraction. Click this link for more information.

New York City also has an organics recycling mandate, which requires businesses in a variety of sectors to source-separate their organic material and either arrange for transportation to an appropriate processing facility, or to process their organic waste on-site.

Due to the ongoing effects of the COVID-19 pandemic, DSNY has extended the warning period for business covered in the third Commercial Organics rulemaking that took effect July 31, 2020. DSNY is not issuing any penalties to those businesses until July 31, 2022.

Follow this link for a full and up-to-date list of establishments covered by the Commercial Organics Rules.


The C40 cities have established a target to report on their progress every two years. This mandate is starting to pass down to individual business level, so that the data can be compiled to create city-wide data.

Detailed Breakdown of Waste-Related Requirements by C40 City

National - Waste - Associates - Article - How to Ensure Waste Management Compliance in the C40 Cities Table 2

Sustainable and Compliant Waste Management with NWA

Our waste management experts will help ensure your business operations are in compliance with all waste and recycling related legislation that exists from a state to town-level, including the requirements of the C40 cities. Our Compliance Manager takes all the onerous paperwork off your hands, filing compliance reports to the municipalities and managing any requests for exemptions for specific locations, as appropriate.

We work directly with your individual locations to develop effective recycling programs and perform constant waste analyses that help us to identify recycling, diversion, repurposing and reuse opportunities to keep your waste out of the landfill and ensure your continued compliance.

Do you have locations in a C40 city?
Speak to your Account Manager today!
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