LEGISLATION
The 2027 landfill ban: what every South African commercial kitchen needs to know now
Most South African commercial kitchen operators have heard about the 2027 deadline. Fewer know that the legal framework behind it has been in place since 2013, that a separate liquid waste restriction has applied since 2019, or that non-compliance today is not a future risk — it is a current one. This article explains exactly what the law requires, when it requires it, and what your kitchen needs to have in place before 1 January 2027.
KEY FACTS AT A GLANCE
- The National Norms and Standards for disposal of waste to landfill (GRN 636) have been law since 2013.
- Food waste has been banned from landfill since 1 January 2027 under the 12-year implementation period.
- Waste with a moisture content above 40% or a pH below 6 has been banned from landfill since 2019 — putrefied food waste meets both criteria.
- Enforcement under NEMA can result in compliance notices, administrative fines and criminal prosecution.
- Getting a commercial kitchen compliant with Bokashi Bran® takes less than one week.
Where the law comes from
South Africa’s approach to waste management is governed by the National Environmental Management: Waste Act No 59 of 2008 (the Waste Act), which operates under the broader National Environmental Management Act No 107 of 1998 (NEMA). These two pieces of legislation establish that every generator of waste — including every commercial kitchen operator in the country — is a holder of waste with direct legal obligations from the moment waste is generated until it reaches lawful final disposal.
The Waste Act empowers the Minister of Environment to set binding norms and standards for waste management. In 2013, that power was used to publish Government Notice R 636 in Government Gazette 36784 — the National Norms and Standards for Disposal of Waste to Landfill, commonly referred to as GRN 636. This is the document that contains the 2027 deadline, the 2019 liquid waste restriction and the full framework for progressive landfill diversion. It is binding law. It has been binding law for over a decade.
The full compliance timeline
GRN 636 does not simply set a single future deadline. It establishes a series of progressive implementation timeframes, each banning a specific waste stream from landfill disposal after a fixed period from the gazette date. The table below sets out the full timeline and what it means for commercial kitchens specifically.
| Year | Regulation | What it means for your kitchen |
|---|---|---|
|
2013 |
GRN 636 published |
The full legal framework comes into force. All implementation clocks begin running. |
|
2018 |
25% garden waste diversion |
First mandatory diversion target for garden waste at landfill facilities. |
|
2019 |
Liquid waste restriction — in effect now |
Waste with moisture content above 40% or pH below 6 prohibited from landfill. Putrefied food waste satisfies both criteria. |
|
2023 |
50% garden waste diversion |
Second mandatory garden waste diversion milestone. |
|
2027 |
Food waste full ban — the final deadline |
All food waste, sewage sludge and fat trap waste prohibited from landfill disposal. Zero organics to landfill from 1 January 2027. |
Two dates in this timeline deserve particular attention.
2019: the restriction that already applies
Section 5(q) of GRN 636 prohibits the disposal to landfill of waste with a moisture content above 40% or a pH below 6 — or waste that liberates moisture under pressure. This restriction came into effect six years after gazette, which means it has applied since 2019. Food waste that has been allowed to putrefy satisfies all three criteria: it has a pH of approximately 4, a moisture content well above 40%, and releases liquid under compression. If your kitchen is currently depositing food waste in a general waste skip that goes to landfill, you are already in breach of a restriction that came into force six years ago.
2027: the final deadline
The 12-year implementation period for the full food waste ban expires on 1 January 2027. From that date, no food waste — cooked or uncooked, processed or raw — may be disposed of at a general waste landfill facility. This applies to every commercial food service operator in South Africa: hotels, restaurants, hospitals, schools, corporate canteens, conference centres, game lodges and every other operation that generates post-consumer food waste.
“The 2027 deadline is not the first deadline in the GRN 636 framework. It is the last one. The framework has been running for over a decade, and the final milestone is now less than a year away.”
What the law actually requires of your kitchen
NEMA Section 16 places six direct obligations on every holder of waste. For a commercial kitchen operator, these translate into concrete operational requirements:
Segregate at source
Food waste must be kept separate from general waste, recyclables and packaging at the point of generation. Contaminated general waste that contains food waste cannot be recycled and cannot be legitimately disposed of at landfill after 2027.
Store safely
Waste must be stored in a manner that does not endanger health, contaminate the environment, create a nuisance through odour or attract pests. An open skip containing mixed food and general waste satisfies none of these requirements.
Dispose lawfully
Waste must be disposed of only at a permitted facility or through an approved treatment process. From 1 January 2027, a general waste landfill is not a permitted disposal route for food waste.
Use registered transporters
Food waste may only be collected and transported by a registered waste transporter. Your waste management contractor must hold the relevant GDARD or provincial registration.
Keep records
You must maintain records of waste volumes, collection, transport and disposal. Monthly collection reports and annual certificates constitute this compliance record.
What enforcement looks like
NEMA is not toothless. Enforcement mechanisms include compliance notices, administrative fines and criminal prosecution. Under Section 31L, a compliance notice can be issued requiring a specific remediation action within a defined timeframe. Failure to comply with a notice constitutes a criminal offence. Under Section 28, any person who causes, or threatens to cause, significant pollution or environmental degradation is required to take remedial action at their own cost — the polluter pays principle operating in practice.
The Western Cape is already ahead of the national enforcement curve. City Manager Notice CTA89/2022 requires all hospitality and food manufacturing operators in Cape Town to submit an Integrated Waste Management Plan to the City demonstrating how they will achieve 100% organic waste diversion by 2027. Operators who have not submitted a plan are in breach of a municipal notice as well as the national framework.
Beyond regulatory enforcement, there is a growing commercial compliance dimension. Hotel groups, corporate canteen operators and institutional food service providers are increasingly embedding food waste compliance requirements into supplier contracts and ESG reporting frameworks. The question is no longer only whether the regulator will act. It is whether your clients will.
If your kitchen is currently sending food waste to a general waste landfill, you are not approaching a deadline. You are already non-compliant with the 2019 liquid waste restriction. 2027 is the final milestone — not the first.
What your kitchen needs to have in place by 2027
Compliance with the 2027 deadline requires five things to be in place. None of them requires capital expenditure, new infrastructure or a fundamental change to how your kitchen operates.
- Food waste separated from general waste at every waste generation point in your kitchen, on every shift.
- Food waste treated and stored in sealed containers that prevent odour, pest attraction and environmental contamination.
- Food waste collected by a registered waste transporter and taken to a composting, vermicomposting or other approved organic treatment facility — or composted on site through an approved method.
- Monthly records of food waste volumes, collection dates and disposal route.
- Annual documented proof of diversion — a certificate or report from your service provider confirming the volumes diverted and the disposal method used.
How long does it take to get compliant?
Getting a commercial kitchen compliant through the Bokashi Bran® system takes less than one week from first contact. The process is: site assessment, drum configuration, SCHWAS team documentation and staff training, first collection. Monthly reports follow from the first collection. The annual IEMA-certified Certificate of Environmental Stewardship — your documented proof of diversion — is issued at year end. There is no capital expenditure, no equipment to purchase and no operational disruption.
Bokashi Bran® has been diverting post-consumer food waste from landfill since 2012. Over 100 commercial kitchen clients — including major hotel groups, corporate canteen operators, schools and golf courses — are already compliant, documented and certified. Their monthly collection reports and annual carbon certificates constitute the compliance record the 2027 deadline requires.
2027 is less than a year away. The time to act is not when the deadline arrives. It is now.
READY TO GET COMPLIANT?
Contact Frank Selepe to get your kitchen assessed and a proposal on the table within 48 hours.
frank@bokashibran.co.za · 063 952 7033 · or contact Bronwyn Jones: bron@bokashibran.co.za · 082 456 9225
Further reading
For the full legislative framework, see our Legislation page: bokashibransa.co.za/legislation
For the Cape Town IWM Plan requirement, see: bokashibransa.co.za/legislation#cape-town
Primary sources: GRN 636, Government Gazette 36784 (2013) · NEMA No 107 of 1998 · Waste Act No 59 of 2008 · City Manager Notice CTA89/2022