Different Regulations, One Framework: How Multi-Unit Restaurants Can Simplify Food-Waste Compliance

The regulations around food waste are changing fast. As of September 2026, a dozen states have already enacted laws requiring certain commercial businesses to divert food waste from landfills, according to the State Climate Policy Dashboard. For a multi-unit restaurant portfolio, these laws aren’t just requirements to track. They create a compliance environment that is constantly evolving, making it hard to know what applies, where and when.

Unlike many areas of restaurant operations, food-waste requirements are not governed by one nationwide standard. Requirements can vary by state, county and municipality. What applies to a restaurant may depend on its size, how much food waste it generates, where it is located and whether food recovery or recycling services are available nearby.

That creates a major challenge for operators managing dozens or hundreds of locations: How do you build a food-waste program that is consistent enough to manage at the portfolio level, but flexible enough to meet local requirements? The answer is a repeatable framework that makes those local differences easier to manage at scale.

Compliance Requirements

The first step is knowing which food-waste requirements apply to each location.

For a multi-unit portfolio, create a location-level compliance matrix that captures the jurisdiction, restaurant size and seating, estimated food-waste volume, regulated materials, effective dates, exemptions, approved handling options and required records. This gives operators a clear view of what applies where, and helps identify locations that may need attention as requirements change.

That level of visibility matters because what triggers compliance can vary significantly from one location to the next. California, Massachusetts and New York show just how different the rules can be:

• California: Under SB 1383, Tier 2 restaurants — 5,000 square feet or 250+ seats — have been subject to edible-food recovery requirements since January 1, 2024. Covered businesses must safely recover as much surplus edible food as possible that would otherwise be thrown away, establish a written agreement with a food recovery organization or service and maintain donation records onsite.

• Massachusetts: MassDEP uses food-waste volume as its trigger. Restaurants that generate more than one-half ton of food materials per week are subject to the state’s commercial organic waste disposal ban.

• New York: The state’s Food Donation and Food Scraps Recycling law combines food-waste volume with the availability of recycling services. Through the end of 2026, restaurants generating an average of at least two tons of wasted food per week must donate excess edible food and recycle remaining food scraps if an organic recycler with capacity is within 25 miles. Beginning January 1, 2027, the threshold drops to one ton and the distance expands to 50 miles. This threshold shift isn’t unique — Massachusetts did the same thing in 2022, cutting its own threshold in half. It’s a sign of how food-waste requirements can evolve over time, with lower thresholds bringing more businesses into the scope of the regulations.

The takeaway: Start with the location, not the national program. A portfolio-wide process can standardize how teams identify requirements, document compliance and manage changes, while giving each restaurant the flexibility to follow the rules that apply to its location.

Food Waste Management

Once you know which rules apply, look at what food waste each restaurant generates and where it goes.

Start by mapping the major food waste streams, from edible surplus and kitchen food scraps to post-consumer food waste. Then connect each stream to the vendor handling it. A vendor review should answer a few basic questions: Which materials are accepted at this location? Is the hauler authorized to provide the service where required? Where does the material ultimately go? Can the vendor provide pickup, weight or contamination data by location? What happens when there is a missed pickup, rejected load or disruption at the processing facility?

New York illustrates why this matters. State requirements direct regulated food scraps to approved organics recyclers or qualifying intermediaries, while New York City allows covered businesses to use private carters, self-transport or approved on-site methods. The right solution can depend on both the location and the services available there.

A national contract does not automatically equal local compliance. Vendor capabilities need to be verified at the restaurant level. A provider that works in one market may not accept the same materials or have an appropriate outlet in another. California, for example, recognizes that food recovery organizations differ in the types and amounts of food they can accept, meaning a covered donor may need more than one agreement.

The takeaway: Audit the food waste, verify the vendor and build the program around what each location can actually support.

Employee Training

Even the right program can break down if employees aren’t sure what goes in which bin.

The most practical approach is to standardize the portfolio’s training content while localizing the details. Core training can cover food-waste separation, contamination prevention, donation safety, bin checks and what to do when something goes wrong. Location-specific training should then show employees the actual containers, labels, accepted materials and vendor instructions for their restaurant.

It’s also worth accounting for how different teams interact with food waste: back-of-house staff typically separate scraps in the kitchen, while front-of-house staff keep food waste separate from trash in customer-facing areas. Clear, team-specific responsibilities help prevent contamination from packaging, cutlery and other non-food materials.

Build these practices into daily operations:

• Introduce waste procedures in employee onboarding

• Refresh training periodically and after contamination or other issues

• Use clear, easy-to-understand signage, translated where appropriate

• Give employees a clear path for questions or problems

For restaurants donating edible food, waste training should also connect to food-safety procedures, including proper handling, temperature control, hygiene, transportation and recordkeeping.

The takeaway: The goal isn’t to give employees more rules to remember. It’s to make the right action obvious when they’re standing in front of the bin.

Compliance Documentation

A strong compliance program should make it easy to show what is required, what is being done and how it’s being documented.

Some records are required by law; others simply make compliance easier to manage and demonstrate. Maintaining a centralized record for each location keeps documentation organized and makes it easier to respond when requirements change or questions arise. Depending on the location and applicable requirements, records may include compliance assessments and applicability calculations, current agency guidance, waivers or exemptions, hauling and food-donation agreements, vendor authorizations, pickup and weight records, where available, training records, current signage, inspection findings and corrective actions.

In many jurisdictions, businesses must submit an annual food waste diversion plan or keep a copy on file with their other documentation, available upon request during an inspection.

There should also be clear ownership at both the portfolio and restaurant levels. At the portfolio level, assign responsibility for maintaining compliance information and monitoring regulatory changes. At the restaurant level, identify who is responsible for day-to-day operations, including sorting, storage, vendor issue escalation and recordkeeping.

The takeaway: Documentation should be a byproduct of daily operations, not something teams scramble to assemble after an inspection.

Food-waste compliance isn’t about chasing every new law as it lands. It’s about building one system that can adapt as the rules change.

Operators who standardize the process and localize the execution can manage compliance consistently across the portfolio while adapting to what each location requires. That means less reinventing the wheel, fewer surprises and a framework that can keep pace as the regulatory map evolves.

John Ayvas is the CEO of Lincoln Waste Solutions by Reconomy, a leading managed waste solutions partner for multi-location operators. With 20-plus years in environmental services, he has led Lincoln since 2015, working with restaurant groups across the U.S. and Canada to build compliant food-waste programs and address organics regulatory concerns.