Class CA – Installation of Reverse Vending Machines

 

Class CA allows for a shop to install, alter or replace a reverse vending machine (RVM) in the shop front or a stand-alone reverse vending machine within the curtilage. This takes effect from 9th April 2026

A reverse vending machine (RVM) is an automated device that accepts empty beverage containers, such as plastic bottles, aluminium cans, and glass, in exchange for a reward. Unlike a traditional vending machine that dispenses goods for money, an RVM takes in recyclable waste and issues a refund, typically as a cash voucher, digital credit, or a charity donation. Their primary purpose is to incentivise high recycling rates, reduce street litter, and support deposit return schemes by giving consumers a convenient, automated way to return their empty packaging for processing and reuse.

 

 

In preparation for the UK’s upcoming Deposit Return Scheme (DRS) launching in October 2027, the government has introduced new permitted development right to fast-track the installation of vital return infrastructure. Driven by the Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025, consumers will soon pay a refundable deposit on single-use bottles and cans, creating a widespread need for automated return points on retail premises. To help retailers adapt without getting bogged down in red tape, the new Class CA permitted development right allows for the installation of reverse vending machines (RVMs) within shop boundaries—or directly into shop walls—without requiring a full planning application, provided specific size, height, and location criteria are met.

For planning purposes, a “shop” is defined as a building used for the retail sale of goods (Class E(a), excluding hot food). Crucially, the definition of an reverse vending machine includes not just the machine itself, but also any associated canopy, enclosure, or building.

Class CA, cannot be blocked via an Article 4.

 

Size and Dimension Limits

To qualify for permitted development, the installation must not exceed the following physical limits:

• Maximum footprint: The gross floor space must not exceed 80 square metres.

• Maximum height: The structure cannot be taller than 4 metres.

• Wall protrusions: If installed into the wall of a shop, no part of the machine may stick out more than 2 metres beyond the outer surface of that wall. 

 

Placement and Boundary Restrictions

The location of the RVM on the forecourt or building is strictly controlled. It is not permitted if:

• Near residential areas: It is within 15 metres of the boundary of any adjacent residential land (Part C use classes).

• Near highways: It faces onto a highway and is within 5 metres of it.

 

Protected Land and Heritage Sites

Permitted development rights do not apply, and full planning permission will be required, if any part of the RVM is to be located on:

• Article 2(3) land (which includes Conservation Areas, Areas of Outstanding Natural Beauty, and National Parks).

• A Site of Special Scientific Interest (SSSI).

• The site of a scheduled monument.

• The curtilage of a listed building.

 

End-of-Life Conditions

This permitted development right comes with a strict operational condition. If the reverse vending machine ceases to be used, the developer or site owner must:

• Remove the machine and any associated structures as soon as reasonably practicable.

• Reinstate the land (or the wall it was installed in) to its original condition as far as is practically possible.

 

Securing Your Installation: The Lawful Development Certificate

While Class CA grants valuable permitted development rights, interpreting the finer nuances—especially regarding boundary measurements, highway proximity, and specific site designations—can sometimes be complex. The last thing any retailer or site owner wants is a dispute with the local planning authority after investing in new recycling infrastructure.

For absolute peace of mind, it is highly recommended that you apply for a Lawful Development Certificate (LDC) prior to installing your reverse vending machine. An LDC provides formal, legal confirmation from your council that your proposed installation perfectly aligns with the Class CA criteria and that a full planning application is categorically not required.

Having an LDC on file is an invaluable asset. It protects you against the risk of future enforcement action, simplifies legal due diligence if you ever decide to sell or lease the commercial property, and ensures your participation in the Deposit Return Scheme gets off to a smooth, fully compliant start. If you require assistance navigating these new rules or preparing a robust LDC application, securing expert planning advice is the best way to guarantee a hassle-free rollout.

Planning Geek can assist you with this – please complete the form at https://planninggeek.co.uk/col for a free fee proposal. 

 

Frequently Asked Questions: Reverse Vending Machines and Planning

 

What happens if my reverse vending machine needs to be larger than 80 square metres? If your proposed installation exceeds the 80 square metre footprint, the 4-metre height limit, or any other specific criteria outlined in Class CA, it will not qualify as permitted development. In these instances, you will need to submit a full planning application to your local authority before commencing any installation work.

Does the definition of a ‘shop’ cover supermarkets and petrol station forecourts? Yes, provided the primary use of the building falls under Class E(a) (the retail sale of goods, excluding hot food). Supermarkets and convenience stores are clear candidates. However, petrol stations are usually classified as sui generis rather than Class E, therefore requiring planning permission. If you are unsure of your site’s exact use class, it is highly recommended to seek professional planning advice via Planning Geek

Can I place the machine in my customer car park? Yes, as long as the location is within the ‘curtilage’ (the attached land/boundary) of the shop. However, you must ensure the placement does not breach the boundary constraints, such as being within 15 metres of a residential boundary or within 5 metres of a highway that it faces. You should also consider whether the installation will result in the loss of essential parking spaces that were a condition of your original planning consent.

What must I do if the machine is eventually removed? Class CA includes a strict condition regarding the end-of-life of the machine. If it ceases operation, you are legally required to remove the machine and any associated structures, and reinstate the land or wall to its original condition as soon as reasonably practicable.

 

Legislation

 

Class CA – Installation etc of a Reverse Vending Machine

Permitted development

CA.  Development consisting of the installation, alteration or replacement of a reverse vending machine in a wall of a shop or within the curtilage of a shop.

Development not permitted

CA1.  Development is not permitted by Class CA if—

(a) the gross floor space of the reverse vending machine would exceed 80 square metres;

(b) the height of the reverse vending machine would exceed 4 metres;

(c) in the case of a reverse vending machine installed, or to be installed, in a wall of a shop, where any part of the reverse vending machine would protrude 2 metres or more beyond the outer surface of that wall;

(d) where any land adjacent to the shop is used for a purpose within Part C of the Schedule to the Use Classes Order (residential purposes), any part of the reverse vending machine would be within 15 metres of the boundary of the curtilage of that residential land;

(e) any part of the reverse vending machine would face onto and be within 5 metres of a highway; or

(f) any part of the reverse vending machine would be—

(i) on article 2(3) land;

(ii) in a site of special scientific interest;

(iii) within the curtilage of a listed building; or

(iv) on the site of a scheduled monument.

Condition

CA2.  Development is permitted by Class CA subject to the condition that where the reverse vending machine is no longer in operation—

(a) the development must be removed as soon as reasonably practicable; and

(b) the land on which the development was situated, including any wall in which the development was installed, must be, as soon as reasonably practicable, and so far as reasonably practicable, reinstated to its condition before that development was carried out.

Interpretation of Class CA

CA3.  For the purposes of Class CA—

“deposit item” has the meaning given in regulation 4 of the Deposit Scheme for Drinks Containers (England and Northern Ireland) Regulations 2025;

“reverse vending machine” means a machine for the purpose of accepting deposit items, reimbursing deposits for each deposit item accepted, and retaining the deposit item for collection and any associated enclosure, building, canopy or other structure;

“shop” means a building used for any purpose within Class E(a) (display or retail sale of goods other than hot food) of Schedule 2 to the Use Classes Order.”.

 

 

 

Reverse Vending Machine Page Updated:  20th March 2026