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Class CA: Installation of reverse vending machines
Class CA allows the installation, alteration or replacement of a reverse vending machine (RVM) in a wall of a shop or within the curtilage of a shop. The right took effect on 9th April 2026.
A reverse vending machine accepts used drinks containers and provides the consumer with the return value or another form of credit. Class CA treats the machine together with any associated enclosure, building, canopy or other structure as the reverse vending machine for planning purposes.
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Permitted development can avoid a full planning application, but only if the right applies and every relevant limit and condition is met. Planning Geek can check the planning history, Article 4 directions and other restrictions, and help with a lawful development certificate or prior approval where needed.
In preparation for the Deposit Return Scheme launching on 1st October 2027 in England and Northern Ireland, the government introduced Class CA to support the installation of return infrastructure at shops. 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 a reverse vending machine includes not just the machine itself, but also any associated canopy, enclosure, or building.
Class CA cannot be removed by an Article 4 direction. The 2026 Order expressly excludes Class CA from article 4.
Reverse vending size and dimension limits
To qualify for permitted development, the installation must not exceed the following physical limits:
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Maximum footprint: The gross floor space must not exceed 80 square metres.
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Maximum height: The structure cannot be taller than 4 metres.
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Wall protrusions: If installed in a shop wall, every part of the machine must protrude less 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:
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Near residential areas: It is within 15 metres of the boundary of any adjacent residential land (Part C use classes).
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Near highways: It faces onto a highway and is within 5 metres of it.
Protected Land and Heritage Sites
Class CA does not apply if any part of the reverse vending machine is to be located on:
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Protected land including conservation areas, National Parks, National Landscapes, the Broads and World Heritage Sites.
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A Site of Special Scientific Interest (SSSI).
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The site of a scheduled monument.
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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:
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Remove the machine and any associated structures as soon as reasonably practicable.
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Reinstate the land (or the wall it was installed in) to its original condition as far as is practically possible.
Lawful Development Certificate
While Class CA grants valuable permitted development rights, interpreting the finer details, especially boundary measurements, highway proximity and 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.
If you want formal confirmation before installation, you can 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 would be lawful under Class CA on the facts and plans submitted.
A certificate can be useful for property records and future due diligence, but it is not compulsory where the development clearly meets Class CA. If you require assistance navigating these new rules or preparing a robust LDC application, Planning advice can be useful where the Class CA tests are not straightforward.
Planning Geek can assist with checking Class CA or preparing a certificate application. Please use our planning applications contact form for a 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 the proposed installation falls outside any of the Class CA limits, it cannot rely on this permitted development right. Planning permission will normally be required unless another planning permission or permitted development right applies.
Does the definition of a ‘shop’ cover supermarkets and petrol station forecourts? A qualifying shop must be a building used for a Class E(a) retail purpose. Supermarkets and convenience stores can qualify. A standalone petrol filling station is generally sui generis, but a machine on a supermarket petrol forecourt needs a site-specific check of whether it is within the curtilage of the qualifying shop and meets the other Class CA limits. 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 is no longer in operation, the development must be removed as soon as reasonably practicable and the land or wall must, so far as reasonably practicable, be reinstated to its condition before the development was carried out.
Reverse vending 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.”.
Current legislation: Part 7 of Schedule 2 on legislation.gov.uk
Reverse vending Page Updated: 23rd September 2026