Two years after New Hampshire banned the disposal of large amounts of food waste in landfills, a new study has revealed a significant gap between policy and practice: the state still lacks enough infrastructure to make the law fully enforceable.
Michael Nork, who supervises materials management, education, and planning at the New Hampshire Department of Environmental Services (DES), said that if all the food waste currently being disposed of in landfills was directed elsewhere, existing compost facilities and food diversion programs wouldn’t have the capacity to handle it.
“We’re hoping that this study provides a signal to those in the food waste management kind of field to think about siting facilities in New Hampshire, whether that’s a composting facility or other processing and management facilities that address food waste issues,” Nork said.
According to the study, commissioned by the state DES, New Hampshire’s composting facilities have a total processing capacity of 8,096 tons per year, but only 3,405 tons of that capacity currently sits unused.
Meanwhile, businesses and institutions subject to the ban generate an estimated 36,500 tons of food waste annually.
The state law, passed in 2025, prohibits anyone who generates at least one ton of food waste per week from sending it to a landfill or incinerator if an authorized composting or alternative facility exists within 20 miles of the point of generation.
The EPA-funded study, part of the Solid Waste Infrastructure for Recycling grant program, found 888 entities statewide fall under the ban.
Food processors and manufacturers generate the largest share of food waste, at 155,570 tons, a category that includes dairy manufacturing, slaughterhouses, seafood processing, bakeries, sugar and confectionery makers, grain and oilseed milling, and breweries.
Infrastructure gaps
The study also pointed out where New Hampshire’s infrastructure gaps are widest. They run through the southeastern part of the state and a swath stretching from Merrimack County up through the North Country.
“There are composting facilities on the periphery, like near the borders of New Hampshire, but even still, those areas still need more development of infrastructure,” he said. “There aren’t really enough facilities for commercial-level generation.”
Data from the study shows Hillsborough and Rockingham counties generate the most food waste in the state, at 51,090 and 68,820 tons per year, respectively.
The study identifies five New Hampshire facilities that process food waste: GBN Farms in Chester, Lebanon Solid Waste Facility in Lebanon, Meadowstone Farm in Bethlehem, Renewal Compost in Derry, and Winter Street Farm, LLC in Claremont.
Together, these facilities are located within a 20-mile radius of approximately 460 businesses and institutions covered by the law. However, the study found that their combined processing capacity is insufficient to meet the anticipated demand for food waste composting.
There are also 16 facilities across New England within a 20-mile radius of New Hampshire’s food waste generators that would be required to divert their waste from landfills.
One project that could help address the shortfall is a proposed anaerobic digester by PurposeEnergy in Londonderry. The application remains under state review, and if approved, the facility would become New Hampshire’s first anaerobic digester designed to process food waste.
As for when the law will be fully enforced, Nork said there’s no set timeline, and it hinges on how quickly new infrastructure comes online.
That’s the same way states like Vermont, New York, and Connecticut have taken with similar bans, he said.
“They all have this kind of underlying intent that creating a ban helps kind of set a level playing field and creates market conditions that allow infrastructure development or encourage infrastructure development because entrepreneurs that are looking to get into the market know that they’re going to have a kind of a guaranteed customer base,” Nork said.
