Legislation
Waste Transfer Notes: What They Are & When You Need One
A waste transfer note is a legal document required every time non-hazardous controlled waste is transferred from a business to a waste carrier or disposal facility. If your business produces commercial waste — which applies to virtually every UK organisation — waste transfer notes are a statutory obligation, not a formality.
The requirement sits under Section 34 of the Environmental Protection Act 1990 and the Environmental Protection (Duty of Care) Regulations 1991. Failing to have a valid waste transfer note in place can result in a £300 fixed penalty notice from your local council, or an unlimited fine on prosecution in court.
This guide explains exactly what a waste transfer note is, what it must include, when an annual season ticket applies, how it differs from a hazardous waste consignment note, and what is changing when mandatory digital waste tracking is introduced.
What Is a Waste Transfer Note?
A waste transfer note (WTN) is a document that records the lawful transfer of controlled waste from one party to another. It creates an audit trail — sometimes called a chain of custody — confirming that waste has been passed to an authorised carrier and will be handled, recovered, or disposed of in compliance with the law.
The legal foundation is Section 34 of the Environmental Protection Act 1990, which places a duty of care on anyone who imports, produces, carries, keeps, treats, or disposes of controlled waste. The duty of care waste transfer note requirement is further detailed in the Waste Duty of Care Code of Practice (2018), which provides the practical guidance businesses are expected to follow.
Waste transfer notes apply to controlled waste — a legal term covering most commercial, industrial, and municipal waste. The duty applies to waste produced at any business premises: offices, retail units, restaurants, manufacturing sites, schools, and hospitals all fall within scope. For more on what the duty of care requires of your business — and the Act that underpins it — see our guides to waste duty of care obligations and the Environmental Protection Act 1990.
Who Needs a Waste Transfer Note?
Any business that produces, transports, or receives non-hazardous controlled waste in England or Wales must have a waste transfer note in place. This applies to:
- All businesses regardless of size — sole traders, micro-businesses, SMEs, and large enterprises
- Waste carriers collecting commercial waste from any premises
- Facilities receiving waste — recycling centres, transfer stations, and treatment facilities
Both the party handing over the waste (the transferor) and the party receiving it (the transferee) must complete, sign, and retain their own copy.
The only exemption is for domestic occupiers disposing of their own household waste. If you work from home, any waste generated through your business activities is commercial waste and is not exempt — it requires a waste transfer note regardless.
Important
Waste transfer notes only cover non-hazardous waste. If your business produces hazardous materials — batteries, chemical waste, fluorescent lighting, electronic equipment, clinical waste, or oils — a hazardous waste consignment note is required instead. See the dedicated section below, or read our full Hazardous Waste Regulations UK guide.
Waste Transfer Note Requirements: What Must Be Included
Under the Environmental Protection (Duty of Care) Regulations 1991, every waste transfer note must contain sufficient information for the waste to be handled, transported, and disposed of safely. The following fields are legally required:
| Required Information | What This Means in Practice |
|---|---|
| Description of the waste | What the waste is and how it is stored or contained — e.g. “mixed commercial waste in 1,100L wheelie bin” |
| EWC code | The six-digit European Waste Catalogue code classifying the waste type |
| SIC code | The five-digit Standard Industry Classification code of the waste producer |
| Quantity | Estimated weight or volume of the waste being transferred |
| Time and place of transfer | The date, time, and address where the handover takes place |
| Transferor details | Full name and address of the business handing over the waste |
| Transferee details | Full name and address of the carrier or facility receiving the waste |
| Carrier registration details | The carrier’s Environment Agency registration number (in CBDU format) or permit details |
| Signatures | Signed and dated by both the transferor and the transferee |
What Is an EWC Code?
An EWC code (European Waste Catalogue code — also called a LoW code, or List of Wastes code) is a six-digit reference number that classifies the type of waste being transferred. It is a mandatory field on every controlled waste transfer note. Common examples include:
- 20 03 01 — mixed municipal waste
- 15 01 06 — mixed packaging
- 20 01 08 — biodegradable kitchen and canteen waste
- 17 09 04 — mixed construction and demolition waste
Your waste contractor will typically identify the correct code. However, as the waste producer, you carry legal responsibility for ensuring the EWC code is accurate. Incorrectly classified waste may not be handled or disposed of appropriately — and this error remains traceable back to your business.
What Is a SIC Code?
A Standard Industry Classification (SIC) code is a five-digit number that identifies your type of business. It can be found on your Companies House registration documentation and is a required field on a controlled waste transfer note.
How to Complete a Waste Transfer Note
You can use the official Duty of Care Waste Transfer Note template from GOV.UK, or any document — including an invoice or delivery receipt — provided it contains all the required information listed above.
Here is the step-by-step process for completing a waste transfer note:
- Describe the waste clearly — state what it is, how it is stored, and the approximate quantity
- Record the correct EWC code — your carrier can assist, but verify it is accurate
- Include your SIC code — available from your Companies House records
- Fill in transfer details — date, time, and the address where collection takes place
- Check your carrier’s registration — record their CBDU registration number before signing
- Both parties sign — the transferor and transferee must each sign and date the note
- Retain your copy — keep it for a minimum of two years from the date of transfer
In practice, if you use a licensed and reputable waste contractor such as Countrystyle Recycling, the waste transfer documentation will be produced and managed as part of your commercial waste collection agreement. Your contractor should provide copies for your records with each collection or under your annual agreement.
Annual Waste Transfer Notes (Season Tickets)
If you have a regular, recurring waste collection — the same waste type, collected by the same carrier, from the same premises — you do not need to complete a new waste transfer note for every individual collection. You can use an annual waste transfer note, commonly referred to as a season ticket.
A season ticket can cover multiple collections for up to 12 months, provided all of the following remain unchanged throughout the period:
- The waste type (and associated EWC code)
- The carrier collecting the waste
- The premises from which waste is transferred
The Schedule Requirement
A season ticket must always be accompanied by a separate running schedule — a log of every individual collection made under that agreement. The schedule must record:
- The date and time of each transfer
- The quantity of waste collected at each visit
- The location of the transfer (where this varies from what is stated on the season ticket)
Both the season ticket and its schedule must be retained for two years after the final waste transfer covered by the agreement.
If anything changes — you switch carrier, the waste type changes, you move premises, or you begin separating additional streams under Simpler Recycling — a new waste transfer note or updated season ticket is required.
Waste Transfer Notes vs Hazardous Waste Consignment Notes
A standard waste transfer note applies only to non-hazardous controlled waste. For waste classified as hazardous under the Hazardous Waste Regulations 2005, a separate and more demanding document is required: the hazardous waste consignment note.
| Waste Transfer Note | Hazardous Waste Consignment Note | |
|---|---|---|
| Applies to | Non-hazardous controlled waste | Hazardous waste only |
| Record retention period | 2 years | 3 years |
| Pre-notification to Environment Agency | Not required | Required in most cases |
| Parties involved | Transferor and carrier | Consignor, carrier, and consignee (all sections) |
| Complexity | Standard document | Multi-section, multiple copies required |
Common waste types requiring a consignment note rather than a WTN include: batteries, fluorescent tubes, electrical equipment (WEEE), chemical and solvent waste, clinical waste, oils, and any asbestos-containing materials.
For full guidance on hazardous waste documentation, see our Hazardous Waste Regulations UK guide or find out about Countrystyle’s specialist hazardous waste disposal service.
How Long Must Waste Transfer Notes Be Kept?
Record retention requirements depend on the type of waste and your role in the waste chain:
| Organisation | Waste Type | Minimum Retention Period |
|---|---|---|
| All businesses (transferor or carrier) | Non-hazardous controlled waste | 2 years from date of transfer |
| All businesses | Hazardous waste consignment notes | 3 years from date of transfer |
| Landfill site operators | Non-hazardous waste received | 6 years |
| Landfill site operators | Hazardous waste received | Lifetime of the site permit |
Both paper and electronic records are acceptable. Records must be available to produce on request if an Environment Agency officer or local authority enforcement officer asks to inspect them. Many businesses store waste transfer notes alongside supplier invoices for ease of retrieval.
How to Check Your Waste Carrier Is Registered
Before transferring waste to any contractor, you have a legal duty to verify that they are authorised to carry it. Using an unregistered carrier is a breach of your duty of care — regardless of whether you were aware of their status at the time.
Registered waste carriers in England hold a registration from the Environment Agency. Their registration number will start with the letters CBDU, followed by a sequence of numbers. You can check any carrier’s registration status using the Environment Agency’s public waste carrier register.
Authorised parties include:
- Businesses registered as waste carriers, brokers, or dealers with the Environment Agency
- Operators of permitted waste management facilities
- Exempt waste operations that fall within registered exemption categories
- Local authority waste collection services
If a contractor cannot provide a valid registration number, do not use them. Should waste collected by an unregistered carrier be illegally dumped, the business that produced the waste can face enforcement action — even if they played no part in its disposal.
For a full explanation of carrier registration requirements, see our guide to waste carrier licence registration and requirements.
Penalties for Not Having a Waste Transfer Note
Failing to produce, complete, or retain a valid waste transfer note is a criminal offence under Section 34 of the Environmental Protection Act 1990. Penalties can take several forms:
- £300 Fixed Penalty Notice — issued by local councils without the need for a court prosecution
- Unlimited fine on conviction — courts have no upper limit when sentencing for duty of care breaches
- Enforcement notice — the Environment Agency may require documented compliance within a specified period
- Criminal prosecution — persistent or serious breaches can result in prosecution
It is also worth noting that liability is not limited to the waste carrier. If waste is traced back to your business and has been illegally deposited — for example, by a rogue contractor — you may face enforcement action as the original waste producer. Keeping thorough records and verifying carrier credentials are your primary defences.
Waste Transfer Notes and the 2025 Simpler Recycling Rules
From 31 March 2025, businesses in England with 10 or more employees are legally required to separate their waste into distinct streams before collection — including dry mixed recycling, food waste, and residual waste. Micro-businesses (fewer than 10 employees) must comply by 31 March 2027.
This directly affects waste transfer documentation. Where a business previously produced one commingled waste stream covered by a single annual WTN, they may now need documentation that accounts for multiple distinct waste types — each with its own EWC code.
If you have an existing season ticket waste transfer note and have recently changed how your waste is separated, review your documentation with your waste contractor. Retaining WTN records that no longer accurately reflect your actual waste streams creates a compliance gap.
Read our full guide to Simpler Recycling regulations and what businesses must do.
The Future: Mandatory Digital Waste Tracking
The UK government is developing a mandatory digital waste tracking system that will eventually replace paper-based waste transfer notes. The system will require businesses and waste operators to record all waste movements digitally in real time, creating an unbroken digital chain of custody from producer to final disposal or recovery point.
The government’s consultation response confirmed that wherever a waste transfer note is currently legally required, an equivalent digital record on the UK waste tracking service will be required instead. Paper notes will no longer satisfy the legal obligation once the system becomes mandatory.
The rollout timeline has moved since the original consultation, with the government pursuing a phased implementation approach. Businesses should monitor DEFRA and Environment Agency announcements for confirmed go-live dates. In the meantime, building strong record-keeping practices now — complete, accurate, and consistently retained waste transfer notes — will make the eventual transition to digital tracking straightforward.
Frequently Asked Questions
Does a sole trader need a waste transfer note?
Yes. Any business producing or handing over controlled waste must comply with the duty of care, regardless of size. Sole traders, self-employed individuals, and micro-businesses are all subject to waste transfer note requirements for any non-hazardous commercial waste they produce.
Can an invoice serve as a waste transfer note?
Yes, provided it contains all legally required information: a description of the waste, the correct EWC code, SIC code, quantity, time and place of transfer, names and addresses of both parties, the carrier’s registration details, and signatures from both parties. Many licensed waste contractors produce invoices or service receipts that function as compliant waste transfer documentation.
Do I need a waste transfer note for skip hire?
Yes. When you hire a skip from a licensed contractor, the skip hire company should produce and sign a waste transfer note covering the waste in the skip. A reputable skip hire provider will handle this as part of the hire agreement — ask for your copy to keep on file.
What is an EWC code and how do I find the right one?
An EWC (European Waste Catalogue) code is a six-digit classification code for your waste type, retained in UK law post-Brexit. Your waste contractor should identify and record the correct code on your waste transfer note. As the waste producer, you are legally responsible for the accuracy of the code. If you are unsure, ask your contractor to confirm the classification and explain the basis for it.
Do I need separate waste transfer notes for different waste streams?
Each distinct waste type carries its own EWC code, and your documentation must accurately reflect what is being transferred. Businesses now separating food waste, dry recyclables, and residual waste under Simpler Recycling may need documentation that accounts for each stream separately — particularly if each stream is collected at different times or by different carriers.
Can waste transfer notes be stored digitally?
Yes. Electronic records are fully accepted under current regulations. Records must be stored securely and be retrievable promptly on request from an Environment Agency officer or local authority enforcement officer. Until mandatory digital waste tracking is introduced, businesses can use any digital storage format that meets these conditions.
What is the difference between a waste transfer note and a hazardous waste consignment note?
A waste transfer note covers non-hazardous controlled waste and must be retained for two years. A hazardous waste consignment note is required for waste classified as hazardous under the Hazardous Waste Regulations 2005, involves stricter documentation requirements including pre-notification to the Environment Agency, and must be retained for three years. See our full Hazardous Waste Regulations guide for details.
Who is legally responsible for completing the waste transfer note?
Both parties share responsibility for their sections. The transferor (the business handing over the waste) is responsible for an accurate waste description and EWC code. The transferee (the carrier or receiving facility) completes their registration and permit details. Both must sign. In practice, most licensed waste contractors prepare the full document and guide their clients through their obligations as part of the service.