Waste transfer notes, consignment notes and your duty of care
When waste moves from one business to another, responsibility for it moves too. The transfer note is the record that shows the handover was done properly. From 1 October 2026 that record starts moving into the government's digital service. The duty behind it does not change.
Everyone in the chain carries it
In 1990 the duty of care replaced the handshake with a paper trail. From October 2026 that paper trail starts giving way to a digital one, under powers in section 58 of the Environment Act 2021.
The duty itself sits in section 34 of the Environmental Protection Act 1990 and applies to anyone who produces, carries, keeps, treats or disposes of controlled waste. In plain terms: store it safely, describe it accurately, hand it only to someone authorised to take it, and keep a record of every transfer.
Each handover, from the business that created the waste to the carrier who moves it and the site that receives it, has to be recorded so the whole journey can be followed back. If a load ends up somewhere it shouldn't, that record is what shows who did their job and who didn't.
Two documents, two kinds of waste
Waste transfer note (WTN), for non-hazardous waste. Its official title is "Duty of Care: Waste Transfer Note". Keep it for at least two years.
Hazardous waste consignment note (HWCN), for anything classed as hazardous: oils, solvents, batteries, asbestos, contaminated soils and so on. Needed every time hazardous waste moves, including between your own premises. The first parts are completed before the waste leaves. Keep it for at least three years.
Both need the six-digit waste code from the List of Waste (often still called the EWC code) and an accurate description. A hazardous note also carries the hazardous properties and, under the digital record, exact component concentrations.
What a compliant transfer note contains
Every field earns its place. Leave one out and the note may not stand up when the regulator asks for it, or the load may be paused at the gate.
| Field | What it needs to say | Where it usually goes wrong |
|---|---|---|
| Description of the waste | Specific enough that the receiving site knows what's on the vehicle and can accept it under its permit. | "Mixed waste", "general", "rubbish". |
| Six-digit waste code | The List of Waste code that matches the description, with the asterisk where the entry is hazardous. | Wrong chapter, a code copied from the last job, a hazardous entry used for non-hazardous material. |
| How it's contained | Loose, in a skip, bagged, drummed, in an IBC, and how many. | Left blank. |
| Quantity | Weight or volume in a measurable unit. Actual if weighed, a stated estimate if not. | Blank, guessed wildly, or unreadable. |
| Transferor and transferee | Legal names and addresses of both parties, and which category each falls into (producer, carrier, broker, site). | Trading names that don't match the Environment Agency's records, old addresses. |
| Registration and permit details | Carrier registration number (CBDU or CBDL), and the receiving site's permit or licence number. | Lapsed registration, number missing or mis-typed. |
| Transferor's SIC code | The Standard Industrial Classification code of the business the waste came from. | Forgotten entirely. |
| Place, date and time | Where and when the transfer happened. | A date that doesn't match the booking or the weighbridge ticket. |
| Signatures | Both parties, with printed names. | One signature, or none, because nobody on site knew who was authorised. |
A season ticket (one note covering repeated transfers of the same waste between the same parties) can cover up to 12 months, provided nothing about the waste or the parties changes.
What changes under digital waste tracking
For a permitted or licensed receiving site in England and Wales, the record of receipt moves into Defra's Digital Waste Tracking Service. For everyone else, the paper duty continues until Defra replaces it in later phases.
For receiving sites
- Every incoming load is recorded digitally within two working days of the movement.
- The carrier is recorded by its existing carrier registration number. There is no new number.
- The paper note that arrived with the load and the weighbridge ticket are recorded alongside, so the digital record can be found by either.
- Hazardous components are recorded with exact concentrations, not "greater than" ranges.
- Defra returns a tracking reference for each movement. Corrections go back as revisions, with the history kept.
For carriers, brokers and producers
- Your own recording duty is planned for a later phase (October 2027 for carriers, brokers and dealers, not yet in statute).
- Until then, keep producing and keeping transfer notes and consignment notes exactly as now.
- From October 2026 the sites you use will need your registration, waste code and description to match what the Environment Agency holds, because they now have to record it. Loads that don't match get paused.
- Scotland and Northern Ireland receiving sites follow from 1 January 2027.
Nothing about the existing expectation has relaxed. You still keep accurate records for the required period and produce them when asked. The digital service changes where the receiving site's record lives, not whether the rest of the chain has to keep theirs.
How the digital record catches the usual mistakes
Most of the errors in the table above are either impossible or obvious in a structured digital record. The code is searched with its official description beside it. The carrier is pulled from the Environment Agency register with its permit status showing, and checked every day so a lapsed registration can't be booked against. The weight is entered as actual or estimate, not left blank. The time is stamped. And the record is in one place, searchable by any reference, rather than in a cab, a drawer and two spreadsheets.
What the digital record can't do is tell you whether the codes and permits you loaded into it were right in the first place. That's the part we do.
Where IWS comes in
If you're not sure which notes you need, what to keep and for how long, or how your current paperwork maps onto the digital record, that's the sort of question we deal with every day. We review where you stand, clean up the codes and registrations, and set you up on our Defra-approved route.
Not sure your paperwork will stand up in October?
Send us your organisation, the site and a telephone number. We'll tell you plainly what's already right and what isn't.
Email us about your site Call 0114 244 2640
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Page last reviewed 5 September 2026.