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Waste Transfer Notes — Requirements and Best Practice

Updated May 2026 — Covers the Environmental Protection (Duty of Care) Regulations 1991

A waste transfer note must be completed every time controlled waste is transferred from one person to another. Both the person transferring the waste and the person receiving it must complete the note and retain a copy for two years. For businesses managing multiple waste collections or operating across multiple sites, this documentation obligation is significant in volume but straightforward in principle.

When is a waste transfer note required?

A waste transfer note is required whenever controlled waste is transferred — which covers the vast majority of waste transfers in a commercial or industrial setting. Exceptions:

• Hazardous waste — requires a consignment note instead (more detailed requirements)
• Household waste collected by a local authority — covered by different provisions
• Some specific exemptions relating to very small quantities

What must a waste transfer note contain?

The note must include:

• A description of the waste — type, quantity, and container type
• The SIC code of the process that produced the waste (where applicable)
• The names and addresses of both parties to the transfer
• The place, date, and time of transfer
• The registration number of the carrier (for registered carriers) or the exemption being relied upon
• Signatures of both parties, or one person if the waste is being received at an authorised facility

Season tickets for regular collections

For regular collections of the same type of waste from the same premises, a season ticket can be used instead of a separate note for each collection. A season ticket:

• Covers a period of up to 12 months
• Must describe the waste types covered
• Can cover multiple collections if they are of the same waste type
• Still requires both parties to retain a copy for two years

Season tickets are widely used in commercial waste collection and significantly reduce paperwork for ongoing relationships with the same carrier.

Electronic waste transfer notes

Electronic waste transfer notes (eWTNs) are legally valid and are increasingly used by waste carriers and producers. To be valid, an eWTN must contain all the same information as a paper note. Both parties must be able to access and retain the electronic record for the required two-year period.

Retention and what happens if records are missing

Records must be retained for two years from the date of transfer (three years for hazardous waste). If the Environment Agency investigates a case of illegal dumping and requests transfer note records, an inability to produce them removes the due diligence defence. Even if you did nothing wrong, lack of documentation makes that very hard to demonstrate.