Waste Transfer Notes and Waste Duty of Care Explained
When waste leaves your business, your responsibility doesn’t leave with it.
A waste transfer note records what is being handed over, who is taking it and when responsibility for the waste changes hands. For businesses producing or handling non-hazardous waste, keeping that information is an important part of meeting your waste duty of care.
Here, we explain what a waste transfer note is, when you need one, how to complete it and how long the records should be kept.
What Is a Waste Transfer Note?
A waste transfer note, or WTN, is a document recording the transfer of non-hazardous waste from one person or business to another.
For each load of non-hazardous business waste transferred, there must be a waste transfer note or another document containing the same required information, such as an appropriate invoice. Both parties must complete the relevant information and keep a copy.
What Information Does a Waste Transfer Note Record?
A waste transfer note should provide enough information for the person receiving the waste to understand what it is and handle it safely.
That includes details such as:
- A clear description of the waste
- The quantity being transferred
- The relevant waste classification or EWC/LoW code
- Details of the person or business transferring the waste
- Details of the waste carrier or receiving business
- The date and location of the transfer
- Relevant authorisation or registration details
- The appropriate SIC code for the business producing the waste
Why Waste Transfer Notes Matter for Duty of Care
Your waste duty of care applies if you produce, carry, keep, treat, dispose of or otherwise control waste.
In practical terms, that means making sure waste is stored safely, described accurately and only passed to someone authorised to receive it. The transfer note creates a record of that handover and helps demonstrate what happened to the waste once it left your control.
For businesses using regular commercial waste collections, having a clear system for these records can make ongoing compliance much easier.
Waste Transfer Notes vs Annual Season Tickets
You do not necessarily need a completely new WTN every time the same waste is collected.
A season ticket, sometimes called an annual waste transfer note, can cover repeated transfers of the same type of non-hazardous waste for up to 12 months, provided the waste holder, carrier and type of waste remain the same.
You must also keep a schedule showing each individual transfer, including its date, time, quantity and location where required.
When Is a Waste Transfer Note Legally Required?
If your business transfers non-hazardous waste to another person, you generally need a waste transfer note or another document containing the required information. That applies whether the waste is being collected by a contractor or moved to another authorised waste facility.
When Businesses Need a Waste Transfer Note
You need appropriate documentation when responsibility for controlled non-hazardous waste passes from your business to another party. That record matters whether you run an office, restaurant, retail unit, construction site, warehouse or multi-site operation.
Do You Need a Waste Transfer Note for Every Collection?
For one-off or changing transfers, a separate WTN may be required. For regular collections where the parties and waste stream remain the same, an annual season ticket can usually cover multiple collections instead.
If the waste type, carrier or other relevant details change, however, the existing season ticket may no longer cover the transfer and a new document will be needed.
When an Annual Waste Transfer Note Can Be Used
Season tickets work particularly well for predictable commercial waste services. For example, if the same contractor collects the same general waste stream from the same business throughout the year, one annual document plus an accurate collection schedule can reduce paperwork without reducing traceability.
How to Complete a Waste Transfer Note
The easiest way to approach a WTN is to remember its purpose: someone looking at the document should be able to identify the waste, where it came from, who handled it and what happened at the point of transfer.
Waste Description, Quantity and EWC Codes
Avoid descriptions that are too vague to be useful. Rather than simply writing “rubbish” or “mixed waste”, describe the waste accurately enough for the receiving business to understand what it contains. You will also need the appropriate waste classification code, often known as an EWC, LoW or List of Waste code.
Business, Carrier and Transfer Details
Record the details of the businesses involved and where and when the transfer took place. You should also check that the person taking your waste is properly authorised. Waste carriers, brokers and dealers that require registration can be checked through the relevant public register.
SIC Codes and the Waste Hierarchy Declaration
The SIC code identifies the type of business activity that produced the waste. Businesses must also take reasonable steps to apply the waste hierarchy, prioritising prevention, re-use and recycling before lower-order options such as disposal.
Good segregation and appropriate business recycling can therefore support more than the paperwork itself: they help determine what happens to the waste afterwards.
Signing and Completing the Waste Transfer Note
Both the business transferring the waste and the business receiving it must complete the relevant sections and sign the document. Do not treat the signature as a formality. Check that the description, waste code, carrier information and other key details actually match the waste being handed over.
What Does a Waste Transfer Note Look Like?
There is no requirement for every WTN to use one identical visual template. What matters is that the document contains the necessary information. An invoice or other record can therefore perform the same role if it captures all the required details.
The Key Sections of a Waste Transfer Note
Expect to see sections covering:
- The waste itself
- Quantity and classification
- Transferor and transferee details
- Waste carrier information
- Date and place of transfer
- Required declarations and signatures
Paper vs Electronic Waste Transfer Notes
Waste transfer notes can be kept electronically as well as on paper. Electronic transfer notes are permitted provided the record can be produced in a visible and legible form when required. That can make digital filing much easier for facilities or compliance teams managing several sites.
What to Check Before Signing a Waste Transfer Note
Before signing, ask three simple questions:
- Does the waste description accurately match what is being collected?
- Are the carrier and business details correct?
- Is anything missing that would make the transfer difficult to trace later?
Five minutes spent checking the document now can save considerably more time during an audit.
How Long Should Waste Transfer Notes Be Kept?
Businesses must keep waste transfer notes for at least two years. That applies to both the business handing over the waste and the business receiving it. Records can be stored electronically or on paper and must be available if requested by an authorised officer.
The Two-Year Retention Requirement
If you are wondering how long to keep waste transfer notes, two years is the standard for non-hazardous waste documentation. A tidy digital filing system can make this considerably easier than trying to locate individual paper documents several years after a collection.
How Long to Keep Annual Waste Transfer Notes and Schedules
Season tickets and their accompanying schedules should also be kept for two years after the last transfer covered by the ticket. Keep the documents together so the overall agreement can easily be matched to individual collections.
Storing Waste Transfer Notes for Audits and Inspections
Your records should be easy to retrieve, not simply technically “somewhere on file”. The Environment Agency or local authority may ask to see waste documentation. Failure to supply required records can result in enforcement action.
Hazardous Waste Consignment Note Retention
Hazardous waste follows a different documentation system. Instead of a standard WTN, hazardous waste movements normally require a hazardous waste consignment note completed before the waste moves.
Waste Transfer Notes vs Hazardous Waste Consignment Notes
A waste transfer note is used for non-hazardous controlled waste. A consignment note is used for hazardous waste and contains additional information relating to its classification, movement and handling.
Westminster Waste provides specialist hazardous waste collection for waste streams that require this additional level of control.
How Long Should You Keep a Hazardous Waste Consignment Note?
For a business that produces or holds hazardous waste in England, hazardous waste records generally need to be kept for three years at the premises where the waste was produced or stored. That is one year longer than the standard two-year requirement for non-hazardous waste transfer notes.
How Retention Requirements Can Vary by Your Role
Not every organisation in the hazardous waste chain has the same retention period. For example, hazardous waste carriers generally keep their register for one year, while producers and holders generally retain records for three years. Different requirements also apply to permitted sites receiving hazardous waste.
Always check the requirement that applies to your role rather than assuming the same rule applies across the whole chain.
How Waste Duty of Care Applies to Businesses
Duty of care is not a separate certificate that makes your waste compliant. It is an ongoing legal responsibility to manage waste properly throughout the time it is under your control.
Your Responsibilities as a Waste Producer or Holder
Businesses should take reasonable steps to:
- Prevent waste from escaping
- Describe it accurately
- Store and segregate it appropriately
- Transfer it only to authorised organisations
- Keep the required records
- Apply the waste hierarchy where appropriate
Checking Waste Carriers and Authorised Waste Sites
Do not assume a waste contractor is authorised simply because they collect waste professionally. Waste carrier registrations can be checked, and waste should only be taken to appropriately authorised sites.
Is There a Waste Duty of Care Licence?
There is no single “waste duty of care licence” that covers your responsibilities. This is sometimes confused with waste carrier registration. Upper-tier carrier registrations must generally be renewed every three years, while lower-tier registrations do not require renewal.
How Waste Duty of Care Is Monitored and Enforced
Waste duty of care is not simply self-policing. The Environment Agency and local authorities can request documentation and investigate how waste has been handled. Businesses that cannot produce required records or that transfer waste improperly can face enforcement action.
Digital Waste Tracking and Business Waste Records
Waste reporting is also becoming increasingly digital. As of 1 October 2026, permitted waste receiving sites in England and Wales must begin reporting waste receipts through the government’s digital waste tracking service. Existing waste transfer notes and hazardous waste consignment notes will initially continue alongside the new system.
For facilities and compliance teams, the direction of travel is clear: good waste records need to be accurate, accessible and increasingly digital.
Waste Transfer Note FAQs
Can one waste transfer note cover regular waste collections?
Yes. A season ticket can cover repeated transfers of the same non-hazardous waste for up to one year, provided the relevant parties and waste type remain unchanged. You must also keep a schedule recording each transfer.
Can waste transfer notes be completed and stored electronically?
Yes. Electronic waste transfer notes are permitted, provided the required information can be produced in a visible and legible form. Records must generally be kept for at least two years.
Is a waste transfer note the same as a hazardous waste consignment note?
No. Waste transfer notes cover non-hazardous waste transfers. Hazardous waste movements normally require a hazardous waste consignment note instead.
What happens if I cannot produce a waste transfer note when requested?
An authorised Environment Agency or local authority officer can request waste documentation. Failure to provide records you are legally required to keep can lead to enforcement action, including a fixed penalty notice in relevant circumstances.
