Waste transfer notes: what your business needs to keep

Your duty of care

Section 34 of the Environmental Protection Act 1990 places a duty of care on anyone who produces, keeps, carries or disposes of controlled waste. For a business, that includes the waste from your office, shop, kitchen or fit-out.

In practice, the duty of care means you must:

• store waste safely and securely so it can’t escape or be blown about
• describe your waste accurately to whoever takes it
• hand it only to someone authorised to take it, such as a registered waste carrier
• complete and keep the paperwork for every transfer
• take reasonable steps to stop it being handled illegally further down the line

The duty doesn’t end when the van drives away. If your waste is later fly-tipped and you can’t show that you took reasonable care, you can be held responsible.

What a waste transfer note must contain

A waste transfer note is the written record of waste moving from one person to another. It can be on paper or electronic. It should include:

The waste

• a written description of the waste, including any treatment it has had
• the European Waste Catalogue (EWC) code, also called the List of Waste code, such as 20 03 01 for mixed municipal waste
• the quantity, for example the number of bags or the size of the bin
• how it is contained: loose, in bags, in a wheeled bin or in a skip

The people

• the names and addresses of both the person handing over the waste and the person receiving it
• your Standard Industrial Classification (SIC) code, which describes your business activity
• the carrier’s waste carrier registration number
• a note of which category the transferor falls into, such as producer or holder

The transfer

• the place, date and time of the transfer
• the signatures of both parties
• a declaration that you have applied the waste hierarchy, meaning you considered prevention, reuse and recycling before disposal

A good contractor fills most of this in for you. Your job is to check the description matches what actually went, and that the carrier details are correct.

Season tickets for regular collections

If the same carrier collects the same type of waste from you regularly, you don’t need a new note for every lift. A single “season ticket” transfer note can cover repeat collections of the same waste for up to 12 months. A weekly general waste collection, for example, can be covered by one annual note.

A season ticket only covers what it describes. If you add a new stream, such as food waste or glass, or the waste changes significantly, you need a new or amended note. One-off jobs like an office clearance or a fit-out strip-out need their own transfer notes.

How long to keep them

• Waste transfer notes: at least two years from the date of transfer.
• Hazardous waste consignment notes: at least three years.

Hazardous waste, such as fluorescent tubes, some electricals, chemicals or asbestos, uses a consignment note rather than a standard WTN. If you’re unsure whether something is hazardous, ask before it’s collected.

Keep notes somewhere you can find them quickly. The Environment Agency or the City of London Corporation can ask to see them, and producing them promptly is the easiest way to show you meet your duty of care. A shared folder with one sub-folder per year and per contractor works well.

The government also plans to introduce mandatory digital waste tracking, which will change how some of this information is recorded. Check GOV.UK for the current timetable.

How to check a waste carrier

Anyone who carries waste as part of their business in England must be registered with the Environment Agency. Before you book anyone, especially a new or unusually cheap contractor:

1. Ask for their carrier registration number. Upper tier numbers usually start with CBDU.
2. Check it on the public register. Search the Environment Agency’s public register of waste carriers, brokers and dealers on GOV.UK. Make sure the name and number match the business you’re dealing with and that the registration is current.
3. Ask where the waste is going. A legitimate contractor can tell you which permitted site it will be taken to.
4. Get the WTN before or at the collection. Not weeks later, and never “we don’t do paperwork”.

The risks of using an unregistered carrier

Cash-in-hand operators who turn up with a van and no paperwork are a common route for fly-tipping. If your waste ends up dumped and it can be traced back to you, you can be prosecuted for failing in your duty of care, even though you didn’t dump it yourself.

• Breaches of the duty of care can lead to an unlimited fine on conviction.
• Councils and the Environment Agency can also issue fixed penalty notices for some duty of care failures, such as not producing transfer notes when asked.
• You may have to pay for the clean-up, and the reputational damage can be worse than the fine.

Waste dumped in a City alley or a neighbouring borough is easily traced from business names on packaging, letterheads and delivery labels. Checking the register takes a couple of minutes.

How we handle the paperwork

We provide a waste transfer note with every job: a season ticket for scheduled commercial waste collections, and a separate note for each one-off clearance or wait-and-load collection. If you run separated recycling and food waste, each stream is described properly so the paperwork also supports your Simpler Recycling compliance.

This guide is a summary for England as of October 2026, not legal advice. Check GOV.UK for the current duty of care code of practice.