Digital waste transfer notes for construction and demolition
Last updated 14 July 2026
In short
Every transfer of construction and demolition (C&D) waste needs a waste transfer note describing the waste, its EWC code and both parties, kept for at least 2 years — 3 years and a hazardous waste consignment note for asterisked codes like asbestos 17 06 05*. Anyone carrying their own C&D waste must hold upper-tier waste carrier registration, a common trap. Digital WTN software captures a compliant note on a muddy site, offline, with predictive EWC codes and on-glass signatures.
Construction and demolition sites generate more waste than any other sector — concrete, brick, soil, timber, metal, plasterboard, and sometimes hazardous streams like asbestos. Every load that leaves site needs a compliant transfer note, and the person moving it usually needs a waste carrier registration too. Here is what C&D duty of care actually requires, the EWC codes you'll meet, the traps that catch builders, and how digital notes make it workable in the mud.
Do I need a waste transfer note for construction waste?
Construction and demolition (C&D) waste sits squarely under the waste duty of care. Whether it's a skip of mixed rubble, a wagon of muck away or a load of stripped-out timber, the transfer must be documented so anyone in the chain can prove the waste went to an authorised destination. A missing or vague note is the single most common finding in a duty of care audit — “builders' waste” on a docket with no EWC code doesn't cut it.
What EWC codes does construction and demolition waste use?
C&D waste mostly falls under Chapter 17 of the European Waste Catalogue. These are the streams you'll meet on almost every site. Codes ending in an asterisk (*) are hazardous and need a consignment note rather than an ordinary transfer note.
| Waste stream | EWC code | Hazardous? |
|---|---|---|
| Concrete | 17 01 01 | No |
| Bricks | 17 01 02 | No |
| Mixed C&D waste | 17 09 04 | No |
| Soil and stones | 17 05 04 | No |
| Wood / timber | 17 02 01 | No |
| Metals (mixed) | 17 04 07 | No |
| Insulation (non-hazardous) | 17 06 04 | No |
| Plasterboard / gypsum | 17 08 02 | No |
| Asbestos | 17 06 05* | Yes — consignment note |
| Contaminated soil | 17 05 03* | Yes — consignment note |
| Tars / coal tar | 17 03 01* | Yes — consignment note |
Some streams have both hazardous and non-hazardous entries depending on contamination — insulation is a good example, where asbestos-containing insulation is hazardous. When in doubt, treat it as hazardous until assessed, and pick the code by the material rather than guessing from memory.
Keep waste transfer notes for at least 2 years and hazardous waste consignment notes for at least 3 years. An EWC code ending in an asterisk (*) is hazardous and needs a consignment note, not an ordinary transfer note.
Do builders need to register as a waste carrier?
Many trades assume that because it's “their own” waste they don't need to register, or that lower-tier will do. For construction and demolition waste specifically, carrying it — even from your own site to the tip — requires upper-tier registration. It's a quick online registration with the regulator (the Environment Agency, SEPA, Natural Resources Wales or NIEA depending on where you work), but operating without it is an offence and turns up fast when a load is stopped or a note is checked.
Why is capturing notes on a construction site so hard?
The paperwork isn't complicated — the environment is. C&D sites are the worst possible place to fill in an accurate note by hand:
- Multiple trades, one site. Groundworkers, demolition, strip-out and fit-out crews all generate different waste streams that need different codes on the same job.
- Muddy, wet conditions. A carbon duplicate book in a site cabin or a wet cab gets illegible, torn or lost long before the two-year retention period is up.
- Poor or no signal. Basements, deep plots and rural sites kill mobile data, so any tool that needs a live connection fails exactly where the load is leaving.
- 842 EWC codes to choose from. Nobody memorises the catalogue; on paper people write “rubble” and leave the code blank, which is the gap an auditor finds.
How does digital WTN software help on construction sites?
Offline-first capture
The note completes fully on the device — waste description, EWC code, quantity, signature, GPS and photos — and syncs when signal returns. A load leaving a basement or a rural plot is never held up or lost because there's no bar of signal.
Predictive EWC search across all 842 codes
Type “concrete”, “plasterboard” or “asbestos” and get the right code — with hazardous entries clearly flagged — so nobody guesses or leaves it blank, and hazardous streams are routed to a consignment note.
On-glass signatures, GPS and photos
Both parties sign on the screen, the note is stamped with location and time, and the operative can attach a photo of the load or the skip. That's the proof a wet carbon copy can never give you.
Per-site pre-fill for multiple trades
Set a site up once — address, producer details, common streams — and every trade on that job captures notes without re-typing the same fields. The office sees loads land in real time instead of waiting for a book to come back.
DWT-ready
Because each note is already a structured digital record, you're positioned for Digital Waste Tracking without a rebuild — you change the destination, not the way the site works.
How does ComplyWaste fit in?
ComplyWaste is our digital waste transfer note app, built around the operative on-site rather than the back office. It's offline-first, has predictive EWC search across all 842 codes, on-glass signatures with GPS, per-site pre-fill for multi-trade jobs, auto-emailed branded PDFs, a searchable archive (2 years for transfer notes, 3 for hazardous consignment notes) and an office dashboard — and it's built to be DWT-ready.
| Plan | Price | For |
|---|---|---|
| Solo | £39 / month | A sole trader or single vehicle |
| Crew | £99 / month | A small demolition or groundworks team |
| Fleet | £199 / month | A larger contractor and busy office |
Every plan starts with a 14-day free trial and no card required. Pricing is published up front rather than hidden behind a demo call.
Frequently asked questions
- Do I need a waste transfer note for construction waste?
- Yes. Every time construction or demolition waste changes hands you need a waste transfer note describing the waste, its EWC code, quantity and both parties, signed by each. Keep it for at least 2 years. Hazardous waste — such as asbestos, contaminated soil or coal tar — needs a hazardous waste consignment note instead, kept for at least 3 years.
- Do builders need to register as a waste carrier?
- Yes. If you carry, transport or move construction or demolition waste — including your own waste from your own jobs — you must register as an upper-tier waste carrier with the environmental regulator. This catches most builders, groundworkers and demolition contractors, because moving your own C&D waste is upper-tier, not lower-tier. Registering is straightforward, but working without it is an offence.
- Which construction waste needs a consignment note instead of a transfer note?
- Hazardous C&D waste needs a hazardous waste consignment note, not an ordinary transfer note. On site this typically means asbestos (17 06 05*), contaminated soil (17 05 03*) and tars or coal tar (17 03 01*) — any EWC code ending in an asterisk. Consignment notes must be kept for at least 3 years.
- How do I capture a waste transfer note on a muddy site with no signal?
- Use offline-first digital WTN software. ComplyWaste captures the whole note — waste description, EWC code, quantity, on-glass signatures, GPS and photos — on the device and syncs when signal returns, so a note is never lost because you were in a basement or a rural plot. It works across multiple trades on the same site and pre-fills per-site details.
- How much does ComplyWaste cost?
- Plans are Solo at £39/month, Crew at £99/month and Fleet at £199/month, with a 14-day free trial and no card required to start. Pricing is published rather than demo-gated.
Related guides
This guide is general information from ComplyWaste, not legal advice. Always check the primary sources for your situation.