Digital waste transfer notes for scrap metal dealers

Scrap metal yards sit in an awkward spot: you carry waste, you receive waste, and you handle streams that quietly cross into hazardous. On top of the environmental rules you also need a licence from your council that has nothing to do with your carrier registration. Here is how waste transfer notes, EWC codes and the coming digital tracking rules actually apply to a scrap dealer — and where they trip people up.

Do scrap metal dealers need waste transfer notes?

It doesn't matter that the metal has value to you; in law it's still waste being transferred, and each transfer needs a compliant note describing the material, its EWC code and both parties. The practical catch for a yard is volume and variety: skips of mixed metal, a van of copper, a flat-bed of ferrous, and the odd end-of-life vehicle can all land on the same morning, each needing the right paperwork.

What EWC codes do scrap metal streams use?

Getting the code right matters because it decides whether an ordinary transfer note or a hazardous consignment note is required. The table below covers the streams a typical yard sees most.

An asterisk on an EWC code (for example 16 01 04*, 16 06 01*) means the waste is hazardous. Hazardous loads need a consignment note kept for at least 3 years; ordinary transfer notes are kept for at least 2 years.

Which scrap streams are hazardous?

The trap is that hazard depends on contamination, not just the metal. Clean copper cable is 17 04 11 and non-hazardous; the same cable carrying hazardous oil crosses into a hazardous code. An end-of-life vehicle is hazardous until it's depolluted — its fuel, oils, coolant and battery removed — after which it becomes 16 01 06. Treating those as ordinary transfers is one of the most common compliance gaps in the trade.

Do I need a scrap metal dealer licence as well as a waste carrier registration?

This is the point scrap businesses most often get wrong. People assume that being a registered waste carrier means they're “licensed for scrap” — they aren't. The two sit under different laws and different bodies:

• →Waste carrier registration — from the environmental regulator (the Environment Agency, NRW, SEPA or NIEA). Required to transport controlled waste, including metal you collect or move.
• →Scrap metal dealer licence — from your local council under the Scrap Metal Dealers Act 2013. Either a site licence (to run a yard) or a collector's licence. This is about buying and selling scrap, cashless payment rules and verifying who you deal with.

On top of these, receiving and storing waste at a yard normally needs an environmental permit or exemption. This page is general information, not legal advice — check your exact permissions with the relevant regulator and council.

Is a scrap yard a carrier or a receiver under Digital Waste Tracking?

Most scrap operations do two things at once: a driver collects metal (carrier) and the yard takes loads in over the weighbridge (receiver). Under Digital Waste Tracking each side has its own duty and its own start date, and the receiver date comes first — so the yard's Receipt of Waste is the part to get ready earliest.

Weighbridge capture

Scrap is priced by weight, so the weighbridge ticket is already the heart of every transaction. Tying that weight, the material and its EWC code to the transfer or receipt record at the moment of weigh-in means one capture serves both the commercial job and the compliance record — instead of a paper ticket and a separate note that never quite match.

How does digital software help a scrap business?

Digital waste transfer note software is built for exactly the mix a yard deals with — high volume, many EWC codes, hazardous edge cases, and both carrier and receiver duties at once:

Right EWC code, hazardous flagged

Predictive search across the full European Waste Catalogue puts the correct code on every load and flags the asterisked hazardous ones — so oily cable or an un-depolluted end-of-life vehicle is treated as a consignment, not waved through on an ordinary note.

Receipt of Waste at the yard

When a load lands, the yard records a Receipt of Waste against the incoming material — the receiver-side record that Digital Waste Tracking wants from October 2026. It's captured as the metal comes in, not reconstructed later.

Weighbridge and audit trail

Weights attach to the record, and every note — transfer or consignment — is retained for its legal period (2 years, or 3 for hazardous) and searchable by customer, date, code or vehicle. That's the clean audit trail an inspection or a stock reconciliation needs.

How does ComplyWaste fit in?

ComplyWaste is our digital waste transfer note app. For a scrap business it captures the right EWC code with hazardous streams flagged, records a Receipt of Waste when loads arrive at the yard, ties in weighbridge weights, and keeps a searchable archive covering both your carrier and receiver duties — built to be ready for Digital Waste Tracking.

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.