Do I need a waste transfer note?
Last updated 14 July 2026
In short
Yes. If your business produces, carries or receives non-hazardous waste and it changes hands, a waste transfer note (WTN) is legally required under the duty of care (s.34 Environmental Protection Act 1990). Both parties must keep it for at least 2 years. Hazardous waste uses a consignment note instead, kept for 3 years.
A waste transfer note (WTN) is the paperwork that proves non-hazardous waste changed hands legally. Almost every business that produces, carries or receives waste needs one — here is exactly when it applies, when it does not, and what it must contain.
Do I need a waste transfer note?
The duty of care applies to anyone who imports, produces, carries, keeps, treats, disposes of, or acts as a broker for waste. Whenever waste passes from one party to another — for example when a builder hands rubble to a skip-hire firm — a waste transfer note must be completed and signed by both sides. Hazardous waste is the exception: it uses a consignment note instead (see below).
Who needs a waste transfer note?
| Situation | WTN needed? |
|---|---|
| A business hands its non-hazardous waste to a carrier or skip firm | Yes |
| A waste carrier collects and passes waste to a receiving site | Yes |
| A permitted site receives non-hazardous waste from a carrier | Yes |
| A householder puts out their own domestic waste for collection | No — but must use a registered carrier |
| Hazardous waste is transferred | No — a consignment note is used instead |
When do you not need a waste transfer note?
A waste transfer note is only triggered when waste is transferred between parties. You generally do not need one when:
- You are a household disposing of your own domestic waste — though you must still check your carrier is registered.
- Waste stays within the same premises or business and does not change legal hands.
- The waste is hazardous — that movement needs a hazardous waste consignment note instead.
What must a waste transfer note contain?
| Item | Detail |
|---|---|
| Description of the waste | A clear description of the waste being transferred. |
| EWC code | The European Waste Catalogue (EWC) / List of Wastes code for the waste. |
| Quantity | How much waste — weight, volume, or number of containers. |
| How it is contained | The type of container: skip, sack, drum, loose, etc. |
| Transferor & transferee details | Names, business addresses, and (for the carrier) their registration details. |
| SIC code | The Standard Industrial Classification code of the business transferring the waste. |
| Place & date of transfer | Where and when the waste changed hands. |
| Signatures | Signed by both the person transferring and the person receiving the waste. |
| Waste hierarchy declaration | A confirmation that the waste hierarchy (reduce, reuse, recycle) has been applied. |
Both parties must keep the waste transfer note for at least 2 years. A hazardous waste consignment note must be kept for at least 3 years.
Do I need a new note for every collection?
A season ticket only works where the same type of waste moves between the same two parties on a routine basis — for example a weekly trade waste collection. If the waste type, parties, or carrier change, you need a fresh note.
How does Digital Waste Tracking change this?
Paper waste transfer notes are being replaced by Digital Waste Tracking (DWT), a mandatory government service for recording waste movements electronically. It becomes mandatory for waste receivers from October 2026 and for waste carriers from October 2027. Once you are in scope, a record in the service replaces the paper waste transfer note for that movement — but until your start date, the duty-of-care rules above still apply in full.
Frequently asked questions
- Does a householder need a waste transfer note?
- No. A household disposing of its own waste does not need a waste transfer note. But you still have a household duty of care: you must check that whoever takes your waste is a registered waste carrier, or you can be fined if it is fly-tipped.
- What happens if I don't have a waste transfer note?
- Failing to complete or keep a waste transfer note is a breach of the section 34 duty of care and a criminal offence. It can lead to an unlimited fine, and the missing paperwork makes it far harder to show you disposed of waste responsibly if it is later dumped.
- Do I need a waste transfer note for hazardous waste?
- No — hazardous waste uses a hazardous waste consignment note instead of a waste transfer note. Consignment notes must be kept for at least 3 years, compared with 2 years for a waste transfer note.
- Do I need a new waste transfer note for every collection?
- Not for regular, identical collections. You can use one 'season ticket' or annual waste transfer note to cover repeat transfers of the same type of waste between the same parties for up to 12 months, rather than completing one each time.
- Will Digital Waste Tracking replace waste transfer notes?
- Yes, once you are in scope. Digital Waste Tracking becomes mandatory for waste receivers from October 2026 and for waste carriers from October 2027, and a record in the service then replaces the paper waste transfer note for that movement.
Related guides
This guide is general information from ComplyWaste, not legal advice. Always check the primary sources for your situation.