How long do you need to keep a waste transfer note?

Last updated 14 July 2026

In short

You must keep a waste transfer note for at least 2 years, and a hazardous waste consignment note for at least 3 years, from the date of the waste transfer. Both the business transferring the waste and the one receiving it must keep their copy and produce it if the environmental regulator asks.

Waste transfer notes and hazardous waste consignment notes are your proof that waste was handed over legally. Keep them for too short a time and you breach your duty of care. Here are the exact retention periods, who has to keep them, and when the clock starts.

How long do you need to keep a waste transfer note?

You must keep a waste transfer note for at least 2 years, and a hazardous waste consignment note for at least 3 years, from the date of the waste transfer. Both the business transferring the waste and the business receiving it must keep their own copy.

These are minimums set by the waste duty of care. The person who transfers the waste (the producer or holder) and the person who receives it (the carrier or site) each hold their own copy — it is not enough for just one party to keep it. If the environmental regulator asks, you must be able to produce the record.

2 years or 3 years? The retention periods

Waste record retention — minimum periods
DocumentMinimum retentionWho keeps it
Waste transfer note (non-hazardous waste)2 yearsBoth parties — the business transferring the waste and the business receiving it, each keeps a copy.
Hazardous waste consignment note3 yearsBoth parties — the consignor (producer/holder) and the consignee (receiving site), each keeps a copy.

Non-hazardous waste transfer notes: keep for at least 2 years. Hazardous waste consignment notes: keep for at least 3 years — one year longer.

The extra year on hazardous waste reflects the greater risk and the tighter tracking regime around it. If a single job produces both kinds of waste, apply the longer period to the hazardous paperwork.

When does the clock start?

The retention period runs from the date of the waste transfer shown on the note — not the date you filed it or signed it later.

So a waste transfer note for a load moved on 1 March 2026 must be kept until at least 1 March 2028. A hazardous waste consignment note for the same date must be kept until at least 1 March 2029. If in doubt, keeping records longer than the minimum is never a breach.

Who has to keep them?

The duty falls on both sides of every transfer, and each keeps their own copy:

  • The business transferring the waste — the producer, holder, or the previous carrier passing it on.
  • The business receiving the waste — the carrier taking it, or the permitted site accepting it.
  • Either party must be able to produce the record if the regulator asks — the Environment Agency (England), SEPA (Scotland), Natural Resources Wales (NRW), or NIEA (Northern Ireland).

Can I keep waste transfer notes digitally?

Yes. There is no requirement to keep paper. A complete digital record you can retrieve and show to the regulator satisfies the duty of care.

Digital records are usually the better choice: they don't degrade or go missing in a filing cabinet, they're searchable when an inspector asks for a specific date, and they can be retained for the full 2 or 3 years without physical storage. The record just has to be accurate, complete, and produceable on request.

How Digital Waste Tracking changes this

The government's Digital Waste Tracking (DWT) service moves this paper trail into a single online record. Once you are in scope, logging a movement in the service replaces the paper waste transfer note or hazardous waste consignment note for that movement — and the record is held in the service itself rather than in your own files.

  • Waste receivers (permitted and licensed sites) are in scope from October 2026.
  • Waste carriers are in scope from October 2027.

Until your start date under DWT, the existing rules stand: keep waste transfer notes for at least 2 years and hazardous waste consignment notes for at least 3 years. Businesses already capturing their notes digitally will have the smoothest transition, because the data simply moves to the tracking service.

Frequently asked questions

How long do you have to keep a waste transfer note?
You must keep a waste transfer note for at least 2 years from the date of the waste transfer. Both the person transferring the waste and the person receiving it must keep their own copy.
How long must I keep hazardous waste consignment notes?
You must keep hazardous waste consignment notes for at least 3 years — one year longer than the 2-year rule for ordinary (non-hazardous) waste transfer notes.
When does the retention clock start?
The clock starts on the date of the waste transfer recorded on the note, not the date you filed or signed it. So a waste transfer note for a load moved on 1 March 2026 must be kept until at least 1 March 2028.
Can I keep waste transfer notes digitally?
Yes. There is no requirement to keep paper. A clear, complete digital record that you can retrieve and show to the regulator satisfies the duty of care — and is easier to store, search and produce than a paper file.
Who has to keep the waste transfer note?
Both parties. The business transferring the waste and the business receiving it must each keep their own copy for the required period and be able to produce it if the Environment Agency, SEPA, NRW or NIEA asks.

Related guides

This guide is general information from ComplyWaste, not legal advice. Always check the primary sources for your situation.