How to write a waste description that satisfies the regulator

The waste description field on a waste transfer note is where most businesses lose marks with the regulator. “General waste” or “mixed rubbish” are the most common entries — and both are inadequate. Here is exactly what to write, and why it matters.

What makes a waste description adequate?

Under section 34 of the Environmental Protection Act 1990, everyone who produces, carries, or receives waste must ensure it is properly described so it can be transferred safely through the waste chain. The Waste Duty of Care Code of Practice is explicit: a description must cover the composition of the waste, its physical form and any hazardous properties. If it doesn't meet that bar, the note may not satisfy your duty of care.

DEFRA's waste data guidance states that a waste description must include the waste's physical characteristics, composition, and whether it is potentially hazardous. All three elements are required.

What must a waste description include?

A fourth element worth including, where relevant, is the process or activity that produced the waste. EWC codes are organised by the industry or process that generated the waste — chapter 17 covers construction and demolition, chapter 13 covers waste oils. Making that link explicit in the description helps the next holder confirm they have the right code and handle the waste appropriately.

What are examples of good and bad waste descriptions?

Notice the pattern in the adequate column: name the materials, state the physical form, and flag whether the waste is hazardous. Where an EWC asterisk code applies, include it in the description so there is no ambiguity between you and the next holder.

How does the waste description relate to the EWC code?

The EWC code tells the regulator which category of waste this is and whether it is hazardous (asterisked codes are hazardous). The description tells them — and the next holder in the chain — what they are actually handling. Regulators expect the two to be consistent: a code for waste mineral oils should not sit alongside a description of “general waste”.

One useful cross-check: EWC chapters are grouped by the industry or process that generated the waste. Chapter 17 is construction and demolition; chapter 20 is municipal and household waste. If your description and your EWC chapter are from different worlds, the code is probably wrong.

What happens if the waste description is too vague?

• →Enforcement action. Environment Agency inspectors routinely check waste transfer notes and can use an inadequate description as evidence of a duty of care breach.
• →Refusal to accept. A carrier or permitted site can lawfully decline to handle waste if the description is insufficient for them to verify that the waste matches what they are licensed to carry or receive.
• →Chain-of-custody gaps. If waste later causes harm or is illegally deposited, a poor description makes it harder to demonstrate you took reasonable steps — the core duty of care test.
• →Digital Waste Tracking rejection. When Digital Waste Tracking becomes mandatory (receivers from October 2026, carriers from October 2027), vague descriptions will be flagged at the point of digital submission — the service validates the waste description field on every record submitted.

How to write a waste description — step by step

• →Name the waste. What are the materials? Be specific — “waste lubricating oil”, not “oily stuff”; “mixed ceramic tiles and concrete”, not “building materials”.
• →State the physical form. Choose one: solid, liquid, sludge, powder, gas, or mixed. This is a required field in Digital Waste Tracking forms — getting into the habit now makes the transition easier.
• →Flag hazard status. If the EWC code ends in an asterisk, say so in the description — e.g. “potentially hazardous — contains mineral oil”.
• →Add the process or origin. A brief note on where it came from — “from vehicle servicing”, “from a kitchen strip-out” — anchors the description to the correct EWC chapter.
• →Cross-check against the EWC code. The description and the code should tell the same story. If they don't, one of them is wrong.

This guide is general information about waste descriptions and duty of care requirements. It is not legal advice. Check your specific obligations against the primary sources below and, where in doubt, consult your environmental regulator.