Waste transfer note vs hazardous waste consignment note: which do you need?
Last updated 15 July 2026
In short
Use a waste transfer note (WTN) for non-hazardous waste and a hazardous waste consignment note for hazardous waste — identified by an asterisk (*) in the EWC code. Both satisfy the duty of care under s.34 Environmental Protection Act 1990, but consignment notes involve three parties, require a unique reference code per movement, and must be kept for at least 3 years rather than 2.
The type of waste decides the document. If the waste is hazardous — shown by an asterisk (*) in its EWC code — you need a hazardous waste consignment note. If it is non-hazardous, you need a waste transfer note. Both satisfy the duty of care under s.34 of the Environmental Protection Act 1990, but they have different parties, different reference requirements, and different retention periods. Here is the complete decision guide.
What is the difference between a waste transfer note and a consignment note?
Both documents exist to satisfy the statutory duty of care under s.34 of the Environmental Protection Act 1990 — anyone who produces, carries, keeps or disposes of controlled waste must ensure it is handled lawfully and does not escape. The WTN and the consignment note are the paper (or digital) evidence that those obligations were met at each handover.
| Waste transfer note | Hazardous waste consignment note | |
|---|---|---|
| Waste type | Non-hazardous (EWC code without an asterisk) | Hazardous (EWC code with an asterisk *) |
| Parties | Two — transferor and transferee | Three — producer/holder, carrier and consignee |
| Unique reference code | Not required | Required — consignment note code (PREFIX/ABCDE) |
| Minimum retention | 2 years | 3 years |
| Legal basis | Environmental Protection Act 1990 s.34 & Duty of Care Regulations 1991 | Hazardous Waste Regulations 2005 (England & Wales) |
| Annual ‘season ticket’ | Allowed — one note can cover repeat collections for the same waste type within a year | Not available — one note per individual movement |
Which document do I need?
The European Waste Catalogue contains 842 codes, of which 408 are marked hazardous with an asterisk. The asterisk is the definitive test — it is not about the physical appearance or everyday name of the waste, but the official classification of that specific waste stream. If you are unsure of the correct EWC code, classify the waste before arranging its removal.
How do I know if my waste is hazardous?
Common hazardous wastes requiring a consignment note include waste oils and solvents, asbestos, batteries, fluorescent tubes and electrical equipment containing hazardous substances, clinical waste, and many paints, adhesives and coatings. If you are uncertain, seek a formal waste classification — hazardous waste regulations place the obligation to classify correctly on the producer.
Who completes each document?
The stages for a hazardous waste consignment note are:
- Parts A & B (Producer/holder): the producer describes the waste, its EWC code(s), hazard properties, quantity and the premises it is leaving from, and generates the unique consignment note code.
- Part C (Carrier): the carrier completes their collection and transport details after collecting the waste and before delivering it.
- Part D (Consignor confirmation): the consignor signs to confirm the producer and carrier details are correct.
- Part E (Consignee): the receiving site records whether the load has been accepted or rejected and notes the treatment or disposal route.
The carrier and the consignee each keep their own copies. The consignee must also record each movement in a site register kept for at least 3 years.
How long must each document be kept?
Waste transfer notes: minimum 2 years. Hazardous waste consignment notes: minimum 3 years — all parties (producer, carrier and consignee) must keep their copy, and the consignee must also keep a register of received consignments for at least 3 years.
These are legal minimums. Keeping records for longer is good practice and costs little extra. If a regulator investigates a historical movement, the retained note is the primary evidence that your duty of care was met.
Does it work the same across the UK?
In Scotland, special waste is regulated by SEPA under the Special Waste Regulations 1996 (as amended). In Northern Ireland, the NIEA administers the equivalent regime. The underlying principle is the same — hazardous or special waste travels with a tracked note kept for years — but the terminology, the exact forms and some thresholds differ by nation. If you operate across borders, check the requirements separately for each nation.
How does Digital Waste Tracking change this?
Digital Waste Tracking captures the same information as the relevant note — waste description, EWC codes, quantity, carrier and disposal or recovery code — but files it electronically in a single national system. Until your mandatory start date, keep issuing the correct document: transfer notes for non-hazardous waste (kept 2 years) and consignment notes for hazardous waste (kept 3 years).
This guide is general information about waste transfer notes and hazardous waste consignment notes and is not legal advice. Rules differ by UK nation and change over time — always confirm your specific obligations with the environmental regulator for the nation you operate in, or with a qualified environmental adviser.
Frequently asked questions
- When do I need a consignment note instead of a waste transfer note?
- You need a hazardous waste consignment note whenever you move hazardous waste. Hazardous waste is any waste with an EWC code marked with an asterisk (*). For all non-hazardous waste, a waste transfer note is the correct document.
- How do I know if my waste is hazardous?
- Check the European Waste Catalogue (EWC) code for your waste. If the six-digit code is marked with an asterisk (*) — for example 13 02 05* for non-chlorinated mineral-based engine oil or 20 01 21* for fluorescent tubes — the waste is hazardous and must travel with a consignment note, not a transfer note.
- How long do I keep a waste transfer note vs a consignment note?
- You must keep a waste transfer note for at least 2 years and a hazardous waste consignment note for at least 3 years. Consignees must also keep a register of hazardous waste consignments received for at least 3 years.
- Who has to sign a hazardous waste consignment note?
- A consignment note is completed in stages: the producer or holder describes the waste and generates the consignment note code (Parts A and B); the carrier completes their transport section (Part C) on collection; the consignor confirms the details (Part D); and the consignee records acceptance or rejection (Part E) on arrival.
- Can one waste transfer note cover multiple collections?
- Yes — a single annual waste transfer note can cover multiple scheduled collections between the same two parties for the same type of waste within one year, often called a 'season ticket'. Each hazardous waste consignment note, by contrast, must cover one individual movement.
Related guides
This guide is general information from ComplyWaste, not legal advice. Always check the primary sources for your situation.