What is a waste transfer note? Definition and legal requirements
Last updated 15 July 2026
In short
A waste transfer note (WTN) is a document that records the transfer of non-hazardous waste from one party to another. It is required under the section 34 duty of care in the Environmental Protection Act 1990, must describe the waste and both parties, be signed by both, and be kept for at least two years.
A waste transfer note is the document that proves waste changed hands legally. Every time non-hazardous waste passes from one business to another, the law expects a record of what it was, who moved it and where it went. Here is exactly what a WTN is, what it must contain, who needs one, and how it differs from a hazardous waste consignment note.
What is a waste transfer note?
The duty of care means anyone who produces, carries, keeps, treats or disposes of waste has a legal responsibility to make sure it is handled safely and only passed to someone authorised to take it. The waste transfer note is the paper (or digital) evidence that this handover happened properly — a shared record both sides keep so the movement of the waste can be traced.
What must a waste transfer note legally contain?
Each field exists so the waste can be identified and traced. These are the details every waste transfer note must carry:
| Field | What it records |
|---|---|
| Parties & addresses | The names and addresses of both the person transferring the waste and the person receiving it. |
| Waste description | A written description of the waste, enough to identify it and how it should be handled. |
| EWC code(s) | The six-digit European Waste Catalogue code(s) classifying the waste. |
| Quantity | How much waste is being transferred, typically by weight or volume. |
| Container type | How the waste is contained or moved — skip, bags, drums, bulk tipper, and similar. |
| SIC code | The Standard Industrial Classification code of the business producing the waste. |
| Date & place of transfer | When and where the waste changed hands. |
| Carrier registration | The waste carrier registration details of whoever transports the waste. |
| Signatures | Signatures of both parties — the one handing the waste over and the one receiving it. |
Who needs a waste transfer note and when?
You need a WTN whenever controlled waste is handed over between two parties in the course of business — for example a builder passing rubble to a skip-hire firm, or a shop handing trade waste to a collection company. The note is completed at the point of transfer and both sides retain it. A single "season ticket" style note can cover repeated transfers of the same waste between the same parties over a fixed period, rather than one note per collection.
Is a digital waste transfer note legal?
Digital WTNs are increasingly the norm, and DEFRA's Digital Waste Tracking service is being phased in to make electronic records the standard. Receivers of waste come into scope from October 2026 (January 2027 in Scotland) and carriers from October 2027. Until October 2027, a properly completed paper waste transfer note still satisfies the carrier's duty of care.
A waste transfer note must be kept for a minimum of two years. A hazardous waste consignment note must be kept for a minimum of three years.
How is a waste transfer note different from a consignment note?
They are two versions of the same duty-of-care record:
- Waste transfer note — for non-hazardous (ordinary controlled) waste. Kept for at least two years.
- Hazardous waste consignment note — for hazardous waste. Captures extra information about the waste and its hazards, and must be kept for at least three years.
This guide is general information about the duty of care and waste transfer notes, not legal advice. Check your obligations against the primary sources below and, if in doubt, your environmental regulator.
Frequently asked questions
- What is a waste transfer note?
- A waste transfer note (WTN) is a document that records the transfer of non-hazardous waste from one party to another. It exists to satisfy the section 34 duty of care under the Environmental Protection Act 1990, describing the waste, the parties involved and the transfer, and it must be signed by both the person handing over the waste and the person receiving it.
- What must a waste transfer note legally contain?
- A waste transfer note must contain the names and addresses of both parties, a description of the waste, its EWC (European Waste Catalogue) code, the quantity and container type, the SIC code of the business producing the waste, the date and place of transfer, the carrier's registration details, and the signatures of both parties.
- Is a digital waste transfer note legal?
- Yes. A waste transfer note can be completed and stored electronically as well as on paper. There is no legal requirement for a WTN to be a paper document, provided it contains all the required information and both parties can produce it when asked. DEFRA's Digital Waste Tracking service is making digital records the standard as it is phased in.
- How is a waste transfer note different from a consignment note?
- A waste transfer note covers non-hazardous waste, while a hazardous waste consignment note covers hazardous waste and captures extra detail. The two documents serve the same duty-of-care purpose for different waste types, and they must be kept for different periods: a waste transfer note for at least two years and a hazardous waste consignment note for at least three years.
- How long must you keep a waste transfer note?
- A waste transfer note must be kept for at least two years. A hazardous waste consignment note must be kept for at least three years. Both the party transferring the waste and the party receiving it must keep their copy for the relevant period and be able to produce it if a regulator asks.
Related guides
This guide is general information from ComplyWaste, not legal advice. Always check the primary sources for your situation.