Waste Transfer Notes Explained

For haulage businesses operating in the waste sector, understanding and complying with regulatory requirements is critical for compliance. One essential document that plays a pivotal role in the waste transportation and disposal processes is the Waste Transfer Note (WTN).  

 In this article, we will delve into what waste transfer notes are, why they are needed, the legal obligations surrounding them, and how digitalisation can simplify compliance for haulage businesses. 

What is a Waste Transfer Note? 

A Waste Transfer Note (WTN) or a duty of care certificate is a legal document that details the transfer of waste from one party to another. It’s vital in maintaining the duty of care that businesses and individuals have on the environment. This document serves as a record of the waste type, quantity, and the entities involved in its transfer. Essentially, it tracks the journey of waste from its generation to its final disposal, ensuring transparency and accountability in the entire waste management process. 

What are the different types of Waste Transfer Notes? 

Non-hazardous waste falls under the purview of a standard duty of care waste transfer note, which includes comprehensive information about the waste producer and recipient, along with specific details regarding the nature and quantity of the waste.  

If any portion or the entirety of the waste is deemed hazardous, it is required to complete a hazardous waste consignment note. This document is essential for ensuring the safe and appropriate handling, management, and disposal of the hazardous waste. In a general sense, hazardous waste encompasses any waste that poses a threat to humans or the environment. 

Various examples of hazardous waste requiring a consignment note include batteries, asbestos, solvents, paints, brake fluids, fridges, pesticides, and oils. The proper disposal of such waste requires professional handling. 

What is a waste consignment note? 

A waste consignment note is a piece of documentation that needs completing every time hazardous waste is moved, regardless of a transfer in ownership. In comparison, a waste transfer note is completed when waste changes hands. Non-hazardous waste doesn’t require the completion of a waste consignment note. 

Hazardous waste consignment notes are part of a system of audit information that shows how a company stores, manages, and moves the hazardous waste in its possession. Companies owning hazardous waste are legally required to show how they are managing it appropriately – a waste consignment note is part of this process. 

Waste Transfer Note requirements 

The level of detail required on a Waste Transfer Note may vary by type of waste being transported, but generally, the following information is commonly included: 

• Details of the parties involved 
• Date and time of transfer 
• Description of the waste including waste codes and quantities 
• Packaging and containers 
• Waste destination 
• Declaration of accuracy 
• Special handling instructions 
• Legal compliance information 
• Environmental permits 
• Emergency contact information 

How much does a Waste Transfer Note cost? 

There’s no charge for completing a Waste Transfer Note (WTN). WTNs can be completed by your waste carrier for free, by simply using a generic waste transfer note template – see the next section. 

Waste Transfer Note template 

Creating a Waste Transfer Note (WTN) is a critical step in documenting the transfer of waste between different parties. While the exact format may vary depending on local regulations and the specific type of waste, a basic WTN template including essential information for compliance can be accessed at the government’s website.  

Who needs a Waste Transfer Note? 

It’s important to note that the specific regulations governing the use of Waste Transfer Notes can vary by region, and the requirements may depend on factors such as the type and quantity of waste being handled. Additionally, there are often distinctions between different categories of waste, with stricter regulations applying to hazardous or special waste. 

1. Waste producers: Any business, organisation, or individual that produces waste is often required to complete a Waste Transfer Note. 
2. Waste carriers: Businesses or individuals responsible for transporting waste from the point of origin to its final disposal or treatment facility. 
3. Waste disposal or treatment facilities: Facilities that receive and process waste for disposal or treatment.
4. Intermediaries or brokers: In some cases, entities that act as intermediaries or brokers in the waste management chain may also be required to use Waste Transfer Notes. 

Why are Waste Transfer Notes needed?  

Waste Transfer Notes play a crucial role in maintaining a transparent and accountable waste disposal process. Here are some key reasons why they are necessary: 

1. Legal Compliance: Proper documentation helps businesses adhere to waste management regulations, avoiding penalties and legal consequences.
2. Traceability: Waste Transfer Notes provide a detailed record of the waste’s journey, enabling authorities to trace its origin and monitor its disposal. 
3. Communication: Waste Transfer Notes facilitate communication between waste producers, carriers, and disposal facilities. This ensures that all parties involved are aware of the type and quantity of waste being transferred, promoting responsible waste management practices. 

Waste Transfer Note season tickets 

Filling out a waste transfer note every time your waste is collected can be tedious. So, for recurring transfers, you can utilise an annual waste transfer note, otherwise known as a season ticket, to avoid the hassle. 

A season ticket is a single WTN that covers multiple transfers over a 12-month period. You can only use a season ticket if all of the following stay the same: 

• The parties involved in the transfer (waste producer and the waste carrier/waste management company) 
• The description of the waste 
• The place where the waste is being transferred to 

 If any of these three details change, you’ll need a new waste transfer note. 

How long do you keep Waste Transfer Notes for?  

The recommended period for retaining Waste Transfer Notes is two years but can differ for hazardous waste. This period allows for audits, inspections, and the resolution of any potential disputes related to waste management activities. Failure to retain records for the required duration may lead to compliance issues. 

The importance of digitising Waste Transfer Notes 

Up until recently, businesses have been making the switch from traditional paper-based systems to digital solutions to improve the admin processes of transporting waste. However, upcoming legislation from DEFRA, due to take effect in 2025 will require hauliers to digitise their WTN in order to create consistent and compliant practices in the industry. Digitalising Waste Transfer Notes can offer several advantages for haulage businesses:

1. Efficiency: Digital records can be easily accessed, updated, and shared, reducing administrative burden and streamlining the waste management process. 
2. Accuracy: Digital systems can minimise errors associated with manual data entry, ensuring that information is recorded accurately. 
3. Compliance monitoring: Digital platforms can provide real-time compliance monitoring, alerting businesses to potential issues and helping them stay ahead of regulatory changes. 
4. Environmental impact: Going digital reduces the need for paper, contributing to environmental sustainability by decreasing the overall carbon footprint of waste management processes. 

Further read: The Waste Transport Management System Brochure