A waste transfer note (WTN) is the documentary record of a waste transaction. Every time controlled waste moves from one party to another in England, Wales, Scotland, or Northern Ireland, a waste transfer note must be completed and signed by both the person transferring the waste and the person receiving it. The note is not a bureaucratic formality; it is the audit trail that demonstrates compliance with the duty of care under Section 34 of the Environmental Protection Act 1990 and, if waste is subsequently mismanaged, the record that establishes who was responsible for it at what point.
Getting waste transfer notes right is not technically complex, but it is consistently done poorly in practice: vague waste descriptions, missing carrier registration numbers, unsigned copies, and failure to retain records are the most common compliance failures. This article covers exactly what a valid waste transfer note must contain, the season ticket option for regular movements, and how to build a straightforward WTN system into your waste management routine.
The Waste (England and Wales) Regulations 2011 specify the information that must appear on a waste transfer note. Missing any of the required elements makes the note non-compliant, even if everything else is in order. The required elements are: a description of the waste (type, quantity, and whether it is loose, in a container, or in a skip), the waste code from the European Waste Catalogue (EWC code), the name and address of both the transferor and the transferee, the address where the waste was taken from, the date of transfer, and confirmation of whether the transferee is an authorised person (their waste carrier registration number or permit reference).
The European Waste Catalogue (EWC) is a hierarchical classification system for waste types. EWC codes are six-digit numbers structured as two digits for the waste category, two for the sub-category, and two for the specific waste type. For example, 15 01 01 is paper and cardboard packaging; 16 01 03 is end-of-life tyres; 20 03 01 is mixed municipal waste. The full EWC list is available from the Environment Agency and is searchable online.
The correct EWC code is the one that most accurately describes the waste at the point of transfer. Using a generic code for a specific waste type that has its own code, such as coding tyres as mixed waste when the tyre code exists, is technically non-compliant and can also affect the permit conditions applicable at the receiving facility. Ask your waste contractor which EWC code they use for your waste type and confirm it matches the waste you are actually transferring.
Businesses separating recyclable waste streams, for example baling cardboard separately from general waste using a Gradeall vertical baler, need a separate waste transfer note for each separated waste stream with the correct EWC code for each material. A mixed waste transfer note cannot cover separated cardboard bales and general residual waste in the same note.
A season ticket waste transfer note covers multiple transfers of the same type of waste between the same two parties over a period of up to 12 months. Instead of completing a new note for every collection, the season ticket WTN is agreed once, signed by both parties, and then applies to all transfers of that described waste type during the covered period. Both parties must retain the season ticket WTN for two years after the period it covers ends.
Season ticket WTNs are appropriate where the waste type, waste description, carrier, and destination are all consistent. If any of these elements change, a new season ticket or a separate individual WTN is needed for the changed element. For example, if a regular cardboard collection switches from one carrier to another, the original season ticket no longer applies to collections by the new carrier, and a new note is required.
For businesses using Gradeall compaction or baling equipment that produces consistent, separated waste streams collected on regular schedules, season ticket WTNs are a practical way to manage documentation without administrative burden for every individual collection. The Gradeall compactor range produces consistent waste volumes in standardised containers that support predictable, regular collection schedules and therefore straightforward season ticket WTN arrangements.
Paper waste transfer notes are still the most common format in practice, but digital WTNs are legally valid provided they contain all the required information, are signed (or have an equivalent digital authentication), and can be produced on request. Several waste management software platforms and contractor-provided apps generate digital WTNs that email copies to both parties at the point of collection. If your waste contractor offers a digital WTN system, confirm it produces records with all the required elements, provides you with a copy for your retention records, and stores those records securely for the two-year period.
“The businesses that manage waste transfer notes most efficiently are the ones that have made it a routine part of the collection process rather than a paperwork task that gets done later,” says Conor Murphy, Director of Gradeall International. “A digital WTN generated at the point of collection is more accurate and more reliably retained than a paper note completed in the yard and filed in a drawer.”
Both parties to the transfer are responsible for the accuracy of the waste transfer note and both must sign it. In practice, the carrier or contractor often prepares the note, but the waste producer is responsible for ensuring that the description of the waste is accurate and that the carrier details on the note match the carrier actually collecting the waste. Signing a WTN without reading it, or allowing a contractor to complete and retain the only copy, puts the producer in a weaker position if the note is subsequently found to be inaccurate or incomplete.
A waste contractor who does not provide a waste transfer note is either unaware of the legal requirement (which raises questions about their competence) or is deliberately avoiding documentation (which raises more serious concerns about the legitimacy of their operation). You should refuse to allow a collection to proceed until a waste transfer note is provided and signed. If a regular contractor persistently fails to provide WTNs, this is grounds for reconsidering the contractor relationship. Using a carrier who cannot or will not provide proper documentation exposes your business to duty of care enforcement action.
No. Waste transfer notes are required for transfers of waste between separate legal entities. Internal movements of waste within a single business, such as moving waste from a production area to an on-site storage facility, do not require a WTN. If a business has separate legal entities operating at the same site, transfers between those entities are transfers between different persons and do require documentation. The test is whether the waste is moving between different legal persons, not whether it is moving between different physical locations.
A single waste transfer note can cover multiple waste types collected in the same vehicle on the same occasion, provided each waste type is separately described with its own EWC code, quantity, and container type. In practice, a mixed collection where different waste types are clearly separated, for example separately tied bales of cardboard and bags of general waste in the same vehicle, can be covered by a single WTN with separate line entries for each stream. Where waste types are mixed together before collection, they should be described as mixed waste with the appropriate mixed waste EWC code.
Failure to produce waste transfer notes when requested by the Environment Agency, SEPA, or NIEA is an offence under the duty of care regulations. The enforcing authority can issue a fixed penalty notice for failure to produce records, or can initiate prosecution for a more serious duty of care breach if the failure to produce records suggests waste has been transferred without documentation. Maintaining a systematic filing system for WTNs, whether paper or digital, for the full two-year retention period is the straightforward preventive measure.
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