If you are responsible for commercial waste in the UK or have ever been involved in an ISO 14001 audit, you’ve probably come across Waste Transfer Notes (WTNs).
Whether your organisation is in technology, logistics, construction or manufacturing, getting Waste Transfer Notes right is essential for demonstrating compliance with environmental legislation and maintaining confidence in your waste management arrangements.
In this blog we explain why waste transfer notes are important and what information to look for to ensure you remain legally compliant and ISO 14001 audit ready!
What is a Waste Transfer Note?
A Waste Transfer Note is a legal document required whenever non‑hazardous waste is transferred from one party to another in the UK. It records who produced the waste, who transported it, and who received it, creating an auditable trail that demonstrates compliance with the Duty of Care under the Environmental Protection Act 1990.
Waste Transfer Notes apply to:
- Routine waste collections
- Ad‑hoc waste removals
- Skip hire
- Recycling collections
- Transfers between sites where another organisation takes possession
Both the transferor (the organisation handing over the waste) and the transferee (the organisation receiving it) must keep a copy for at least two years.
What Information Should Be on a Waste Transfer Note?
One of the most common non‑conformities we see during ISO 14001 audits is incomplete or inaccurate Waste Transfer Notes. UK legislation sets out specific minimum requirements.
Key information to check on every Waste Transfer Note
A compliant Waste Transfer Note should include:
- Date and time of transfer
- Place of transfer
- Full name and address of the waste producer (transferor)
- Full name and address of the waste carrier (transferee)
- Waste carrier licence number (or permit / exemption number where applicable)
- Description of the waste, including:
- Type of waste
- How it is contained (e.g. loose, bagged, skip)
- Quantity (weight, volume, or number of containers)
- European Waste Catalogue (EWC) / List of Wastes code
- Standard Industrial Classification (SIC) code of the waste producer
- Confirmation that the waste hierarchy has been applied
- Signatures of both parties (electronic signatures are acceptable)
These requirements are set out in the Waste (England and Wales) Regulations 2011, Regulation 35.
If an annual WTN covers multiple, repeated transfers of the same waste, between the same parties, under the same conditions, for up to 12 months: instead of listing the date and time on the WTN itself, businesses keep a separate schedule that records the details of each individual collection.
What is an EWC Code and Why Does It Matter?
An EWC (European Waste Catalogue) code, also known as a List of Wastes code, classifies the waste by its source and type. Using the wrong code is a common mistake and can invalidate the Waste Transfer Note.
For example:
- Mixed municipal waste: 20 03 01
- Paper and cardboard packaging: 15 01 01
- Electrical equipment: 16 02 14
Accurate coding helps ensure waste is handled, treated or disposed of correctly and is essential evidence during regulatory inspections or ISO 14001 audits.
Search the European Waste Catalogue here:
https://www.sepa.org.uk/media/162682/sepa-waste-thesaurus.pdf
Do You Need a Waste Transfer Note for Every Collection?
Another frequently asked question is whether a new Waste Transfer Note is needed for every waste collection.
In practice, businesses can use:
- Single Waste Transfer Notes for one‑off collections
- Annual or “season ticket” Waste Transfer Notes for regular, consistent waste transfers
An annual Waste Transfer Note can cover multiple collections over up to 12 months, provided:
- The waste type remains the same
- The waste carrier remains the same
- The producer remains the same
A separate schedule must still record the date, time and quantity of each collection.
How Long Should Waste Transfer Notes Be Kept?
Both parties involved in the transfer must retain Waste Transfer Notes for a minimum of two years and be able to produce them to:
- The Environment Agency
- Local authorities
- Certification bodies during audits
Failure to produce records when requested is a breach of legal duty and can lead to enforcement action.
Common Problems Found in Waste Transfer Notes
From an auditor’s perspective, the most common issues include:
- Missing or incorrect EWC codes
- Waste carrier licence numbers not recorded or out of date
- Vague waste descriptions (e.g. “general waste” only)
- Notes not signed by both parties
- Records not retained for the full two‑year period
- Inconsistent use of annual Waste Transfer Notes
These issues often surface during ISO 14001 internal audits or external certification assessments.
The Role of Waste Transfer Notes in ISO 14001
Waste Transfer Notes play a direct role in demonstrating compliance with several clauses of ISO 14001:2015, including:
- Clause 6.1.3 – Compliance obligations
WTNs provide evidence that legal waste requirements have been identified and met. - Clause 8.1 – Operational planning and control
WTNs demonstrate that waste is controlled, transferred to authorised persons, and managed according to defined processes. - Clause 9.1 – Monitoring, measurement, analysis and evaluation
Waste documentation supports monitoring of waste streams and compliance performance.
Certification bodies regularly sample Waste Transfer Notes during audits as tangible evidence of environmental control.
How Is Hazardous Waste Handled?
Unlike non‑hazardous waste, hazardous waste in the UK must be managed under a stricter regulatory framework to ensure it does not harm people or the environment.
Every movement of hazardous waste must be accompanied by a Hazardous Waste Consignment Note (HWCN), which records the waste’s classification, hazardous properties, origin, destination, and the parties involved in the transfer. The consignment note must remain with the waste until it reaches its final authorised disposal or treatment facility, and businesses must retain records for at least three years.
Only licensed waste carriers may transport hazardous waste, and producers must correctly identify and classify the material using the relevant EWC/LoW codes and confirm any applicable hazardous properties (HP1–HP15). Together, these controls ensure that hazardous waste is safely stored, securely transported, and legally treated or disposed of in line with the Hazardous Waste Regulations.
More information on Hazardous / Special Waste: https://www.netregs.org.uk/environmental-topics/waste/using-consignment-notes-for-hazardousspecial-waste/
How Assent Risk Management Can Help
At Assent Risk Management, we regularly support organisations that:
- Are unsure whether their Waste Transfer Notes meet legal requirements
- Need help identifying applicable environmental legislation
- Want to strengthen ISO 14001 operational controls
- Have received audit findings relating to waste documentation
Our ISO 14001 consultancy and auditing services help organisations put robust, proportionate systems in place that stand up to regulatory scrutiny and third‑party certification.
We also provide environmental and sustainability consultancy, internal audits, and training tailored to your sector. If you need help ensuring your compliance with waste regulations, or implementing ISO 14001, contact us today!
