What must be on a waste transfer note

When non-hazardous waste changes hands, the transfer has to be documented. The waste duty of care code of practice describes three ways of doing it: the free national electronic system, a paper transfer note, or alternative documentation such as an invoice, provided it contains all the required information.

That last point is worth dwelling on. An invoice can be a lawful transfer record, but only if it carries everything the code requires. Most invoices do not, which is why a separate note remains the straightforward route.

The code of practice requires the description of the waste to be accurate and to contain everything you are reasonably in a position to provide for the lawful and safe handling of it by later holders. It then lists what that includes: the classification of the waste using the appropriate List of Wastes code; the quantity and nature of the waste, and whether it is loose or in a container; the type of container if it is in one; the time and place of the transfer; the SIC code of the transferor; the names and addresses of both the transferor and the transferee, with their signatures, which may be electronic provided an enforcement officer can view them; and the capacity in which each party acts, together with the authorisation they hold in that capacity — a permit number or a registration number.

That last item is the one that makes a note checkable after the event. A note carrying the carrier's registration number can be verified against the public register long after the van has gone. A note without it records only that somebody collected something.

The description must also confirm that you have applied the waste hierarchy, as required by regulation 12 of the Waste (England and Wales) Regulations 2011.

End-of-life tyres are 16 01 03 in the List of Wastes, the classification still widely called the EWC code. Shredded or granulated end-of-life tyres are 19 12 04. Those are the codes the Environment Agency's own tyre exemption guidance uses, and they are what belongs in the classification field of a note covering a tyre collection.

Getting the code right is not administrative fussiness. The classification determines which controls apply to the movement, and the code of practice treats misclassification of waste as an example of the sort of failure the duty of care is meant to prevent.

A garage with a weekly collection does not need a fresh note each time. The code of practice provides for a season ticket: a single transfer note covering a series of non-hazardous waste transfers, lasting up to one year, for regular transfers of the same type of waste with the same carrier. Where one carrier services several of your sites with the same waste types, those sites can be listed in a schedule to the ticket.

The code adds a practical condition that is easy to overlook: you should keep a record of the collection times and the quantities of waste. A season ticket with no collection record behind it describes an arrangement rather than any particular transfer.

The code of practice requires a copy of the waste description to be kept, electronically or on paper, for two years for non-hazardous waste and two years for season tickets. Hazardous waste consignment notes are kept for three years, and different periods apply to those receiving hazardous waste.

Two years is the floor, not a target. Keeping notes alongside the date you checked each carrier's registration gives a record of having taken reasonable measures rather than a record of having filed some paper.

This page describes what the statutory code of practice and the classification guidance say. It is not legal advice, it does not cover hazardous waste in any detail, and it cannot account for the particulars of any individual arrangement. Where the answer matters, the code of practice itself is short, free and linked below.