Do you need help understanding what waste transfer notes are and how to complete them?
Jurisdiction: England
Commencement: 1st April 2024
Amends: The Packaging Waste (Data Reporting) (England) Regulations 2023
Various duties apply.
The responsibility for reporting packaging waste has been updated for following types of packaging waste:
Definitions have also updated for “Producers” and “UK owners” to provide clarification on the division of responsibilities between the following entities:
The Legislation Update Service is the best way to stay up to date automatically with legislation in England, Wales, Scotland, Northern Ireland and the Republic of Ireland.
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During the webinar, we gathered your questions and have answered them below. If you’d like to know more about our Consultancy Service or the Legislation Update Service, please contact us.
An Energy Savings Opportunity Scheme (ESOS) survey is a mandatory energy assessment for large companies / undertakings*. It’s important to note that smaller organisations may also be required to carry out an ESOS assessment if they are part of a corporate group.
*A large company or undertaking means an organisation which either:
If an organisation qualifies, they must carry out ESOS assessments every 4 years. An ESOS assessment requires participants to do 3 things:
More details on ESOS are available in this guidance.
Plastic packaging components will not be chargeable for the Plastic Packaging Tax if it is for use in the ‘immediate packaging’ of a human medicinal product. In relation to a medicinal product, the definition in the Human Medicines Regulation (2012) is “the container or other form of packaging directly in contact with the medicinal product”. In those Regulations, medicinal product is defined as:
As a result, common packaging types such as rigid plastic bottles, sachets, tubes, stick packs and thermo-moulded strip pouches (unit-dose blister packaging) will not be liable for the UK Plastic Packaging Tax, unlike outer or secondary packaging layers. Medical devices therefore, are not captured under this definition and are not subject to the exemption as are not used for the immediate packaging of licensed human medicine.
However, it is worth noting that some specific medical devices are excluded from the tax (rather than exempt), but only if the plastic packaging forms an integral part of the goods.
A packaging component is an integral part of the goods where both the:
An example of this would be an inhaler.
Therefore, plastic packaging components which are an integral part of the goods are not subject to the Plastic Packaging Tax and you do not need to account for them on your tax return.
Plastic packaging components which are an integral part of the goods, are not subject to Plastic Packaging Tax and you do not need to account for them on your tax return.
A packaging component is an integral part of the goods where both the:
An example of this would be inhalers.
Therefore, plastic packaging components which are an integral part of the goods are not subject to the Plastic Packaging Tax and you do not need to account for them on your tax return.
If the plastic packaging components used within medical devices do not form an integral part of the goods, then they would be subject to the tax.
The 10 tonnes of packaging referred to during the legal webinar is in relation to the new Plastic Packaging Tax. This is a new tax with obligations on anyone that imports into the UK, or manufactures, 10 or more tonnes of plastic packaging. More information on this can be found here and government guidance is available here.
I think that the 50 tonnes of packaging you are referring to is in reference to different requirements set out under the Producer Responsibility Obligations (Packaging Waste) Regulations 2007. A business or organisation has duties under these Regulations if it:
Business that meet this criteria are obligated as a packaging producer and must register as such with the relevant environmental regulator.
Handling of packaging includes both filling of packaging and the import of packaging, therefore when considering if a company has handled over 50 tonnes of packaging it should include the weight of packaging from imports. A business that is part of a group must add up the total amount of packaging handled and the annual turnovers of all parts of the group to see if they are an obligated packaging producer. Obligated packaging producers will be given an annual recycling target that relates to the type and weight of packaging that they use / produce. This target is known as their ‘obligation’. A recycling obligation will be assigned for each material handled. The amount each business has to recycle is determined by three factors:
Further guidance on producer responsibilities can be found here.
From 1st January 2023 the extended producer responsibility requirements have reduced the threshold for packaging producers to 25 tonnes. There are different obligations for those that handle between 25-50 tonnes of packaging to those that handle over 50 tonnes, with the initial obligation being that from 1st January 2023 they must keep a record of the amount of packaging handled. There is a tool available to help determine if this change will apply to businesses, available via the following link: https://www.gov.uk/guidance/check-if-you-need-to-report-packaging-data.
Any red diesel that was placed into the tank of a vehicle or machine before 1st April 2022 can still be used until it’s empty. However, any red diesel in a storage tank cannot be held and must be removed. The tank you mention would be classed as a storage tank and therefore should not be used.
If you qualify for ESOS and your organisation is fully covered by ISO 50001, you do not need to carry out an ESOS assessment. You just need to notify the Environment Agency that you’re compliant with ESOS. Further guidance is available here.
Plastic Packaging Tax is due on plastic packaging components when they’re ‘finished’. A component is finished when it has undergone its last substantial modification. A substantial modification is the last manufacturing process which changes the nature of the packaging component. Labelling packaging is given as an example of a change that is not classed as a substantial modification as seen here.
Note that there are some draft regulations which were consulted on in the summer 2021. I would expect these to explain substantial modification further when they come into force: The Plastic Packaging Tax (General [Substantial Modification]) Regulations 2021. More information can be found here.
The EU Withdrawal Act 2018 maintains established environmental principles and ensures that existing EU environmental law will continue to have effect in UK law, including the Industrial Emissions Directive (IED) and Best Available Techniques (BAT) Conclusion Implementing Decision made under it.
The UK government has introduced secondary legislation under the EU Withdrawal Act 2018, and further legislation in the devolved administrations where required, to ensure the domestic legislation that implements the IED (including the Transitional National Plan) can continue to operate. This amends current legislation to:
The IED aims to protect both human and environmental health by reducing harmful industrial emissions across the European Union – primarily through the optimum application of BAT.
The UK Government is establishing a new regulatory framework to boost industrial emissions standards and reduce air pollution following Brexit.
This will be through the UK’s new Best Available Techniques (BAT) framework.
Any new industrial emissions legislation is likely to come from the Environment Act 2021; Legislation Update Service will inform subscribers if this is the case.
Online-only retailers are not required to operate return points under The Deposit and Return Scheme for Scotland Regulations 2020.
However, online-only retailers have an obligation to:
The requirements for this takeback scheme are currently under review.
SEPA has also published a regulatory position statement which can be found here. This position statement indicates that enforcement action will not be taken against online retailers who do not offer a takeback service due to ongoing uncertainty regarding the scheme’s requirements. This position statement may be withdrawn at any time by SEPA.
More information on obligations for online retailers can be found here.
Currently, only the draft Regulations (The Environmental Protection (Plastic Plates etc. and Polystyrene Containers etc.) (England) Regulations 2023) have been published and no associated guidance has been issued. As a result, it is not yet clear if single-use plastic plates, cutlery, balloon sticks, expanded and extruded polystyrene food and drinks containers already purchased will be permitted to be used after October 2023. It is anticipated that there may be a period within which you can continue to supply or sell leftover supplies, as was the case with single-use plastic straws, cotton buds and drink stirrers, but this has not yet been confirmed.
It is worth noting that in the government’s Consultation outcome: Summary of responses and government response, it states that “businesses should prepare for the ban to apply in full, from October 2023. The Government’s intention is to bring the bans into force on 1 October, subject to Parliamentary approval”.
Legislation Update Service will inform subscribers when the Regulations and any associated guidance is published.
Currently only the draft Regulations (The Environmental Protection (Plastic Plates etc. and Polystyrene Containers etc.) (England) Regulations 2023) have been published and no associated guidance has been issued.
In the government’s Consultation outcome: Summary of responses and government response, it states that the ban on the supply of single-use plastic plates, trays, and bowls will not apply to plates, trays, and bowls that are used as packaging, in shelf-ready pre-packaged food items as defined in regulation 3 of the Packaging (Essential Requirements) Regulations 2015 (such as bowls and platters in ready prepared meals). This is to avoid duplication or confusion with proposals for an extended producer responsibility scheme (EPR) for packaging.
It is our understanding therefore, that packaged airline meals will not be captured under these Regulations, but this cannot be confirmed until the Regulations and associated guidance have been published. Legislation Update Service will inform subscribers when these are published.
The technical requirements that must be met to use UKCA marking will depend on the product. The guidance document on designated standards provides a list of standards that may be used to provide ‘presumption of conformity’.
The guidance document on conformity assessment provides information on which products can be self-declared and which products must be third-party assessed.
Authorisations granted by the European Chemicals Agency (‘ECHA’) prior to 31st December 2020 were automatically transferred to the Health and Safety Executive (HSE) under UK REACH. These authorisations will continue to apply under UK REACH until the existing authorisation made under EU REACH expires, unless otherwise notified.
Organisations may have requirements to provide information to the HSE as per the transitional agreements. More information on reporting requirements can be found here.
It is no longer a requirement for businesses or schools to assess and manage the risks from Coronavirus (COVID-19) as per this withdrawn guidance.
If a downstream user becomes aware of a newly classified substance of very high concern (SVHC), they need to meet the requirements under this guidance from the HSE. In short, if you supply an article containing a substance that appears on the UK REACH Candidate List in a certain concentration, you must inform the consumers. Also, if you produce, import or supply articles containing SVHCs, you must notify the HSE.
While there are some specific exclusions, in general such equipment does require marking. The manufacturer’s instructions would normally contain information on conformity assessment, it the product is exempt and why. We advise that if you are unsure whether a particular item is exempt that you seek specialist advice.
Diisocyanates training needs to be conducted by “an expert on occupational safety and health with competence acquired by relevant vocational training” as per the training instructions in the Annex to Regulation (EU) 2020/1149. Therefore, you can do it yourself as long as you meet those requirements.
During the webinar, we gathered your questions and have answered them below. If you’d like to know more about our Consultancy Service or the Legislation Update Service, please contact us.
UK REACH doesn’t cover exports to the EU, it only covers domestic manufacture, use and importation to the UK. In terms of considering PFAS chemicals as part of manufacturing for export to the EU there are 2 things to consider:
A full list of the requirements and process can be found on the Government website: Extended producer responsibility for packaging: who is affected and what to do.
Guidance on what data you need to collect and how to report it can be found on the Government website here.
If you are a subscriber to LUS then you can access the entry in your register for England, Scotland, Wales, and Northern Ireland.
We recently collaborated with Valpak to produce a webinar on Extended Producer Responsibility which you may also find useful. The webinar can be found here.
The Extended Producer Responsibility applies to anyone who does one or more of the following.
A producer can be:
If your company places a product in packaging, regardless of whether the packaging was imported then you might have obligations under the Regulations.
You can check the packaging activities that are covered here.
Thresholds for producer responsibilities can be found here.
According to the current guidance, “your total weight is the amount of packaging in a calendar year (January to December) that you supplied through the UK market and/or imported, emptied and then discarded in the UK.”
Considering the above, it seems fair to assume that “packaging that is exported out of the UK on finished product” does not fall in any of the above categories and, as such, should not be counted towards the total weight.
The Government Guidance states that you only need to register for the Plastic Packaging Tax if you exceed the specified threshold (10 tonnes).
If your total amount is below the threshold, then you don`t need to register for the Plastic Packaging Tax 2022.
While the T4 exemption will continue to apply (under a changed name and conditions), the S1 and S2 will be prohibited from being registered at a site where there is a direct link to any other waste exemption.
As such, your interpretation is correct. To continue all current activities, the site will need to apply for and obtain a waste permit before the end of the 6 month transition period.
Under The Packaging Waste (Data Reporting) (England) Regulations 2023, organisations that are part of a registered compliance scheme* are exempt from the data reporting requirements. This means that the compliance scheme has taken on your obligation to report the data and it is their responsibility to submit the data on time.
*The list of registered compliance schemes can be found here.
Household packaging
Household packaging is primary* or shipment packaging** supplied to:
*Primary packaging is the packaging used to contain a product e.g. a crisp packet.
**Shipment packaging is packaging used to ship a product directly to the consumer e.g. cardboard boxes and bubble wrap.
Non-household packaging
Non-household packaging is:
*Secondary packaging is packaging used to group items together for sale or shipping purposes e.g. a cardboard tray.
**Tertiary packaging is packaging used to protect packaging during transport e.g. pallets.
Retaining evidence
Organisations must retain evidence to demonstrate that packaging is non-household packaging. N.B. If you cannot provide evidence then you must classify the packaging as household packaging.
Organisations must retain evidence for packaging that, due to its nature, can only be used by an organisation. This evidence must be kept for at least 7 years.
Evidence can include:
Further information on household and non-household packaging can be found here.
Online-only retailers are not required to operate return points under The Deposit and Return Scheme for Scotland Regulations 2020.
However, online-only retailers have an obligation to:
The requirements for this takeback scheme are currently under review.
SEPA has also published a regulatory position statement which can be found here. This position statement indicates that enforcement action will not be taken against online retailers who do not offer a takeback service due to ongoing uncertainty regarding the scheme’s requirements. This position statement may be withdrawn at any time by SEPA.
More information on obligations for online retailers can be found here.
Extended producer responsibility applies to organisations that:
The Packaging Waste (Data Reporting) (England) Regulations 2023 applies to organisations that:
You may need to collect and report packaging data if you supply packaged goods that are labelled with your own branding. This includes your name, your trademark or any other distinguishing mark. An example of this can be found here.
We advise clarifying with NISA / The Co-op as it will depend on your situation and whether the packaging is branded.
Further information on this can be found here.
We recently collaborated with Valpak to produce a webinar on Extended Producer Responsibility which you may find useful. The webinar can be found here.
Do you need help understanding what hazardous waste consignment notes are and how to complete them?
Listen to one of our short and simple webinars on hazardous waste consignment notes, where Kerry Hammick, one of our experienced consultants will talk you through:
There are three webinars available, covering the legal requirements for England and Wales, Northern Ireland and Scotland.
Each webinar is accompanied with definitions of any technical terms and a comprehensive FAQ to answer all your waste transfer notes questions.
The webinars can be found by choosing your jurisdiction from the below list.
As you may already be aware, 100% of profits generated by The Compliance People are directly gift-aided to our parent charity, Newground Together.
This month we’re thrilled to announce the launch of our Newgrounds’ brand new Employment and Skills Support Hub in Calderdale!
Through an individual approach, the hub is a place designed to support people in finding sustainable employment. In order to support individuals on their employment journey, the hub also offers a range of training opportunities and confidence booster sessions.
The Hub aims to welcome in anyone who would like support individuals with their knowledge and connections to aid their journey into the workplace.
Stephanie Webster, our Community Programmes Coordinator at Newground Together said:
“We understand stepping into the working world can be a challenging time which is why we’re thrilled to be able to expand our job club support in Pellon.
The job club is here to empower people to reach their employment goals and equip them with the right tools to go the whole way. There are no criteria to come along, so we want people to get in touch with our team to find out how to take the next step into employment or training.”
The Hub at Pellon will be open every Monday from 1pm to 3pm and will be based at The Addy, 53-55 Rye Lane, Halifax HX2 0QB.
For more information, contact the team on [email protected] or visit the webpage here https://www.newgroundtogether.co.uk/calderdale/.
Changes are coming to waste exemptions in England & Wales.
If you currently operate a waste activity under an exemption, you’ll need to understand how these changes will affect you, and importantly – how to prepare.
In short, some operators will need to get an environmental permit, change their activities, or stop them completely.
Consultant Rayan Stanislaus from The Compliance People gives you a summary of what to expect.
Currently, the Waste Exemption Regime allows some low-risk activities to be carried out on a registration system and be exempt from the requirement to hold an environmental permit. This Regime is set out within The Environmental Permitting (England and Wales) Regulations 2016 (EPR).
What are the changes?
The general changes to the Waste Exemption Regime are as follows.
*Direct link means where an exempted waste activity:
Waste exemptions to be removed
The following waste exemptions will be removed, and operators will need to carry out activities under an environmental permit or stop the activities completely. The transition period for these changes is 3 months.
Changes to specific waste exemption conditions
Specific waste exemptions will have their conditions changed. There will be a transitional period for each of these waste exemptions after the EPR changes come into effect, giving operators time to adjust. Within these periods, you must make changes to your activities to ensure compliance, apply for the appropriate permit, or stop the waste activity.
Detailed information on all the changes is published in Defra’s supplementary Government response and annexes.
The tables below give a summary of the changes to specific waste exemptions and transition periods (it may worthwhile saving it, as it will come in handy later).
| Exemptions | Condition changes | Transition period |
| U1 – Use of waste in construction |
|
12 months |
| T4 – Preparatory treatments, such as, baling, sorting, shredding |
|
6 months |
| T6 – Treating waste woods and waste plant matter by chipping, shredding, cutting, or pulverising |
|
6 months |
| T12 – Manually treating waste |
|
6 months |
| D7 – Burning waste in the open |
|
6 months |
|
|
|
12 months
|
It is best to review your registered waste exemption(s) against the Government’s guidance. You can find details of your current waste exemption(s) on the Government’s public register. The Environment Act 2021 gives regulators powers to amend certain exemption conditions without amending legislation, so we can expect future changes to the Waste Exemption Regime.
In the meantime, we will keep you updated on everything you need to know about the changes to waste exemptions. If you’re struggling to wrap your head around these changes, our consultants are happy to support you to ensure your organisation remains compliant with all environmental permitting requirements.
No obligation demo to help you understand how it works and how your business can use it
Do you need help understanding what waste transfer notes are and how to complete them?
Listen to one of our short and simple 20-minute webinar on waste transfer notes in Northern Ireland.
Kerry Hammick, one of our experienced consultants, will talk you through
Waste: Anything which you decide to, or are required to, throw away.
Hazardous waste: Waste is generally considered hazardous if it (or the material or substances it contains) are harmful to humans or the environment. Examples of hazardous waste include:
Waste transfer note: A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-hazardous waste to another party. The format of a WTN must conform to the requirements laid out in Part 9 of The Waste (England and Wales) Regulations 2011.
Consignment note: A consignment note, or hazardous waste consignment note (HWCN) is a legally required document that details the transfer of hazardous waste from one party to another. The note must be prepared before any hazardous waste is moved and is required for all movements of hazardous waste. The format of a HWCN must meet the requirements set out in Schedule 1 of The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.
Producer: Any person whose activities produce waste.
Holder: The waste producer or the legal person in possession of the waste.
Carrier: A person who collects or carries waste. A carrier must be registered with the Environment Agency in England or Natural Resources Wales in Wales.
Dealer: Any person that buys waste with the aim of subsequently selling it (including where they don’t take physical possession of the waste).
Broker: Any person that arranges waste transportation and / or the management of waste on behalf of another party, e.g. local authorities contracting out waste services to another firm.
Transferor: The current holder of the waste.
Transferee: The person receiving the waste.
Consignee: A person who receives hazardous waste to recover or dispose of it. The consignee must have an appropriate environmental permit or waste exemption in place in order to accept the waste.
Consignor: A person who causes the waste to be removed; this can be the producer, the holder or an agent acting with authority from the producer or holder of the hazardous waste.
A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-special waste to another party. The format of a WTN must conform to the requirements laid out in section 3 of The Environmental Protection (Duty of Care) (Scotland) Regulations 2014.
A WTN can be issued to cover a particular collection, or for multiple collections of the same waste type, from the same site, by the same waste carrier over a maximum period of one year (a ‘season ticket’).
WTNs are not required by an occupier of domestic property for the removal of household waste produced on the property.
A WTN is a legally required document for non-hazardous waste. When hazardous waste is moved, it must be accompanied by correctly completed paperwork called a consignment note, or hazardous waste consignment note (HWCN). The note must be prepared before any hazardous waste is moved and is required for all movements of hazardous waste. The format of a HWCN must meet the requirements set out in Schedule 1 of The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.
An annual WTN or ‘season ticket’ is a single WTN that covers a series of non-hazardous waste transfers. The annual WTN can last up to one year and be used for regular transfers of the same type of non-hazardous waste with the same waste carrier from the same site. If you have several sites serviced by the same carrier with the same types of waste collected, they can be listed in a schedule to the annual WTN. It must be clear on the WTN what period it covers.
You should also keep a record of the collection times and the quantity of waste collected each time. A good way to do this is to get a delivery ticket from the waste carrier for each load collected stating when the collection took place and how much was collected.
Waste needs to be disposed of legally and correctly to protect people and the environment. It is a legal requirement that WTNs are completed for all transfers of waste to another party. WTNs allow the regulator to understand what wastes are being generated and how they are being disposed of and / or recovered. They provide a clear auditable paper trail from when the waste is produced to when it is disposed of and can help to evidence that a business has met its statutory duty of care.
WTNs are legally required for all transfers of non-hazardous waste to another party.
A WTN must be signed and dated by the transferor (usually the producer or holder of the waste) and the transferee (the person receiving the waste).
Paper or electronic copies of WTNs are acceptable. For non-hazardous waste in England and Wales you can use:
For hazardous waste consignment notes, paper or electronic copies are also acceptable. However, the online Edoc system is not yet available for hazardous wastes. The Environment Agency and Natural Resources Wales provide a template consignment note. You can use your own consignment note but it must have all the same information fields as this one and be as near to the same format as possible.
It is a legal requirement to keep copies of all WTNs / waste transfer information for at least two years. Hazardous waste consignment notes must be retained for a minimum of three years.
The Environment Agency and Natural Resources Wales provide a template WTN (in English and Welsh) which includes all of the required information. You can use alternative documentation, e.g. an invoice, as long as it contains all the required information.
The Environment Agency and Natural Resources Wales provide a template consignment note which is available in an electronic and paper version. You can use your own consignment note but it must have all the same information fields as this one and be as near to the same format as possible.
The Environment Agency’s public register allows checks to be carried out on waste carriers, waste exemptions and environmental permits in England. Simply select the register you wish to view, type in the company name (or you can use the address or permit number if you know it) and click ‘search’. You will then be able to see what authorisations your waste contractor has in place.
Natural Resource Wales’ public register allows checks to be carried out on waste exemptions and environmental permits in Wales in the same way that the Environment Agency’s register does above. Waste carriers licences in Wales can be checked used Natural Resources Wales spreadsheet of carriers, brokers and dealers.
It is good practice to request a copy of the environmental permit for the disposal / recovery site that your waste is being sent to. By doing so, you can check the EWC codes (codes used to identify waste as listed in the European Waste Catalogue, also referred to as LoW (List of Waste) or Waste Classification Code) the permit authorises to be accepted at that site are the same as those for the wastes being removed from your premises.
When a material is manufactured from non-waste materials, production residues are often unavoidable. The residue is either a waste or a non-waste by-product.
The residue is a by-product and not a waste when the material meets all of these conditions:
Common examples include:
The decision tree on the next page can help in determining if something is a waste or a by-product.
No obligation demo to help you understand how it works and how your business can use it
Do you need help understanding what waste transfer notes are and how to complete them?
Listen to one of our short and simple 20-minute webinar on waste transfer notes in Scotland.
Kerry Hammick, one of our experienced consultants, will talk you through:
Waste: Anything which you decide to, or are required to, throw away.
Hazardous waste: Waste is generally considered hazardous if it (or the material or substances it contains) are harmful to humans or the environment. Examples of hazardous waste include:
Waste transfer note: A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-hazardous waste to another party. The format of a WTN must conform to the requirements laid out in Part 9 of The Waste (England and Wales) Regulations 2011.
Consignment note: A consignment note, or hazardous waste consignment note (HWCN) is a legally required document that details the transfer of hazardous waste from one party to another. The note must be prepared before any hazardous waste is moved and is required for all movements of hazardous waste. The format of a HWCN must meet the requirements set out in Schedule 1 of The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.
Producer: Any person whose activities produce waste.
Holder: The waste producer or the legal person in possession of the waste.
Carrier: A person who collects or carries waste. A carrier must be registered with the Environment Agency in England or Natural Resources Wales in Wales.
Dealer: Any person that buys waste with the aim of subsequently selling it (including where they don’t take physical possession of the waste).
Broker: Any person that arranges waste transportation and / or the management of waste on behalf of another party, e.g. local authorities contracting out waste services to another firm.
Transferor: The current holder of the waste.
Transferee: The person receiving the waste.
Consignee: A person who receives hazardous waste to recover or dispose of it. The consignee must have an appropriate environmental permit or waste exemption in place in order to accept the waste.
Consignor: A person who causes the waste to be removed; this can be the producer, the holder or an agent acting with authority from the producer or holder of the hazardous waste.
A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-special waste to another party. The format of a WTN must conform to the requirements laid out in section 3 of The Environmental Protection (Duty of Care) (Scotland) Regulations 2014.
A WTN can be issued to cover a particular collection, or for multiple collections of the same waste type, from the same site, by the same waste carrier over a maximum period of one year (a ‘season ticket’).
WTNs are not required by an occupier of domestic property for the removal of household waste produced on the property.
A WTN is a legally required document for non-hazardous waste. When hazardous waste is moved, it must be accompanied by correctly completed paperwork called a consignment note, or hazardous waste consignment note (HWCN). The note must be prepared before any hazardous waste is moved and is required for all movements of hazardous waste. The format of a HWCN must meet the requirements set out in Schedule 1 of The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.
An annual WTN or ‘season ticket’ is a single WTN that covers a series of non-hazardous waste transfers. The annual WTN can last up to one year and be used for regular transfers of the same type of non-hazardous waste with the same waste carrier from the same site. If you have several sites serviced by the same carrier with the same types of waste collected, they can be listed in a schedule to the annual WTN. It must be clear on the WTN what period it covers.
You should also keep a record of the collection times and the quantity of waste collected each time. A good way to do this is to get a delivery ticket from the waste carrier for each load collected stating when the collection took place and how much was collected.
Waste needs to be disposed of legally and correctly to protect people and the environment. It is a legal requirement that WTNs are completed for all transfers of waste to another party. WTNs allow the regulator to understand what wastes are being generated and how they are being disposed of and / or recovered. They provide a clear auditable paper trail from when the waste is produced to when it is disposed of and can help to evidence that a business has met its statutory duty of care.
WTNs are legally required for all transfers of non-hazardous waste to another party.
A WTN must be signed and dated by the transferor (usually the producer or holder of the waste) and the transferee (the person receiving the waste).
Paper or electronic copies of WTNs are acceptable. For non-hazardous waste in England and Wales you can use:
For hazardous waste consignment notes, paper or electronic copies are also acceptable. However, the online Edoc system is not yet available for hazardous wastes. The Environment Agency and Natural Resources Wales provide a template consignment note. You can use your own consignment note but it must have all the same information fields as this one and be as near to the same format as possible.
It is a legal requirement to keep copies of all WTNs / waste transfer information for at least two years. Hazardous waste consignment notes must be retained for a minimum of three years.
The Environment Agency and Natural Resources Wales provide a template WTN (in English and Welsh) which includes all of the required information. You can use alternative documentation, e.g. an invoice, as long as it contains all the required information.
The Environment Agency and Natural Resources Wales provide a template consignment note which is available in an electronic and paper version. You can use your own consignment note but it must have all the same information fields as this one and be as near to the same format as possible.
The Environment Agency’s public register allows checks to be carried out on waste carriers, waste exemptions and environmental permits in England. Simply select the register you wish to view, type in the company name (or you can use the address or permit number if you know it) and click ‘search’. You will then be able to see what authorisations your waste contractor has in place.
Natural Resource Wales’ public register allows checks to be carried out on waste exemptions and environmental permits in Wales in the same way that the Environment Agency’s register does above. Waste carriers licences in Wales can be checked used Natural Resources Wales spreadsheet of carriers, brokers and dealers.
It is good practice to request a copy of the environmental permit for the disposal / recovery site that your waste is being sent to. By doing so, you can check the EWC codes (codes used to identify waste as listed in the European Waste Catalogue, also referred to as LoW (List of Waste) or Waste Classification Code) the permit authorises to be accepted at that site are the same as those for the wastes being removed from your premises.
When a material is manufactured from non-waste materials, production residues are often unavoidable. The residue is either a waste or a non-waste by-product.
The residue is a by-product and not a waste when the material meets all of these conditions:
Common examples include:
The decision tree on the next page can help in determining if something is a waste or a by-product.
No obligation demo to help you understand how it works and how your business can use it
Do you need help understanding what waste transfer notes are and how to complete them?
Listen to one of our short and simple 20-minute webinar on waste transfer note in England and Wales.
Kerry Hammick, one of our experienced consultants, will talk you through:
Waste: Anything which you decide to, or are required to, throw away.
Hazardous waste: Waste is generally considered hazardous if it (or the material or substances it contains) are harmful to humans or the environment. Examples of hazardous waste include:
Waste transfer note: A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-hazardous waste to another party. The format of a WTN must conform to the requirements laid out in Part 9 of The Waste (England and Wales) Regulations 2011.
Consignment note: A consignment note, or hazardous waste consignment note (HWCN) is a legally required document that details the transfer of hazardous waste from one party to another. The note must be prepared before any hazardous waste is moved and is required for all movements of hazardous waste. The format of a HWCN must meet the requirements set out in Schedule 1 of The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.
Producer: Any person whose activities produce waste.
Holder: The waste producer or the legal person in possession of the waste.
Carrier: A person who collects or carries waste. A carrier must be registered with the Environment Agency in England or Natural Resources Wales in Wales.
Dealer: Any person that buys waste with the aim of subsequently selling it (including where they don’t take physical possession of the waste).
Broker: Any person that arranges waste transportation and / or the management of waste on behalf of another party, e.g. local authorities contracting out waste services to another firm.
Transferor: The current holder of the waste.
Transferee: The person receiving the waste.
Consignee: A person who receives hazardous waste to recover or dispose of it. The consignee must have an appropriate environmental permit or waste exemption in place in order to accept the waste.
Consignor: A person who causes the waste to be removed; this can be the producer, the holder or an agent acting with authority from the producer or holder of the hazardous waste.
A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-special waste to another party. The format of a WTN must conform to the requirements laid out in section 3 of The Environmental Protection (Duty of Care) (Scotland) Regulations 2014.
A WTN can be issued to cover a particular collection, or for multiple collections of the same waste type, from the same site, by the same waste carrier over a maximum period of one year (a ‘season ticket’).
WTNs are not required by an occupier of domestic property for the removal of household waste produced on the property.
A WTN is a legally required document for non-hazardous waste. When hazardous waste is moved, it must be accompanied by correctly completed paperwork called a consignment note, or hazardous waste consignment note (HWCN). The note must be prepared before any hazardous waste is moved and is required for all movements of hazardous waste. The format of a HWCN must meet the requirements set out in Schedule 1 of The Hazardous Waste (England and Wales) (Amendment) Regulations 2016.
An annual WTN or ‘season ticket’ is a single WTN that covers a series of non-hazardous waste transfers. The annual WTN can last up to one year and be used for regular transfers of the same type of non-hazardous waste with the same waste carrier from the same site. If you have several sites serviced by the same carrier with the same types of waste collected, they can be listed in a schedule to the annual WTN. It must be clear on the WTN what period it covers.
You should also keep a record of the collection times and the quantity of waste collected each time. A good way to do this is to get a delivery ticket from the waste carrier for each load collected stating when the collection took place and how much was collected.
Waste needs to be disposed of legally and correctly to protect people and the environment. It is a legal requirement that WTNs are completed for all transfers of waste to another party. WTNs allow the regulator to understand what wastes are being generated and how they are being disposed of and / or recovered. They provide a clear auditable paper trail from when the waste is produced to when it is disposed of and can help to evidence that a business has met its statutory duty of care.
WTNs are legally required for all transfers of non-hazardous waste to another party.
A WTN must be signed and dated by the transferor (usually the producer or holder of the waste) and the transferee (the person receiving the waste).
Paper or electronic copies of WTNs are acceptable. For non-hazardous waste in England and Wales you can use:
For hazardous waste consignment notes, paper or electronic copies are also acceptable. However, the online Edoc system is not yet available for hazardous wastes. The Environment Agency and Natural Resources Wales provide a template consignment note. You can use your own consignment note but it must have all the same information fields as this one and be as near to the same format as possible.
It is a legal requirement to keep copies of all WTNs / waste transfer information for at least two years. Hazardous waste consignment notes must be retained for a minimum of three years.
The Environment Agency and Natural Resources Wales provide a template WTN (in English and Welsh) which includes all of the required information. You can use alternative documentation, e.g. an invoice, as long as it contains all the required information.
The Environment Agency and Natural Resources Wales provide a template consignment note which is available in an electronic and paper version. You can use your own consignment note but it must have all the same information fields as this one and be as near to the same format as possible.
The Environment Agency’s public register allows checks to be carried out on waste carriers, waste exemptions and environmental permits in England. Simply select the register you wish to view, type in the company name (or you can use the address or permit number if you know it) and click ‘search’. You will then be able to see what authorisations your waste contractor has in place.
Natural Resource Wales’ public register allows checks to be carried out on waste exemptions and environmental permits in Wales in the same way that the Environment Agency’s register does above. Waste carriers licences in Wales can be checked used Natural Resources Wales spreadsheet of carriers, brokers and dealers.
It is good practice to request a copy of the environmental permit for the disposal / recovery site that your waste is being sent to. By doing so, you can check the EWC codes (codes used to identify waste as listed in the European Waste Catalogue, also referred to as LoW (List of Waste) or Waste Classification Code) the permit authorises to be accepted at that site are the same as those for the wastes being removed from your premises.
When a material is manufactured from non-waste materials, production residues are often unavoidable. The residue is either a waste or a non-waste by-product.
The residue is a by-product and not a waste when the material meets all of these conditions:
Common examples include:
The decision tree on the next page can help in determining if something is a waste or a by-product.
No obligation demo to help you understand how it works and how your business can use it
Do you need help understanding what waste transfer notes are and how to complete them?
Listen to one of our short and simple webinars on waste transfer notes where Kerry Hammick, one of our experienced consultants will talk you through:
There are three webinars available, covering the legal requirements for England and Wales, Northern Ireland and Scotland.
Each webinar is accompanied with definitions of any technical terms and a comprehensive FAQ to answer all your waste transfer notes questions.
The webinars can be found by choosing your jurisdiction from the below list.
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