Bitesize webinar
Do you need help understanding what hazardous waste transfer notes are and how to complete them?
Listen to one of our short and simple 20-minute webinars on hazardous waste transfer notes in England and Wales. Kerry Hammick, one of our experienced consultants, will talk you through:
- what hazardous waste consignment notes are and why we need them;
- what information is required on a hazardous waste consignment note;
- how to correctly complete a hazardous waste consignment note; and
- what consignee returns are and the information necessary when completing or receiving them.
Common Definitions
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:
- asbestos;
- chemicals, such as brake fluid or print toner;
- batteries;
- solvents;
- pesticides;
- oils (except edible ones), such as car oil;
- equipment containing ozone depleting substances, like fridges; and
- hazardous waste containers.
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.
FAQs
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 The Waste (England and Wales) Regulations 2011, as amended.
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.
The:
- ‘XXXXXX’ is the first 6 letters or numbers (not symbols or spaces) of the name of the company that produced the waste / where the waste is being removed from and must be followed by ‘/’
- ‘YYYYY’ is exactly 5 numbers or letters (not symbols or spaces) of your choosing
For example, for a consignment of hazardous waste being removed from The Compliance People it would be THECOM/A0001. Each code can only be used once from the address where the waste is removed from. You must change the ‘YYYYY’ to create a different code each time waste is consigned from that premises.
- Part C – the waste carrier
- Part D – the consignor (the waste producer, holder or an agent acting with authority from the producer or holder of the hazardous waste)
- Part E – the consignee (person who receives the hazardous waste to recover or dispose of it)
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 hazardous wastes being removed from your premises.
Hazardous waste consignee returns are reports completed by the consignee to inform the regulator about the hazardous waste consignments that have been received, removed or disposed at a site. They are a compulsory requirement of The Hazardous Waste (England and Wales) Regulations 2005, as amended.
A consignee return must be sent to the regulator (the Environment Agency for England and Natural Resources Wales for Wales) each quarter and report what hazardous waste has been received or disposed of at your premises or place where it is produced. This can be submitted on a spreadsheet electronically, or in a paper format:
Operators are charged for hazardous waste consignee returns. Fees are per consignment of waste and depend on whether the consignment formed part of a multiple collection (if it came from multiple locations) or not. The fees for both England and Wales are:
- Single consignment – £10 (electronic returns) or £19 (paper returns)
- Multiple collection – £5 (electronic returns) or £10 (paper returns)
Waste contractors often incorporate the cost of such submissions into their fees for hazardous waste collection.
The consignee must send information known as a ‘return’ to the producer or holder of the waste entered on the consignment note. The return tells them what happened to their waste.
A producer return can be completed in one of two ways:
- Use the format set out in Schedule 8 of The Hazardous Waste (England and Wales) Regulations 2005, as amended
- Send both a copy of the fully completed consignment note and a description or confirmation of the disposal or recovery method for each waste on the consignment – required because Part E of the note is completed when the waste is received before the operation starts
The waste producer / holder should receive returns every quarter from the consignee dealing with their hazardous waste.
Ask for producer returns in writing if you do not get them – you need them to keep records.
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