What is the difference between a waste transfer note (WTN) and a consignment 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 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.
Is there a standard format for a consignment note? Does it have to follow a certain format?
The Environment Agency and Natural Resources Wales provide a template
HWCN which is available in an electronic and paper version. You can use your own HWCN but it must have all the same information fields as this one and be as near to the same format as possible.
How long should I keep consignment notes for?
In England and Wales is a legal requirement to keep copies of all HWCNs for at least three years. WTNs / waste transfer information (for movements of non-hazardous waste) must be retained for a minimum of two years.
Can I have an annual note for consignment notes?
An annual WTN or ‘season ticket’ is a single WTN that covers a series of non-hazardous waste transfers. You cannot have an annual HWCN in place for movements of hazardous waste.
How do I generate a consignment note code?
You must create a consignment note code and enter it onto the HWCN. The format for the consignment note code must be ‘XXXXXX/YYYYY.
- ‘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.
Do I need a consignment note for each collection?
A consignment note is required for all movements of hazardous waste. Every time hazardous waste is collected from your premises and transferred to another site a consignment note must be in place and have the relevant sections completed correctly.
Which bits of the consignment note do I need to sign?
The following parts of the consignment note must be signed and dated by:
- 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)
How do I check a site is authorised to accept hazardous waste?
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.
What are consignee returns?
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.
What are producer returns?
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.