What is the difference between a waste transfer note (WTN) and a special waste consignment note?
A waste transfer note (WTN) is a legally required document which must be completed for all transfers of non-hazardous / 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.
When special waste is moved it must be accompanied by correctly completed paperwork called a consignment note, or special waste consignment note (SWCN). The note must be prepared before any special waste is moved and is required for all movements of special waste. The format of a SWCN must meet the requirements set out in Schedule 1 of The Special Waste Regulations 1996, as amended.
Is there a standard format for a consignment note? Does it have to follow a certain format?
All special waste consignment notes in Scotland must bear a unique code (for which a fee is payable), issued from the Scottish Environment Protection Agency (SEPA), consisting of two letters -SA, SB or SC – and a series of numbers, for example SA 123456. SWCNs can be purchased directly from SEPA via one of their local offices or online
There is no requirement to use a SEPA-issued SWCN. Bespoke SWCNs can be used as long as they contain a code (SA/SB/SC) issued by SEPA. However, any bespoke SWCNs used should correspond to or be similar to the format found in Schedule 1 of The Special Waste Regulations 1996, as amended, and contain the information required by the regulations. Editable PDF copies of the SWCN are available to download and use.
It is recommended that you discuss any proposed format with SEPA in the first instance and use the format set out in the Regulations.
A SEPA issued consignment note consists of five different coloured (self-carbonising) pages, each with five sections labelled A–E. The use of self-carbonising paper or coloured pages is not a legal requirement.
How long should I keep consignment notes for?
In Scotland it is a legal requirement to keep copies of all SWCNs for at least three years. WTNs / waste transfer information (for movements of non-hazardous/special 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 / special waste transfers. You cannot have an annual SWCN in place for movements of special waste.
How do I get a consignment note code?
All consignment notes must bear a unique code, issued from SEPA, consisting of two letters – SA, SB or SC – and a series of numbers, for example SA 123456.
Consignment note codes (and SWCNs) can be purchased directly from SEPA via one of their local offices or online. Alternatively, companies can create their own SWCNs which adhere to the format set out in Schedule 1 of The Special Waste Regulations 1996, as amended, and include the unique consignment note code issued from SEPA.
SA codes: cost £15 each and are used for all other types of consignment not listed under SB or SC below.
SB codes: cost £10 each and are used for the consignment of special waste consisting only of lead acid motor vehicle batteries.
SC codes: are free of charge and are restricted to the following movements:
- the second or subsequent removal of waste within a succession of extended carrier’s collection rounds
- the return of out-of-specification materials, which are waste, to the original manufacturer
- the removal of waste from a ship to a conveyance or reception facility
Do I need a consignment note for each collection?
A consignment note is required for all movements of special waste. Every time special waste is collected from your premises and transferred to another site a SWCN must be in place and have the relevant sections completed correctly.
What paperwork do I need for cross border movements of special waste?
All special waste produced in Scotland must be consigned using a SEPA issued SWCN or a code issued by SEPA, regardless of its final destination within the UK.
When exporting special waste to England, Wales or Northern Ireland for treatment, disposal or recovery, the consignee who receives the waste is required to send a copy of the completed consignment note (including part E) to SEPA.
Producers in England, Wales or Northern Ireland should use the paperwork for their own country, completed in accordance with the relevant domestic legislation.
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 A – the consignor (the waste producer, holder or an agent acting with authority from the producer or holder of the hazardous waste)
- Part C – the waste carrier
- Part D – the consignor
- Part E – the consignee (person who receives the hazardous waste to recover or dispose of it)
Can I use electronic consignment notes?
For special waste the legislative framework in Scotland does not currently allow for the use of electronic SWCNs or an electronic waste tracking system for the movement of special waste. In recognition of the limitation of the current paper-based system and the benefits that an electronic system can provide for users, SEPA will accept the use of electronic waste tracking systems for the movement of special waste under a Regulatory Position Statement in the following circumstances:
For each consignment of special waste, the electronic system must generate a unique record which must:
- contain a unique (chargeable) code (SA/SB/SC) issued by SEPA
- be in a form agreed by SEPA
- contain all the information specified in Schedule 1 of The Special Waste Regulations 1996, as amended
Consignees must still comply with regulation 5(4)(d) of the Regulations, i.e. once the waste is received, they must submit a paper copy of the completed SWCN to SEPA.
All consignment notes (paper or electronic) must bear a unique code, issued from SEPA, consisting of two letters – SA, SB or SC – and a series of numbers, for example SA 123456.
How do I check a site is authorised to accept hazardous waste?
SEPA’s public register is not complete and currently only contains documentation and information on SEPA’s permits for operations in Scotland that fall under Pollution Prevention and Control Part A legislation and medium combustion plant permits that fall under Pollution Prevention and Control Part B legislation. To check waste management permits and waste exemptions for the waste types permitted, contact: [email protected]
. You can check waste carriers’ registrations using SEPA’s registered carrier or broker table
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.
Do I need to pre-notify the regulator before any special waste leaves my site?
Movements of special waste between sites in Scotland do not require you to pre-notify SEPA. However, you must pre-notify SEPA of a special waste movement if it is being sent to a location outside of Scotland or the waste originates outside Scotland and will be transported to a location in Scotland.
If you do need to pre-notify SEPA you do this by completing parts A and B of the pre-notification sheet of a consignment note. This must be sent to SEPA at least 72 hours, and not more than one month, before special waste is moved out of Scotland, or imported into Scotland from England or Wales.
Some hazardous / special waste movements are exempt from pre-notification. The exemption will apply if:
- You regularly produce and transport the same type of waste to the same disposal or recovery facility – you only need to pre-notify SEPA of the first consignment in any one year, provided you refer to the number of the initial pre-notification in all SWCNs
- Your business operates on a number of sites, and you transport your special waste to a site that you own that holds a suitable licence, permit or exemption to receive the waste
- You return faulty products or materials as hazardous / special waste to the supplier or manufacturer
- Your consignment only contains lead-acid vehicle batteries
Movements of special wastes that are exempt from pre-notification must still be accompanied by a SWCN.
What are consignee returns / copies?
Special waste consignee returns / copies are completed by the consignee to inform the regulator about the special waste consignments that have been received, recovered or disposed at a site. The consignee must send a completed copy of the SWCN to SEPA immediately upon receipt of each consignment. This is a compulsory requirement of The Special Waste Regulations 1996, as amended.