In the UK, any movement of hazardous waste – known as a consignment – needs to be accompanied by a legal document called a consignment note that has been correctly completed before the waste begins its journey. A consignment note is needed whenever hazardous waste is moved around, even if it doesn’t change hands. The movement of non-hazardous waste, by contrast, has its own rules and uses a different document known as a waste transfer note.
The current system of waste transfer and consignment notes is due for reform in April 2025 when mandatory digital waste tracking comes into force, introducing a UK-wide database that is meant to digitalise reporting of waste movements and phase out the use of paper documentation.
What are consignment notes for?
Hazardous waste consignment notes are part of an audit system that tracks how a company stores, manages and moves the hazardous waste in its possession. Companies owning hazardous waste are legally required to provide evidence that they are managing it appropriately. A waste consignment note is part of this process.
What are hazardous and non-hazardous wastes?
Waste is generally considered hazardous if it (or the material or substances it contains) is harmful to humans or the environment. Examples of hazardous waste include asbestos; chemicals such as brake fluid or print toner; batteries; solvents; pesticides; car oil; fridges and other equipment containing ozone depleting substances; and hazardous waste containers. Examples of non-hazardous wastes include domestic wastes; food waste; hygiene waste; packaging waste; recyclable waste such as paper, aluminium and glass; wooden waste furniture; and construction waste.
Scotland has its own consignment note
In Scotland, whose regulator is the Scottish Environment Protection Agency (SEPA), hazardous waste is referred to as special waste. Special waste that has been produced in Scotland needs to be consigned using a special waste consignment note (SWCN) bearing a unique SEPA-issued code, regardless of its final destination within the UK.
Consignees in England need to send a completed copy of the note to SEPA if the waste is from Scotland, or to the Northern Ireland Environment Agency (NIEA) if the waste is from Northern Ireland. If a load is rejected, a copy of the note needs to be sent to the relevant regulator. The producer and the Environment Agency also need to be informed by the consignees about all wastes they have received, using consignee returns.
What information goes on a consignment note?
There are five sections on a consignment note that need to be completed by four people: the producer or holder of the waste; the carrier of the waste; the consignor; and the consignee who receives it.
Producer or holder
The producer or holder of the waste fills in the first two sections, which must include the consignment note code and European Waste Catalogue (EWC) code; where the shipment is going from and going to; details of who produced the waste if different from the holder; a description of the waste; and details of the process that gave rise to the waste.
Carrier
The carrier of the waste is responsible for checking the above completed information in line with their duty of care obligations before the waste is removed. They need to complete and sign the third section, which includes their own details and those of the vehicle or vehicles they are using to transport the waste.
Consignor
The third individual, the consignor, needs to be present when the waste is collected. They need to complete the next section themselves before the waste is moved, and confirm that all the previous steps have been followed and checked. The consignor certifies, first, that the carrier has been checked as registered; second, that they have been advised of any precautionary measures which might need to be shared with the carrier; third, that the waste is packaged and labelled correctly in line with carriage of dangerous goods requirements for transport; and fourth, that the carrier has been advised of any special handling requirements.
Consignee
The fifth part of the consignment note is completed by the consignee, who receives two copies of the note from the carrier. The consignee checks the waste and the note, and either accepts or rejects the shipment. This is recorded on the note. They enter the EWC code, having checked that the waste is classified correctly; they check and enter the quantity of each code having weighed it in kilograms; and they enter the waste management operation that will be applied to the waste at the site using its R (recovery) or D (disposal) code.
When is a consignment note not needed?
A consignment note is not needed for the movement of non-hazardous waste, which instead requires a waste transfer note when it changes hands. Moving domestic hazardous waste from a domestic household to an initial collection point doesn’t need a consignment note either, unless it involves asbestos waste. Nor is a consignment note appropriate for waste that is imported or exported under international waste shipment controls, which require different forms of movement documentation.
