When non-hazardous waste changes hands, a legal document called a waste transfer note (WTN) is needed to record the waste type, the waste quantity, and the parties involved in its transfer. Also known as duty of care certificates, WTNs are meant to track the movement of waste along the so-called chain of custody to provide accountability, and encourage responsible waste management.
Moving hazardous waste, as opposed to non-hazardous waste, has its own rules which include the compilation of a hazardous waste consignment note.
What goes on a waste transfer note?
Anyone transferring waste needs to include on the WTN a description of the waste and any processes it has been through; how the waste is contained or packaged; and the quantity of waste. They also need to record the place and date of transfer, the name and address of both parties, as well as details of the permit, licence or exemption of the person receiving the waste.
If the party handing over the waste has a waste management licence or is a registered carrier of controlled waste, they should put down their licence or registration number. A WTN also requires the relevant European Waste Catalogue (EWC) code for the waste, the Standard Industry Code (SIC) of the waste holder, and the name of their unitary authority or council.
Additional requirement for Northern Ireland
In Northern Ireland, a statement must accompany the WTN indicating that the waste hierarchy has been applied in line with regulation 17 of the Waste Regulations (Northern Ireland) 2011.
Risks of non-compliance
As a general rule, WTNs need to contain enough information for the waste to be handled safely, and either recovered or disposed of legally in line with the Environmental Protection Act 1990 (EPA). This act sets out the duty of care obligations for anyone handling certain kinds of waste, which requires them to take all reasonable steps to keep it safe. Prosecution is a risk if waste is mismanaged as a result of missing information on a waste transfer note. WTNs should be stored for two years to ensure compliance, allowing for for audits, inspections, and resolution of disputes.
When will waste transfer notes be phased out?
The existing paper-based system of waste transfer notes is due to be accompanied by Mandatory Digital Waste Tracking (MDWT) in April 2025. From that point, waste producers, intermediaries, brokers, carriers, and facilities that receive the waste will need to feed their data into a unified, UK-wide digital database, although there are a number of exceptions and details are still lacking. While some of the current reporting requirements will almost certainly be retired, hard copy WTNs are unlikely to disappear any time soon.
Until the new rules relating to MDWT come into force, existing regulations apply and the UK government website provides a WTN template which can be downloaded as a pdf.
Administrative burden is set to rise
The additional reporting requirements and heightened levels of regulatory scrutiny that MDWT will introduce are sure to put more pressure on back-office staff in the sector. As a result, many waste traders will have little alternative but to adopt modern recycling software or scrap trading software as a means of automating their reporting and compliance processes.
