What is a waste transfer note and why is it important?

A waste transfer note is a legal requirement for companies like SunSkips when handling waste generated by other businesses.

But many people aren’t even aware that they need one, let alone what information needs to be filled in to demonstrate they are abiding by the legal duty of care.

Here’s everything you need to know about waste transfer notes, including how to complete them and what happens if you can’t produce one for the Environment Agency…

What is a waste transfer note?

A waste transfer note (sometimes called a “duty of care note”) is a legal document that proves the transfer of waste from one party to another.

This is important because it ultimately determines who is responsible for the waste’s proper disposal.

In practice, the document is created when one waste carrier transfers waste over to another, including when a collector uses a third-party site for processing.

A waste transfer note is required when waste changes hands, so if a business that produces waste uses a carrier that then takes it to a site run by a different company, two documents will need to be completed.

SunSkips completes waste transfer notes like this for clients that use our site to recycle waste, in which case it’s more commonly referred to as a “tipping receipt” or “weighbridge ticket”, but has all the same details.

How to fill out a waste transfer note

A waste transfer note requires a fair bit of information, but once you get used to filling it all out, it doesn’t take all that long to complete.

The document must include:

• A clear description of the waste that’s being transferred, its quantity, weight and European Waste Catalogue code (also known as the “waste classification code” or “LoW (List of Waste)”.
• Names and addresses of both parties involved in the transfer.
• Details of where and how the waste was produced.
• How the waste is contained (in a skip, bag, loose, etc.)
• Date, time and address of the transfer.
• A check to confirm that regulation 12 of the Waste (England and Wales) Regulations 2011 has been upheld (which pertains to preventing waste ending up in landfill).
• Signatures of both parties.
• Waste carriers license number.
• SIC code of the transferor.

It’s important to make sure all the above information appears clearly on the document. Typically, this is the responsibility of the receiving party, but both must sign and keep a copy.

In some cases where the same waste is transferred on a recurring basis, it’s possible to complete one waste transfer note to cover a period of up to 12 months. This “season ticket” should also include the collection dates and times.

NOTE: Waste transfer notes are for non-hazardous waste only. If the waste is hazardous or a persistent organic pollutant (POP), you’ll need a hazardous waste consignment note. This is similar to a waste transfer note, except it must specifically state where the waste is being disposed of and be kept for three years.

How long do you keep waste transfer notes for?

Waste transfer notes must be kept by both parties for two years. They should be filed somewhere safe where they are unlikely to be lost, damaged or stolen.

Photocopies of waste transfer notes are not admissible as evidence in the case of an investigation by the Environment Agency, so they must be generated as either carbon copies or printed off if completed digitally.

Example of a waste transfer note

In the past, a standardised waste transfer note was necessary before a transfer could take place, but nowadays you can draw one up however you like. But to make sure you don’t forget any of the necessary information, it’s best to use a standard template.

Section A of D of a standard waste transfer note

For those unsure of where to start, the Environment Agency has templates available on its website, including one that can be filled out online for convenience.

But don’t be surprised if you find a business uses their own design for the document with their logo and brand colours – or simply an invoice or receipt. As long as it contains all the relevant information, it’s a perfectly valid legal document.

What happens if you don’t complete it?

If the authorities come knocking because they suspect you’re involved in the illegal dumping of waste (fly-tipping) and you can’t present them with a completed waste transfer note to prove your innocence within seven days, you’re liable for criminal prosecution.

The fines for this can be staggering and it’ll likely be reported in the local press, damaging your business’ reputation.

But those who are either unaware of the legal requirement to complete a waste transfer note, or who are simply skipping it altogether due to irresponsibility, are missing out on potentially enormous savings.

Waste transfer notes are massively useful in calculating your waste management costs and can help waste auditors work out how to streamline your processes and cut costs.

Do I need a waste transfer note when hiring a skip?

A good skip hire company will take care of your waste transfer note on your behalf. For example, SunSkips sends clients all the paperwork by email when the skip is collected.

However, individuals do have a responsibility to make sure their waste management provider holds a valid waste carrier’s licence.

You may also be required to apply for a skip hire permit if you’re planning to keep your container on a public road, although again, most skip hire companies are happy to take care of that for you (SunSkips included).

The future of tracking who’s responsible for waste disposal

Unfortunately, waste transfer notes aren’t 100% effective in keeping track of waste, as there will always be unscrupulous people offering to clear waste for next to nothing (and then dump it on a country lane).

To combat this, more advanced methods of tracking waste are currently being trialled.

One interesting development is the use of RFID tags on plastic packaging (similar to what you might see on high-value items at the supermarket to prevent shoplifting), which will allow authorities like the Environment Agency to track illegal waste back to the business or individual that created it.

Methods like this aim to crack down on fly-tipping, which costs English taxpayers around £11 million every year to clear up.

You can trust SunSkips to thoroughly fill out all the relevant paperwork for your waste management, including the waste transfer note. Get in touch today to discuss how we can help take some of the hassles of waste management off your plate.