Waste Transfer Notes

Waste disposal regulation made simple by AnyJunk, the responsible rubbish clearance company – PART III

What is a Waste Transfer Note?
A waste transfer note is a document that records a transfer of waste from one party to another. It includes details of the place, date and time of transfer, the parties involved, the license or permit number of the person receiving the waste, and a description of the waste being transferred. The description of the waste should include the relevant European Waste Catalogue codes, as well as an indication of quantity and/or weight.

Example Waste Transfer Note for use by a Waste Carrier
The environment Agency (EA) provides an example waste transfer note on their website at http://www.netregs.gov.uk/netregs/63209.aspx but it’s a little confusing because it includes quite a few bits that aren’t relevant in a basic transfer from a producer to a waste carrier. So, here is our example of a simple waste transfer note that can be used by a waste carrier collecting waste from a business.

When is a waste transfer note required?
When a business transfers waste to another party, the transfer should be recorded by a waste transfer note. The meaning of ‘transfer’ in this context means passing responsibility – it does not mean transport from A to B. Hence the waste transfer note details the parties and address where the transfer of responsibility took place not where the waste ended up. So, in the typical scenario of a waste carrier collecting waste from a client’s premises and taking it to a waste transfer station run by a third party, there will be two waste transfers and two waste transfer notes. The first documenting the transfer from the original producer of the waste to the waste carrier, and the second when the waste carrier delivers the waste the tip (commonly referred to as a ‘tipping receipt’ or ‘weighbridge ticket’). In this common circumstance, while the producer may be interested in where the waste ends up his only legal obligation is to have a waste transfer note for the collection transfer, not the disposal transfer.

Householders don’t need waste transfer notes
Somewhat confusingly, there is no legal requirement for a waste transfer note when a waste carrier removes waste from a home for an occupier of that home. The precise definition of household waste is woolly but has been interpreted to include all waste material that comes out of a home including builders waste provided it is the householder herself who engages a waste carrier to remove it.

No transfer = no transfer note
It might sound obvious, but if no transfer of waste occurs then no waste transfer note is required. For example, a contractor building a conservatory that takes away demolition debris from his customer’s premises does not need to create a waste transfer note because they produced the waste themselves not the customer. The only requirement for a waste transfer note is when they deliver that waste to a 3rd party tip. On the other hand, if the contractor engages a waste carrier (such as a skip company or man & van clearance company like AnyJunk) to remove the waste, then a transfer occurs onsite between the two parties and a waste transfer note is required.

Note that if the same contractor leaves the waste behind for the occupier to arrange disposal, then technically speaking there is a waste transfer at that point but in practise the EA ignores this.

Who is responsible for producing it?
It is common practise for the party receiving the waste to produce the waste transfer note but both parties are responsible for making sure the information is accurate and both must sign the document and keep it for two years. Since photocopies of waste transfer notes are not acceptable, they are invariably created in duplicate using carbon copies (or occasionally electronically).

What does all this mean in a nutshell?
Businesses transferring waste to another party require a waste transfer note for every transfer and should keep it on file for at least 2 years.

Householders don’t need any waste transfer notes.

Need Practical Help?
If you need a registered waste carrier to clear your waste contact www.anyjunk.co.uk, the UK’s largest rubbish clearance company.

Our small print
AnyJunk is not a firm of solicitors, consultant or public authority – we are a rubbish clearance company. This guidance is designed to be a pragmatic summary for the majority of users and we have not included a multitude of additional rules, caveats and exemptions that may be relevant to your specific situation. If you require more detailed information or a definitive view on the rules and regulations governing waste, we recommend seeking independent legal advice or, at the very least, contacting the Environment Agency for a proper chat. In other words, please don’t sue us; we’re only trying to help!

Photo by Jeff Kubina

10 Responses

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  1. Pete Cain says:

    Your ‘simple waste transfer note’ lists flourescent tubes and fridges etc; note that these wastes must be moved on a consignement note as they are hazardous wastes (contain mercury and other nasty chemicals) NOT on a waste transfer note, which should only be used for non hazardous wastes.
    Hope this helps.

  2. Tim Witcomb says:

    Thanks for the comment. Yes, hazardous waste consignment notes are
    required when removing commercial hazardous waste but not for removing
    most domestic hazardous waste (other than asbestos) from a residential
    property. So, as a matter of good practice, we specify hazardous waste
    in waste transfer notes we supply domestic customers.

  3. Geoffrey Morgan says:

    The Waste (England & Wales) Regulations are really confusing and the law draftsman really should have done more to keep things simple. If waste is collected from a householder, we are told that the householder (transferor) doesn’t need to have a waste transfer note. This it is said, is to reduce the administrative burden on housholders, yet fly tipping incidents frequently involve household waste. Does the waste carrier removing waste from households have to raise a waste transfer note for the consignment to be taken to a waste transfer station? If not surely it makes a complete mockery of the system.

  4. Tim Witcomb says:

    Hi Geoffrey, thanks for your comment. You’re right that the regulations can be confusing and yes, the waste carrier definitely needs a waste transfer note as they are a business transferring waste to another party.

  5. Geoffrey Morgan says:

    Tim, thank you for this advice. At what stage does the transferee need to complete the waste transfer notes? Is it on receipt of the waste or prior to when it is passed to a third party?

    A big problem I find, is many waste carriers are unable to read or write and are therefore unable to complete this documentation. They really should ensure that waste carriers are competent to do the job. You wouldn’t employ someone on heavy plant machinery who hasn’t got the qualifications, so why allow folk to be waste carriers, if they can’t do everything that is required, such as filling in the forms needed for Duty of Care.

  6. Tim Witcomb says:

    Hi Geoffrey, the WTN should be completed on receipt of the waste – our WTNs are emailed in PDF format automatically to our customers as the AnyJunk truck team leaves the site.

  7. alison says:

    when clearing a site of brick and concrete slabs who is responsible for removal ie filling in the correct forms, is the owner of the site or the builder taking down the building or the transporter of the material. Does the owner hold responsibility through out

  8. Tim Witcomb says:

    Hi Alison, a waste transfer note is not legally required when a waste carrier removes waste from a home for an occupier of that home. This includes builders’ waste provided it is the householder who asks a waste carrier to remove it. If the builder arranges for someone to take the waste away, a waste transfer note is required. The purpose of the waste transfer note is to transfer the responsibility for the waste so no, the owner of the site does not hold responsibility throughout. Businesses transferring waste to another party require a waste transfer note for every transfer and should keep it on file for at least 2 years.

  9. Jules says:

    We are just handed collection notes by the driver removing our waste – does this satisfy the requirements or should we be preparing a full waste transfer note and giving the driver a copy, even though he probably can’t complete all the details needed?

  10. Tim Witcomb says:

    It sounds like your waste contractor is not supplying you with a proper waste transfer note. It needs to be signed by both parties and detail the waste being removed, including the address, date, and names of parties. An example of a waste transfer note can be found at http://www.environment-agency.gov.uk/business/topics/waste/40047.aspx along with further guidance. Although it is the responsibility of both the waste carrier and the producer of the waste to record a waste transfer in a waste transfer note, in practise it is always the waste carrier that provides the paperwork. If your existing waste contractor is unable to do this, we recommend you consider an alternative contractor who can.

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