Waste Transfer Notes are legally required for almost every commercial movement of waste in England and Wales. They are also one of the most commonly misunderstood, incomplete and — when enforcement happens — most damaging compliance failures in the industry.
This guide covers the legal basis, exactly what a WTN must contain, who's responsible for what, and the most common mistakes.
What is a Waste Transfer Note?
A Waste Transfer Note (WTN) is a document that records the transfer of controlled waste from one person to another. It is required under the Environmental Protection Act 1990, Section 34 — the Duty of Care.
When a waste producer hands material to a waste carrier, and when a carrier deposits it at a facility, a WTN (or appropriate documentation) must be completed. Both parties must keep a copy for a minimum of two years.
Who needs a WTN?
Anyone who produces, carries, keeps, treats or disposes of controlled waste in England and Wales. This includes excavated soil, construction waste, scrap metal, general commercial waste and most organic materials.
What a WTN must contain
Under the Environmental Protection (Duty of Care) Regulations 1991 (as amended), a WTN must include:
Description of the waste
Sufficient to identify it. The EWC (European Waste Classification) code should be included — e.g. 17 05 04 for soil and stones not containing hazardous substances.
Quantity
In tonnes or cubic metres. Estimated weight is acceptable if weighbridge is not available at collection.
Type of container
Loose in tipper, skip, bulk bag, etc.
Current location
The address where waste is being collected.
Transfer information
Where it is going, whether it is a single or season ticket.
Carrier details
Name, address, and EA Waste Carrier Registration number.
Producer details
Name, address, and SIC code of the waste producer.
Signatures and dates
Both the transferor (waste producer) and transferee (carrier) must sign and date.
Season ticket WTNs
If the same type of waste is transferred regularly between the same parties, a season ticket WTN can cover multiple transfers. It must specify the period covered (maximum 12 months), the type of waste, the parties and locations, and the maximum quantity per transfer.
Season tickets are common in muck-away programmes, regular waste collections and recurring aggregates movements.
Common mistakes
Missing EWC code
The EWC code is mandatory. Use the EWC Lookup at app.bulkmatch.co.uk to find the right code for your material.
No carrier registration number
The carrier's EA Waste Carrier Registration must be on the note. Without it, the note is non-compliant and the transfer may be considered illegal.
Unsigned or undated
Both parties must sign. A note signed only by the carrier is not compliant.
Vague waste description
'Soil' is not sufficient — 'excavated clay, inert, from residential basement dig' with EWC 17 05 04 is.
Lost notes
Both parties must retain copies for 2 years minimum. Keep digital copies as a backup.
Penalties for non-compliance
Failure to comply with the Duty of Care is a criminal offence. The Environment Agency can issue fixed penalty notices of up to £300 per waste transfer for minor breaches. Serious or repeated non-compliance can result in prosecution, unlimited fines and — for companies — director disqualification.
The EA carries out spot checks on waste movements. Having an incomplete or missing WTN when stopped is not a minor issue.
Free WTN Generator — no account needed
BulkMatch's free WTN Generator at app.bulkmatch.co.uk helps you create compliant waste transfer notes in minutes. Includes EWC code lookup. When BulkMatch launches, WTNs will be generated automatically for every qualifying load.