Waste Transfer Note
A Waste Transfer Note (WTN) forms part of the Duty of Care regime which requires the transfer of waste to be accompanied by a written description of the waste.
A WTN can either be completed on line at https://www.gov.uk/government/publications/duty-of-care-waste-transfer-note-template or by use of a paper document.
The description of the waste must be accurate, contain all the information required in order to ensure the lawful and safe handling, transport, treatment, recovery or disposal by subsequent holders of the waste, including[1]:
- classification of the waste by using the appropriate codes (referred to as the List of Waste (England) Regulations 2005 (LoW) or the European Waste Catalogue (EWC))
- its quantity and nature and whether it is loose or in a container
- if in a container, the type of container
- the time and place of transfer
- the SIC code of the transferor (current holder of the waste)
- the name and address of the transferor and transferee (person receiving the waste) and their signatures (the signature can be electronic as long as an enforcement officer can view it)
- the capacity in which the transferor and transferee are acting (e.g. as a producer, importer or registered waste carrier, broker or dealer) and their relevant authorisation to act in that capacity (e.g. their permit number or registration number).
The description must also contain a statement confirming that the current holder has fulfilled their duty to apply the Waste Hierarchy as required by regulation 12 of the Waste (England and Wales) Regulations 2011.
WTNs must be in place for each and every transfer of Non-Hazardous Waste however, a 'season ticket' (a single waste transfer note that covers a series of non-hazardous waste transfers) can be used if the same type of waste is being transferred by the same carrier. If several sites are serviced by the same carrier with the same types of waste collected, these can be listed in a schedule to the season ticket but a record of the collection times and the quantity of waste should be maintained. A 'season ticket' can last up to 12 months[1].
A WTN is not required for non-hazardous waste if the waste holder does not change on the transfer of waste e.g. the waste is moved to other premises belonging to the same business. However, it is best practice that the business understands who has responsibility for that waste and a record is kept of internal transfers for audit purposes[1].
WTNs must be kept by a producer of waste for a minimum of two years.
If an authorised officer of the EA, NRW or local authority asks for sight of the written description of waste, or a copy of it, and one is not provided, a fixed penalty notice can be issued. Where the waste is Hazardous Waste, a variable monetary penalty for breach of the requirements to supply information may be issued[1].