Hazardous waste: consignment notes, storage and records

Hazardous waste carries more paperwork than anything else that leaves a site: a classification, a consignment note before it moves, storage rules while it waits, and records that outlive most of the jobs you will ever do. Since 1 October 2026 in England and Wales there is a digital layer on top of all that, with receiving sites reporting each load through the Digital Waste Tracking Service (Scotland and Northern Ireland follow in January 2027). This guide covers the rules side in one place: what counts as hazardous, how a consignment note works from producer to consignee, what the four nations each require, how to store and separate it, and how long every party keeps the records.

The digital side has its own guide, so start there if the reporting duty is new to you: hazardous waste and digital waste tracking covers the service, the deadlines and the hazard property codes. This page is the other half: the rules that apply whether a load is moving on paper, on the service, or on both.

What counts as hazardous waste

Waste is generally considered hazardous if it, or the material or substances it contains, is harmful to humans or the environment. That is the definition the regulator works from. In practice the list people recognise includes asbestos, chemicals such as brake fluid and print toner, batteries, solvents, pesticides, oils (all except edible ones), equipment containing ozone depleting substances like fridges, and the containers hazardous waste arrives in.

The formal route is classification. Every waste gets a code from the List of Waste, and the hazardous entries are the ones marked with an asterisk. Some waste types have more than one possible entry depending on what they actually contain, so two loads with the same name can carry different codes and different duty levels. The technical guidance behind the classification is the waste classification manual known as WM3, and safety data sheets are the fastest way to find out what is in a waste you did not manufacture yourself. If the classification side is new, our EWC codes guide for transfer notes walks through how codes are chosen, and the code lookup covers the entries you see most often.

The consignment note, part by part

Hazardous waste moves on a consignment note, and the note follows a fixed pattern of five parts. The producer or holder completes parts A and B before the waste is removed, normally in three copies, and hands them all to the carrier. The carrier completes part C when it collects. Part D goes to the consignor, who may be the producer itself or a broker or dealer, and it cannot be completed before the carrier arrives. The consignee completes part E on receipt, once the load has been checked against the note.

The detail that catches people out is what part B has to say. As a minimum: a full description of the waste, its six-digit code from the List of Waste, the quantity in kilograms, the chemical and biological components with their concentrations, the physical form, the hazard properties, any persistent organic pollutant marking, the container type, number and size, and the carriage details for dangerous goods, including UN numbers where they apply.

Each note carries a unique code: six characters that identify the producer, then a five-character serial you change for every load. In England the six characters are the first six characters of the company name; in Wales they are the premises code Natural Resources Wales issued at registration. In England, letter suffixes flag the unusual movements: V for waste removed from ships, F for fly-tipped waste, D for a consignee return derogation, and P for waste piped continuously. Wales has its own code shapes, including a FLY prefix for fly-tipped waste. If the note turns out to be wrong, the consignee does not correct it on the doorstep. The note is rejected instead, and the consignee completes part E marking what was rejected and why. The rejected load procedure is worth knowing before it happens to you: In England, the carrier phones the Environment Agency, the producer chooses where the load goes next, and the replacement movement needs a fresh note carrying the original code with an R added.

Across the four nations

The five-part note is the England and Wales instrument, and in England the system is lighter than many people remember: since April 2016, premises that produce hazardous waste no longer have to register with the Environment Agency. The note itself, and the duty of care behind it, are unchanged.

Wales runs the same five-part note through Natural Resources Wales, with per-movement notes for anything moving to or from a site in Wales; loads arriving from outside Wales follow the rules of the country they came from. Unlike England, Wales also kept premises registration: premises that produce or store over 500kg of hazardous waste a year register with Natural Resources Wales and renew every twelve months.

Scotland does not use the English form at all. Special waste, which is what Scotland calls hazardous waste, moves on a special waste consignment note carrying a unique SEPA-issued code, whatever its destination in the UK. You can design your own note if it carries everything the Special Waste Regulations require, but the code comes from SEPA, and completed notes go back to SEPA electronically. Pre-notification applies in Scotland where the guidance requires it.

Northern Ireland takes the same shape as Scotland: hazardous waste is consigned on a note or number issued by the Northern Ireland Environment Agency, again regardless of where in the UK the waste is heading.

Two cross-border quirks are worth keeping in a drawer. Waste going from England into Scotland or Northern Ireland needs an extra copy sent to SEPA or NIEA at least 72 hours before the movement. Waste coming the other way, from Scotland or Northern Ireland into England, puts the copy duty on the English consignee, who sends the completed note back to SEPA or NIEA. England to Wales movements follow the normal England procedure.

Storing, separating, and the mixing ban

Mixing hazardous waste is banned before it even gets to the paperwork. You cannot mix hazardous waste with non-hazardous waste, with something that is not waste at all, or different hazardous wastes together. Waste oils with different characteristics cannot be mixed either. The only way a mix becomes lawful is when the site's environmental permit specifically authorises that operation and it is the best available technique for the job, which is a very narrow door.

Collections are a different matter from mixing. Gathering several hazardous items on one vehicle is fine as long as they are not physically mixed, cannot cross-contaminate, and each item is separately classified, described and quantified on the paperwork. Nothing may be hidden from the next holder of the waste. Sites also have a duty to separate wastes that have already been mixed unlawfully, where it is technically possible and the separation is needed to deal with health risks or a substantial environmental risk.

One exception runs the other way: householders can put domestic hazardous items, other than asbestos, into the normal mixed municipal collection, as long as they meet their local authority's waste segregation instructions. Businesses cannot. That includes tradespeople working at a domestic property: any hazardous waste they produce must stay out of the household bin and follow the waste duty of care.

Records: who keeps what, and for how long

Retention periods are where the shorthand goes wrong, because the answer depends on which party you are. The simple version, kept for three years, is only really the producer's answer. The full picture:

• Producers and holders keep a register of consignment notes, consignee returns and related documents for 3 years, at the premises that produced or stored the waste.
• Carriers keep records for 1 year, at their head office.
• Dealers and brokers keep the producer and holder records for 3 years.
• Permitted waste sites: a landfill keeps all records for as long as it holds the permit; other permitted sites keep consignment notes for 5 years, and the site inventory and all other records for the life of the permit; sites operating under an exemption keep records for 3 years.

The figures above are the England position; Northern Ireland keeps carrier copies for at least three years and the consignee's copy until the site licence expires.

There is one more regular chore in the same family: consignees send consignee returns every quarter, to the Environment Agency and separately to the producer or holder of the waste. Digital tracking has not removed any of this. It has added to it, which brings us to what actually changed on 1 October.

What digital tracking adds

Since 1 October 2026, every organisation licensed or permitted to receive waste in England and Wales must use the report receipt of waste service for the controlled waste it receives. Scotland and Northern Ireland start in January 2027, and waste carriers, brokers and dealers are planned to join from October 2027. A receipt is due within 2 working days of the load arriving, counting from the day after receipt.

For hazardous waste specifically, two details matter most. The paper method has not gone anywhere: waste transfer notes, Annex VII forms and hazardous waste consignment notes all still have to be completed where they already applied, running alongside the digital service. And where a load arrives covered by more than one consignment note, each note's waste goes into the service as its own separate record. The data a receipt carries covers the movement, the classification and hazard codes, the recovery or disposal operation, and persistent organic pollutants, so the classification work done for the consignment note does double duty. Registration and the annual service charge sit per organisation, £26 a year covering all of that organisation's receiving sites, with the first payment due by 31 January 2027.

If your site receives hazardous wastes, the practical result is that every load now has a record trail in two places, and the two need to agree. That is the daily job LoadLog exists for: hazardous waste software that captures the classification and hazard fields once, checks the receiving site's data against the consignment note, and submits the receipt to DEFRA before the two-day clock runs out.