What is a Waste Transfer Note (WTN)? A Complete Guide

A Waste Transfer Note, or WTN, is the legal record created every time non-hazardous waste changes hands in the UK. If you transfer waste from one person to another — from a skip hire company to a recycling facility, from a builder to a waste carrier, from a transfer station to a landfill — the law requires a WTN for that movement.

This guide explains what a WTN is, what must be on it, who needs one, how long to keep it, and how the system is changing under DEFRA's Digital Waste Tracking Service.

The legal basis for Waste Transfer Notes

The requirement to document waste movements comes from Section 34 of the Environmental Protection Act 1990, which established the Duty of Care for waste. The Duty of Care applies to any business that produces, carries, keeps, treats, imports, disposes of, or controls waste. It requires that waste is transferred only to authorised persons and that a written record — the Waste Transfer Note — is created and kept for each transfer.

The detailed rules for WTNs are set out in the Waste (England and Wales) Regulations 2011. These regulations specify what information must be recorded, who must sign it, and how long it must be kept.

A WTN is separate from a hazardous waste consignment note. Hazardous waste movements use a different system with additional requirements. This guide covers non-hazardous waste WTNs only.

When do you need a Waste Transfer Note?

You need a WTN whenever non-hazardous waste is transferred from one business to another. Common situations include:

• Skip Hire Collections: A skip hire company collecting a loaded skip from a customer and taking it to a transfer station.
• Construction Transfers: A waste carrier collecting construction waste from a building site and delivering it to a recycling facility.
• Onward Disposal: A transfer station sending sorted waste onwards to a landfill or treatment plant.
• Commercial Waste Collection: A business paying a licensed waste carrier to remove everyday operational waste from their premises.

If both the transferor and the transferee are businesses, a WTN is required. A householder taking waste to the local tip does not need a WTN — the Waste Duty of Care does not apply to householders for their own household waste.

What must be on a Waste Transfer Note

The Waste (England and Wales) Regulations 2011 specify the mandatory information that must appear on every WTN. A compliant WTN must include:

• The Waste Description: A clear description of what the waste is and how it is packed.
• EWC Code: The European Waste Catalogue (EWC) code for the specific waste type (also known as the List of Wastes code).
• Quantity: The total quantity of waste, normally measured by weight or volume.
• Containment: The type of container or vehicle the waste is held in.
• Time & Place: The exact date, time, and location of the transfer.
• The Transferor's SIC Code: The 2007 Standard Industrial Classification (SIC) code of the business producing or transferring the waste.
• Business Categories: The legal status of both parties (e.g., whether they are the producer, importer, carrier, broker, or dealer of the waste).
• Names & Addresses: The name and address of the waste producer, the current holder, the carrier collecting it, and the final receiving site.
• Carrier Registration: The carrier's registration number issued by the Environment Agency (or NRW, SEPA, or NIEA depending on location).
• Site Authorization: The environmental permit number or registered waste exemption number of the receiving site.
• Signatures: Written or electronic signatures from both the person transferring the waste and the person receiving it.
• Duty of Care Declaration: A signed confirmation that the waste hierarchy has been applied and the Duty of Care has been met.

If the waste is being imported or exported between the UK and other countries, additional documentation is required, but that is outside the scope of a standard WTN.

Keeping records and what the Environment Agency can ask for

The transferor must keep a copy of the WTN for two years from the date of transfer. The transferee — the person receiving the waste — must also keep their copy for two years. This applies to paper and digital WTNs equally.

The Environment Agency can request to see WTNs as part of a routine site inspection or as part of an investigation. You must produce the records within seven days of being asked. Failure to produce a WTN when requested can result in enforcement action, including civil penalties of up to £5,000 per incident.

Records should be kept in a way that makes them easy to find and retrieve. A digital system with searchable records makes this straightforward. Paper records stored in filing cabinets require manual searching, which becomes difficult at scale. The regulations do not specify a particular format — paper and digital records are equally valid under the 2011 Regulations, provided they contain all the mandatory information and are available when requested.

The difference between paper and digital Waste Transfer Notes

The Waste (England and Wales) Regulations 2011 explicitly permit digital Waste Transfer Notes and electronic signatures. Paper has never been a legal requirement. Despite this, most waste operators in the UK continued using paper WTNs well into the 2020s.

A paper WTN is typically a multi-part carbon form filled out by hand at the point of transfer. One copy stays with the producer, one goes with the carrier, and one stays at the receiving site. For a site handling hundreds of loads per month, this generates a significant volume of paper that must be stored, organised, and retrieved when needed.

A digital WTN replaces the paper form with an electronic record created on a computer, tablet, or phone. The same information is recorded, and the same signatures are captured, but the data is stored electronically rather than on paper. Digital records are searchable, cannot be lost in the same way a paper form can, and do not degrade over time.

Digital signatures on WTNs are legally valid under the Electronic Communications Act 2000 and the Waste (England and Wales) Regulations 2011.

How the Digital Waste Tracking Service changes things

From October 2026, the rules change for permitted waste receiving sites. DEFRA's Digital Waste Tracking Service (DWTS), established under Section 58 of the Environment Act 2021, requires receiving sites to submit waste movement records to a central government database in addition to keeping their own WTN records. Scotland follows in January 2027. Waste carriers, brokers, and dealers join the scheme from October 2027.

This is not a replacement for the WTN. The WTN remains the legal record of the transfer. What changes is that receiving sites must now report the receipt of waste to the DWTS within two working days. The data reported includes the waste type, EWC code, quantity, carrier details, receiving site details, and date of receipt.

There are two ways to report to the DWTS: through an API connection using compatible waste software, or by downloading a spreadsheet template from the service, filling it in, and uploading it. The spreadsheet option is temporary and expected to remain available until at least October 2027.

The annual fee for using the service is £26 per legal entity. This is separate from any fees charged by software providers for compliance tools that connect to the API.

For a detailed breakdown of the deadlines and who is affected, see our DWTS compliance page or read the official guidance on GOV.UK at Report receipt of waste.

What a compliant Waste Transfer Note looks like today

Whether paper or digital, a compliant WTN follows a rigid structure. It must clearly outline:

• The name, address, and SIC code of the waste producer.
• A clear description of the waste, including its six-digit EWC code.
• The quantity, normally formatted in tonnes or cubic metres.
• The explicit date and time of the transfer.
• The carrier's name, address, and Environment Agency registration details.
• The receiving site's name, address, and active environmental permit/exemption number.
• Signatures from both authorised parties completing the transfer.
• A written declaration that the UK Waste Hierarchy and Duty of Care have been met.

The standard format for non-hazardous WTNs in England and Wales is the WMC2A format. Northern Ireland and Scotland have their own equivalents. The data fields are the same regardless of format — only the form layout differs.

If any of these fields are missing, the WTN is not compliant. An incomplete WTN is the same as no WTN, and the same penalties apply.

What happens if you do not have a Waste Transfer Note

Operating without a WTN for a waste movement that requires one is a breach of the Duty of Care under the Environmental Protection Act 1990. The Environment Agency can issue civil penalties of up to £5,000 per incident. For serious or repeated breaches, the Agency can prosecute, and the courts can impose unlimited fines.

If an EA officer visits your site and asks to see the records for the last month's incoming waste and you cannot produce the corresponding WTNs, you have a compliance problem regardless of whether the waste was handled correctly. The record is the proof.

A note on hazardous waste

This guide covers non-hazardous Waste Transfer Notes. Hazardous waste movements require a consignment note under the Hazardous Waste (England and Wales) Regulations 2005, which is a different document with additional fields. The data requirements for the DWTS also differ for hazardous waste. If your site handles hazardous waste, check the specific requirements that apply to your operation.

Summary

A Waste Transfer Note is the legal record of a non-hazardous waste movement in the UK. It must contain specific information about the waste, the SIC code of the transferor, the parties involved, and the transfer details. It must be kept for two years and produced within seven days if requested. Digital WTNs and electronic signatures have been legal since 2011.

From October 2026, receiving sites must also submit waste receipt data to the DEFRA Digital Waste Tracking Service alongside their existing WTN records. This adds a reporting requirement on top of the existing duty of care record-keeping, and most sites handling any significant volume will find a dedicated compliance tool the most practical way to meet both obligations.