How to maintain a waste transfer note record system

To comply with UK law, you must keep a signed Waste Transfer Note (WTN) for every load of non-hazardous waste that leaves your business premises or project site. These records must be organised into a secure filing system and retained for a minimum of two years to be produced upon request by the Environment Agency or your local council.

Why a record system is mandatory

Under the "Duty of Care" legislation in the UK, your responsibility for waste doesn't end when the skip is collected. You are legally required to prove that your waste was handled by a licensed carrier and taken to a permitted site. Without a proper record system, you risk unlimited fines or even prosecution if waste from your business is found fly-tipped, even if you weren't the one who dumped it.

Setting up your filing system

You can maintain your records either physically or digitally. The key is consistency and ease of retrieval.

• Physical Filing: Use a dedicated lever-arch file with monthly dividers. This is often easiest if you are handed paper tickets on-site by drivers.
• Digital Filing: Scan paper notes immediately and save them in a dedicated folder (e.g., /Business_Records/Waste_Notes/2024/). Use a clear naming convention like YYYY-MM-DD-SiteLocation-Provider.pdf.

What must be included in every note

Before filing a note, check that it contains the following essential information. If it's missing, the record may not be legally compliant:

Requirement	Details
Waste Description	A clear description of the waste (e.g., "Mixed construction and demolition waste").
EWC Code	The European Waste Catalogue code (e.g., 17 09 04 for mixed construction waste).
Quantity & Container	How much waste there is and what it is in (e.g., 8-yard skip).
Transfer Details	The date, time, and address where the waste was handed over.
Signatures	Both you (the producer) and the driver (the carrier) must sign the note.
Licence Info	The carrier's waste registration number and the disposal site's permit number.

Steps to maintain your records

1. The Handover: When the waste collector arrives, ensure the WTN is filled out correctly. Both parties must sign it before the waste leaves the site.
2. Immediate Storage: Never leave tickets in a van or on a dashboard where they can be lost or fade in the sun. Place them in a "to be filed" tray or scan them at the end of every day.
3. Monthly Audit: At the end of each month, cross-reference your WTNs against your waste disposal invoices. If you have an invoice for a collection but no matching WTN, contact the waste company immediately for a copy.
4. The Two-Year Rule: Set a recurring calendar reminder every six months to archive or securely destroy records that are more than two years old.

Tip: If you use the same waste carrier for the same type of waste over a long period, you may be able to use a "Season Ticket" (an Annual Waste Transfer Note). This covers all transfers for up to 12 months, significantly reducing your paperwork.