Hazardous Waste Consignment Note: Who Signs What

Hazardous waste cannot lawfully move in England without a consignment note, and the note is split so that each party signs only its own section. The parts that hold collections up are almost always the producer's: the SIC code and the waste classification code, neither of which a carrier can supply for you.

What is a hazardous waste consignment note, and when do you need one?

A consignment note is the document that must accompany hazardous waste from the producer to its final destination. It is not optional and it is not a delivery note: hazardous waste cannot lawfully move in England without one, and the note must stay with the load until it arrives.

It is a different document from a waste transfer note. A waste transfer note covers non-hazardous controlled waste; a consignment note covers hazardous waste and carries more information, more signatures and a reporting obligation on the receiving site.

Hazardous waste in this sense includes asbestos, chemicals such as brake fluid or print toner, batteries, solvents, pesticides, non-edible oils, equipment containing ozone-depleting substances such as fridges, and hazardous waste containers themselves. Classifying the waste is the first step, because the classification decides which document you are filling in.

Who completes which part of the note?

The note is split by role, and each party completes only its own part. The most common failure is a producer signing the carrier's section or leaving its own blank.

Use a continuation sheet where there is not enough space rather than compressing entries. Environment Agency consignment notices come in 3 colour-coded copies, but you can equally use a note supplied by your waste contractor or write your own — provided it carries all the information the official form carries.

What information does the producer have to supply?

Two codes, and neither can be guessed. The first is the SIC code (2007), which describes the business activity that produced the waste. The second is the waste classification code — also called the LoW or List of Waste code, or the EWC code — which describes the waste itself.

These are the fields that most often hold up a collection, because they belong to the producer and nobody else can derive them. A carrier cannot assign your SIC code and should not assign your waste code; both describe facts about your business and your process.

Classify the waste before you book anything. The classification decides whether you need a consignment note at all, which codes go on it, and whether the movement is also regulated in transit under ADR — and all 3 of those questions have to be settled before a vehicle is useful to you.

The producer or holder also has to keep one copy of the completed note and give 2 copies to the carrier. Those two travel with the load. If you hand over a single copy, the carrier cannot both leave one at the destination and retain one, which breaks the chain at the far end.

How long do you have to keep the records, and where?

This is where the three roles diverge, and the answer depends on which one you are.

The register a producer keeps is not just the notes. It must include the consignee returns received from the sites that took the waste, plus any related documents — carrier schedules listing the carriers where more than one was involved, and records of rejected loads. Where a document is not accurate or complete, you must keep a record of the missing information rather than simply filing the incomplete version.

What are consignee returns, and why should you chase them?

A consignee return is the receiving site's report on hazardous waste it has received, treated or disposed of. As a producer you should get them every quarter from the consignee handling your waste, and you need them to complete your own 3 year register.

The consignee has to send separate returns to the Environment Agency and to the producer — not the same document copied to both. Published deadlines run a month after the reporting period: July to September 2026 by 31 October 2026, and October to December 2026 by 31 January 2027.

If you do not receive them, ask in writing. The Environment Agency's own advice is blunt: contact the agency and stop using a waste business that does not provide consignee returns. A site that will not report what it did with your waste is a site that leaves you unable to evidence your own duty of care — see waste duty of care.

What does the carrier have to check before accepting the load?

Parts A and B, and the waste itself. A carrier is required to check the producer's sections and satisfy itself the waste is classified correctly before it accepts the consignment — and then to separate the waste correctly when loading.

1. Step 1 — check parts A and B and inspect the waste against them.
2. Step 2 — complete part C.
3. Step 3 — leave one copy with the producer or holder, keep 2 that travel with the load.
4. Step 4 — take the waste to the destination named on the note, which must be an authorised waste site with an environmental permit.
5. Step 5 — keep the register for one year at head office.

A carrier that takes a load to a different site from the one on the note has broken the chain, whatever the commercial reason. If a consignee rejects the load, the rejected-loads procedure applies to both the carrier and the producer.

What happens if the receiving site rejects the load?

The rejected-loads procedure applies, and it binds both the carrier and the producer. A consignee that rejects hazardous waste does not simply hand it back — the rejection itself becomes a record that has to sit in the producer's register alongside the original note.

That is why "records of rejected loads" appears explicitly in the list of documents a producer must keep, next to the consignment notes and the consignee returns. A rejection with no paper trail looks identical to waste that went missing.

The commonest cause is a classification mismatch: the waste in the drum is not the waste described in parts A and B. Since the carrier is required to check those parts and the waste before accepting it, a rejection at the far end usually means the check at the near end was not made. See ADR for how classification works in transit and hazardous goods for the handling.

What does it cost to file a consignee return?

The fees are charged per consignment and fall on the consignee, not on you as producer — but they explain why a treatment site cares whether a job is recorded as a single consignment or part of a multiple collection. The paper route costs roughly twice the electronic one in both cases.

For a producer, the figure that matters is not the fee but the arithmetic behind it: every consignment generates a reporting event with a cost attached, which is why consolidating collections is usually cheaper than calling a vehicle each time a drum fills.

A multiple collection is one where the waste came from several locations, and it is reported at roughly half the single-consignment rate. For a business with 3 or 4 sites producing the same stream, routing one vehicle round all of them reduces both the transport cost and the reporting cost — but only if the note is completed as a multiple collection, with a carrier schedule where more than one carrier is involved.

Where does T&C Logistics sit in this chain?

We are registered with the Environment Agency as an upper tier waste carrier, broker and dealer under registration number CBDU654368, valid to 20 August 2029. You can verify that for yourself: search CBDU654368 on the Environment Agency's public register of waste carriers and brokers before you hand anything over. That is the check the agency asks every producer to make, and we would rather you made it.

All three roles matter in practice. Carrier covers moving the waste; broker and dealer cover arranging for someone else to treat or dispose of it, which is what a managed collection with partner treatment actually is. We carry; the treatment itself happens at a partner-operated permitted facility, not at our premises.

On the dangerous goods side we hold ADR competence across classes 2, 3, 4, 5, 6, 8 and 9 — not class 1 explosives and not class 7 radioactives. Much hazardous waste is also ADR-regulated in transit, so both regimes apply at once: see dangerous goods note for the transport document and documented chain of custody for how the audit trail is kept. Tell us the waste codes and the volume and we will confirm what we can carry.