Waste Transfer Note

A waste transfer note is the paper trail that proves your business handed its waste to someone legally entitled to take it. Under the UK duty of care, producing waste does not end your responsibility for it — you remain accountable for where it goes, and the transfer note is the evidence that you discharged that duty properly. For businesses disposing of end-of-life IT equipment the note matters twice over: it is both the environmental record and, in practice, the first thing an auditor asks for. This guide sets out exactly what the note must contain, how long to keep it, and where old computers and monitors sit in the waste classification system.

What is a waste transfer note?

A waste transfer note is a written record of the transfer of non-hazardous controlled waste from one party to another. It is required under the UK waste duty of care and must be completed and signed by both the person handing the waste over and the person receiving it.

The duty of care is the principle that responsibility for waste follows the waste. A business that produces waste does not discharge its obligation simply by paying someone to remove it — it must take reasonable steps to check that whoever takes it is authorised, and must keep documentary evidence of the transfer. The transfer note is that evidence. Without one, there is nothing to show that the waste left your site lawfully, and nothing to demonstrate that you checked the person taking it. The Environment Agency and local authorities can ask to see transfer notes, and GOV.UK states that operating without the required carrier or broker registration carries an unlimited fine.

What must a waste transfer note contain?

The note must carry enough information for the next holder to handle the waste safely and legally, plus a fixed set of identifying details about the waste, the parties and their authorisations. A note missing the EWC code or the carrier's registration number is not complete.

The duty of care waste transfer note template published on GOV.UK sets these out as fields to complete.

How long do you have to keep a waste transfer note?

Two years. Both the transferor and the transferee must retain the transfer note and the written description of the waste for two years from the date of transfer, and produce them if a regulator asks.

A paper or electronic copy is equally acceptable, so a scanned note filed against the job reference satisfies the requirement. The practical failure mode is not refusing to keep notes — it is keeping them somewhere nobody can find them two years later. For businesses running periodic IT refreshes, the sensible discipline is to file the transfer note with the asset disposal record for the same batch, so the environmental document and the asset list are retrievable together. Auditors typically ask for both at once, and a note that cannot be produced on request is, for enforcement purposes, a note that does not exist.

When do you need a consignment note instead of a waste transfer note?

When the waste is hazardous. Hazardous waste does not move on a transfer note at all — it moves on a consignment note, which is a separate document under a separate regime with its own notification requirements.

This distinction catches out businesses disposing of mixed IT loads. Unlike general office waste, a pallet of decommissioned equipment can contain both hazardous and non-hazardous items, and the two cannot travel on the same paperwork. A batch of laptops with no hazardous components is non-hazardous; add one display device containing POPs — a cathode ray tube or a flatscreen panel alike — and that item requires consignment-note treatment. Screen type alone does not settle it, which is why the assessment happens before collection rather than at the weighbridge. Getting this wrong is not a clerical error — it means the load moved without the documentation its classification demanded. If your load includes anything covered by the dangerous goods rules in transport as well, see our guide to ADR regulations, which governs carriage rather than disposal.

Which EWC code applies to old computers, laptops and tablets?

It depends on whether the equipment contains hazardous components. Business IT equipment is not automatically assigned a code — GOV.UK guidance requires that office equipment of a non-household type is individually assessed.

An asterisk against a code means the waste is hazardous. Printed circuit boards, cables and plastic housings can carry hazardous chemicals and persistent organic pollutants, so the assessment is a real exercise rather than a formality. GOV.UK publishes dedicated guidance on how to classify WEEE and on classifying specific electrical devices and components, which states that office equipment of a non-household type must be assessed item by item where it is not already listed.

Can one waste transfer note cover repeat collections?

Yes. A single note — commonly called a season ticket or annual transfer note — can cover repeated transfers for up to twelve months, provided the waste description, the parties and the collection location all stay the same.

This is the normal arrangement for scheduled collections, and it removes the need to raise a fresh note every visit. The conditions are strict, though: change the type of waste, change the carrier, or move the collection to a different site, and the season ticket no longer covers the transfer — a new note is required. Where a season ticket is in use, each individual collection still needs to be recorded, typically on a schedule listing the date, quantity and site for every visit. A season ticket reduces paperwork per collection; it does not remove the obligation to record what actually moved.

Who is responsible if the paperwork is wrong — you or the carrier?

Both, but the producer cannot transfer the risk away. The duty of care sits with the business that produced the waste, and it is not discharged by pointing at a contractor after the fact.

That is why the carrier's registration number appears on the note: it is the field that records which authorised party took the waste, and it is checkable. Anyone who transports waste, or who buys, sells or disposes of it, must be registered — and so must a broker, defined by GOV.UK as anyone who "arranges for someone else to buy, sell or dispose of waste", even if they never handle it themselves. Before a collection, the registration can be verified against the Environment Agency's public register of waste carriers and brokers. If you did not check, and the waste is later mishandled, the fact that somebody else physically drove it away is not a defence.

What should you check before handing over business IT equipment?

Run through five checks before the vehicle leaves. Each one corresponds to a field a regulator or auditor can later ask you to evidence, and all five take minutes at the point of collection rather than hours in reconstruction.

1. Verify the registration. Confirm the carrier or broker is registered with the Environment Agency and that the number on the note matches the public register.
2. Classify the load. Establish whether the equipment falls under 16 02 14 or contains hazardous components requiring 16 02 13* and consignment-note treatment.
3. List the assets. Record what is leaving, item by item, before it goes — particularly anything data-bearing. Reconciling a list afterwards is far harder.
4. Get the note signed at transfer. Both parties sign; a note completed later from memory is a weaker record and may be incomplete.
5. File it for two years. Store the note with the asset list for the same batch so both can be produced together.

For equipment leaving as part of a wider move rather than a disposal, our guidance on office relocation logistics covers the transport side, and businesses in the sector may find our electronics logistics overview useful.

How does T&C Logistics handle IT equipment collections?

We are registered with the Environment Agency as an upper tier waste carrier, broker and dealer under registration number CBDU654368, so the collection leg is performed under our own registration rather than subcontracted authorisation. Treatment and recycling then take place at an approved facility operated by our partner.

The division matters, because the two roles carry different authorisations. Carrying controlled waste requires carrier registration; treating it requires a permitted facility, and those are separate permissions held by separate parties. T&C Logistics is not an approved treatment facility and does not process WEEE itself — recovery happens at a partner site holding the relevant permit. Where data-bearing assets need certified destruction, the certificate is issued by the processor that performed it, not by us. Transport runs under our Operator's Licence with GPS-tracked vehicles and goods-in-transit cover, and loads containing items classified as dangerous for carriage are handled under our hazardous goods procedures by ADR-licensed drivers. Cover levels for goods while in our care are set out under goods-in-transit insurance. Apply the same check to us that this guide recommends for any carrier: search CBDU654368 on the Environment Agency public register before you book. To discuss a collection, get in touch or call +44 7963 400173.