Consignment notes: required for every hazardous waste movement under the Hazardous Waste (England and Wales) Regulations 2005. Completed before collection, kept three years. England and Wales use different codes.
A waste transfer note does not cover hazardous waste. Hazardous movements need a consignment note, completed before the vehicle arrives rather than as it leaves, and the two documents are not interchangeable.
Offices trip over this more than most premises, because the hazardous items in a building are rarely the ones people expect. They are not drums of solvent. They are light fittings, batteries and a handful of electrical items that look like ordinary office equipment right up until the point they are classified.
The short version:
- Complete the note before the waste is collected, not afterwards
- Notes come in a set of three: producer, carrier, consignee
- Keep your copy for three years, not two
- England no longer registers producer premises. Wales still does, and uses a different SIC code year
- You should receive quarterly producer returns telling you what happened to the waste. Most people never chase them
- Mixing hazardous wastes without authorisation is an offence
When a Transfer Note Is the Wrong Document
The set comes in three parts, one each for the producer, the carrier and the consignee who receives it. Your contractor will normally complete much of the form and may prepare it for you, but responsibility for the consignor sections being correct and signed sits with you as the producer. That does not transfer with the waste.
Our guide to waste transfer notes covers the non-hazardous document and includes a template. This is the other one.
What an Office Actually Produces
| Item | Why it is hazardous | Where it turns up |
|---|---|---|
| Fluorescent tubes and compact lamps | Mercury content | Every ceiling grid in an older fit-out |
| Emergency lighting and UPS batteries | Battery chemistry | Escape routes, comms rooms, under desks |
| Some display and electrical equipment | Component composition varies by item and age | Store rooms and forgotten cupboards |
| Aerosols | Propellant under pressure | Cleaning stores and facilities cupboards |
| Fire extinguishers | Contents and pressure | Corridors and kitchens, often unrecorded on any asset list |
| Smoke detectors of certain types | Radioactive source in ionising units | Ceilings, usually removed by a contractor who assumes someone else owns them |
Classification is item-specific and depends on composition, so treat this as a list of things to check rather than a ruling. The point is that a clearance survey which only counts desks and chairs will miss all six, and they are the ones that need the other document.
Where England and Wales Diverge
| England | Wales | Scotland and Northern Ireland | |
|---|---|---|---|
| Producer registration | Not required since 1 April 2016 | Still required with Natural Resources Wales | Separate regimes |
| Premises code | None | Yes, on the note | Not applicable in the same form |
| SIC code year | SIC 2007 | SIC 2003 | Check with the regulator |
| Terminology | Hazardous waste | Hazardous waste | Special waste in Scotland |
| Codes and notification | Consignment note code you create | Premises code plus consignment note | Unique codes through SEPA, purchased-code system through NIEA |
In England the consignment note code you create follows a set format: six characters then a forward slash then five more. The first six are taken from the name of your organisation, using letters and numbers only, and the final five are yours to choose provided they are letters or numbers. It looks trivial and it is the field most often filled in wrongly, usually because someone reuses last quarter code rather than issuing a new one.
What Goes on the Note
- EWC codes for each waste, at the right level of specificity
- Hazard property codes, the HP series, identifying what the hazard actually is
- Recovery or disposal codes for the intended treatment
- SIC code, at the year applicable in that nation
- UN codes where the load moves under dangerous goods carriage rules
- Quantity, containment, and full details of producer, carrier and consignee
Before you sign, check the consignee actually holds a permit or exemption covering the waste you are sending. A permitted site is not permitted for everything, and sending waste a site cannot lawfully accept is your problem as much as theirs.
Producer Returns: The Records Nobody Chases
Consignees also submit quarterly returns to the regulator, to the Environment Agency in England or Natural Resources Wales in Wales, and pay a fee per consignment. That is their obligation rather than yours. The one that matters to you is the return sent back to you as producer.
In practice these go unrequested for years. If they are not arriving, ask in writing, because without them your file shows waste leaving the building and nothing at all about what happened next. That is a thin position in front of an auditor and an even thinner one if a site is later investigated.
The reason to care is the same reason the paperwork exists. Under the duty of care your responsibility does not end at the loading bay, and a producer return is the cheapest evidence available that it was discharged properly.
Mixing, and Why a Clearance Tempts It
The classic version is a single cage for the ceiling strip: tubes, emergency lighting batteries and general fittings together. That one cage now contains at least two hazardous streams and a quantity of ordinary waste, and it cannot lawfully be described on any document.
Separation has to happen at source, on the floor, as items come down. It cannot be reconstructed at the transfer station, and any description written afterwards to fit what arrived is a description of something that did not happen.
Retention, and What Digital Tracking Changes
The Digital Waste Tracking (England) Regulations 2026 come into force on 1 October 2026 and cover the information currently held on consignment notes as well as transfer notes. As with the non-hazardous side, the first phase binds permitted receiving sites rather than producers. Carriers, brokers and dealers follow in October 2027, and Scotland begins in January 2027.
Your obligation to consign hazardous waste correctly is unchanged in the meantime, and existing paper notes remain the evidence for past movements through their full three year retention. What is worth asking now is whether the sites treating your hazardous streams are registered on the service, since those are the sites whose records will be visible to the regulator first. The waste transfer note guide sets out the full timetable.
When This Is Not Your Problem
Equally, some hazardous streams belong to a specialist rather than to a relocation contractor. Asbestos is licensed work. Pressurised systems, refrigerants and anything requiring dangerous goods carriage sit with carriers holding the right approvals. We do not transport hazardous substances, and any clearance we run is planned so those streams are handled by the appropriate specialist alongside us rather than by us.
And if you are the incoming tenant, the hazardous streams from the previous fit-out are the outgoing party obligation. What you want is confirmation the consignments happened, not their notes.
Questions We Are Asked
What is a waste consignment note?
The statutory document that must accompany every movement of hazardous waste, replacing the duty of care transfer note used for non-hazardous waste. It travels with the load in a three part set covering the producer, the carrier and the consignee.
How do I complete a consignment note?
Complete the consignor sections before collection, with the waste description, EWC codes, hazard property codes, intended recovery or disposal codes, SIC code, quantity and containment, plus full details of all three parties. Your contractor will usually assist, but responsibility for the consignor sections is yours.
How long do I need to keep hazardous waste consignment notes?
Three years, which is a year longer than the two years required for non-hazardous waste transfer notes. Keep the producer returns with them.
How do I write a consignment note code?
In England you create one yourself in a set format: six characters drawn from your organisation name, a forward slash, then five characters of your choosing. Letters and numbers only, no symbols or spaces. Wales uses a premises code instead, issued on registration.
Does one note cover a whole clearance?
Only where the same hazardous waste goes to the same consignee via the same carrier. Different streams need separate consigning, and mixing them into one container to avoid that is an offence.
Finding the Hazardous Items Before the Clearance Starts
Almost every problem described here is created at survey stage rather than on the day. If the hazardous items were identified when the building was walked, the consigning is straightforward. If they were not, they surface halfway through a strip and someone makes a decision about a cage under time pressure.
Our office clearance and IT asset disposal services are scoped around separating streams at source. Talk to us about a survey and we will identify which of your streams need consigning and which specialist handles them.