Waste transfer notes: required for every transfer of non-hazardous business waste under EPA 1990 s34. Keep them 2 years, 3 for hazardous consignment notes. Digital waste tracking starts 1 October 2026.
Every time non-hazardous waste leaves your premises, the transfer has to be documented and both sides have to keep a copy. That obligation sits with you as the producer, and it does not transfer to the contractor who drives away with the load.
Most guidance on this is written for a weekly bin collection. A site clearance behaves differently. Several waste streams leave one building in a single day, each with its own description, its own destination, and in some cases a different document entirely. That is where the paperwork tends to fail.
The short version:
- A waste transfer note covers non-hazardous waste. Hazardous waste needs a consignment note instead
- Keep transfer notes for two years, consignment notes for three
- The producer keeps the duty of care whatever the contractor says
- A season ticket covers repeat collections, but rarely survives a clearance
- From 1 October 2026, digital waste tracking begins replacing the paper system, starting with the sites that receive waste
What the Law Requires When Waste Leaves a Site
The duty follows the waste. If material from your building is later found fly-tipped, the fact that a contractor took it away is not a defence. What protects you is a record showing the waste went to an authorised person and an authorised facility.
The practical requirements sit in the Waste (England and Wales) Regulations 2011, which carried the duty of care regime forward. Two obligations matter most on a clearance: waste goes only to a registered carrier, and every transfer is covered by a valid document describing the waste well enough for the next person to handle it lawfully.
Enforcement is not theoretical. Local authorities and the Environment Agency can request records on the spot, and failure to produce them is itself an offence, carrying a fixed penalty notice or, on conviction, an unlimited fine.
What Has to Be on the Document
| Element | What it means in practice |
|---|---|
| Waste description | Enough detail for the next handler to deal with it safely. Office waste is not a description. |
| EWC code | The European Waste Catalogue code for that stream. Confirm it per load rather than reusing the last one. |
| How it is contained | Loose, bagged, caged, in a skip, palletised. |
| Quantity | Weight, volume, or a container count. |
| SIC 2007 code | The industry code for the producer. |
| Waste hierarchy declaration | A statement that the hierarchy was applied, meaning reuse and recycling were considered before disposal. |
| Transferor details | Your name, address, and confirmation that you are the producer. |
| Transferee details | Their name, address, and carrier registration or permit reference. |
| Broker or dealer details | Registration details, where one arranged the transfer. |
| Place, date and time | Where and when the transfer happened. |
| Signatures | Both parties. |
The two most commonly missed are the waste hierarchy declaration and the carrier registration number. The second is worth checking rather than accepting, because a carrier registration can be verified on the Environment Agency public register before the vehicle arrives.
A Template You Can Copy
| SECTION A. DESCRIPTION OF THE WASTE | |
| Description of waste What it is, its physical form, relevant properties | |
| EWC code Six-digit European Waste Catalogue code | |
| How it is contained Loose, bagged, caged, skip or palletised | |
| Quantity Weight, volume or number of containers | |
| Waste hierarchy applied Confirm reuse and recycling were considered before disposal | |
| SECTION B. TRANSFEROR, MEANING YOU | |
| Transferor name and address The producer of the waste | |
| Transferor SIC 2007 code Industry classification code | |
| Transferor status Producer or holder | |
| SECTION C. TRANSFEREE, MEANING THE CARRIER | |
| Transferee name and address Who is taking the waste | |
| Carrier registration number Verify on the Environment Agency public register | |
| Permit or exemption reference Where the transferee holds one | |
| Broker or dealer details Only if one arranged the transfer | |
| SECTION D. THE TRANSFER ITSELF | |
| Address of transfer Where the waste changed hands | |
| Date of transfer | |
| Time of transfer | |
| Transferor signature and name | |
| Transferee signature and name | |
Both parties sign, both parties keep a copy, and both copies are retained for two years. If the waste is hazardous, this is the wrong document and a consignment note is required instead.
Non-Hazardous and Hazardous Are Two Different Documents
This catches people out on clearances specifically, because an office produces more hazardous waste than most occupiers realise. Fluorescent tubes, certain batteries, some display screen equipment and a range of electrical items fall into hazardous classifications. Putting them on a standard transfer note does not make them non-hazardous.
In Scotland the equivalent is a special waste consignment note, and every consignment carries a unique code obtained through SEPA. Northern Ireland operates a comparable purchased-code system through the NIEA. If you are clearing sites across borders, the documentation is not interchangeable.
Why a Clearance Produces Several Streams, Not One
We cross-referenced the streams a typical office clearance produces against the documentation each one requires. No published guide sets these out together, because most are written from the perspective of a bin round rather than a building being emptied.
| Stream | Typical route | Document | Retention |
|---|---|---|---|
| Serviceable furniture | Redeployment, donation or resale. Not waste at all if genuinely reused | None if reused. Keep donation and redeployment records | Your own policy |
| Non-serviceable furniture | Recycling or recovery | Waste transfer note | 2 years |
| Non-hazardous WEEE | Licensed treatment facility | Waste transfer note | 2 years |
| Hazardous WEEE and lamps | Specialist treatment | Consignment note | 3 years |
| Data-bearing IT | Certified destruction before the hardware becomes waste | Certificate of destruction, then transfer or consignment note as classified | Per your retention policy |
| Confidential paper | Secure shredding | Destruction certificate plus transfer note | 2 years |
| General and mixed | Transfer station | Waste transfer note | 2 years |
Two consequences worth drawing out.
First, the furniture row. Reused furniture is not waste, so it produces no transfer note, which means an unbroken set of notes does not prove good outcomes. It proves the opposite, that everything was disposed of. If reuse matters to your reporting, the evidence is donation records and redeployment logs, not the waste file. Our office furniture disposal and reuse page covers how that is recorded.
Second, the data-bearing row runs on a different clock. Under Article 5(1)(f) of the UK GDPR your confidentiality obligation persists for as long as data is recoverable, which includes after the device has left the building. The transfer note evidences the waste duty. It does not evidence the data duty. Those are two separate records and auditors ask for both. See IT asset disposal and office clearances for how the streams are separated at source.
Season Tickets and Why They Rarely Fit a Move
The waste type, the carrier and the other recorded details must stay the same for the duration. Change any of them and you need a new season ticket, or a single transfer note for that movement.
A clearance changes all of them at once. The waste type shifts from general office waste to furniture, then to WEEE. The carrier may differ by stream. The collection point may move from a loading bay to a floor.
Where a season ticket is already in place and the site is being cleared, the safer position is single notes for the clearance movements, keeping the ticket for the routine waste that continues until the last day. You will also need a schedule listing each individual transfer, which can sit on a spreadsheet or in invoicing records, and it is kept for two years after the final transfer alongside the ticket itself.
How Long to Keep Records, and Who Asks
Enforcement officers from the local authority or the Environment Agency can ask at any point in that window. So, increasingly, can other people. A landlord surveyor assembling a dilapidations position. A client ESG team compiling a Scope 3 return. A procurement team auditing a social value commitment made at tender.
That last group is the reason to organise the file by project rather than by month. A clearance file that can be handed over whole is worth considerably more than a chronological archive that has to be reassembled two years later. Where records themselves need storing against retention dates, our document storage service covers it.
Digital Tracking: What Changes From October 2026
Some coverage currently claims the paper waste transfer note disappears in October 2026. For waste producers, that is not correct, and the distinction changes what you need to do this year.
Phase one obligations sit with the sites that receive waste: transfer stations, recycling facilities, treatment sites. If you are an office occupier clearing a building, you are not in phase one. Your duty of care is unchanged and the documentation you rely on today continues to apply. Existing paper notes also stay valid as evidence for past movements, for the full two or three year retention period.
What does change is who you should be asking questions of. Receiving sites must record specified information for every load, normally by the end of the second working day after receipt, with a fixed penalty for failures. Regulation 5 sets the fee at 26 pounds a year for each legal entity creating or editing records. Carriers join in October 2027. A contractor who has not registered by their phase is a contractor whose chain of evidence will have a gap in it.
The timeline is worth treating with some caution even now. Mandatory tracking was originally set for April 2025, deferred to April 2026, and then to October 2026. The regulations are approved, but the rollout has moved before.
The practical step now: when you next appoint a clearance contractor, ask which of their destination sites are registered on the service and what their plan is for the carrier phase. That question costs nothing and tells you a great deal.
When This Does Not Apply to You
Equally, if furniture is genuinely being redeployed to another of your own sites, that movement is not a waste transfer and needs no note. Treating it as one creates a record suggesting you disposed of assets you actually kept, which is the opposite of what you want in a social value or ESG return.
And if you are the incoming tenant rather than the outgoing one, the clearance documentation is the outgoing party obligation. What you want from them is confirmation it happened, not copies of their notes.
Questions We Are Asked
What should be on a waste transfer note?
A description of the waste, its EWC code, how it is contained, the quantity, your SIC code, a waste hierarchy declaration, full details of both parties including the carrier registration number, the place, date and time of transfer, and signatures from both sides.
Can I make my own?
Yes. There is no obligation to use the GOV.UK template. An invoice or delivery receipt is acceptable provided it contains every required element. The content is what the regulator checks.
How long should you keep one?
Two years from the date of transfer for non-hazardous waste. Three years for hazardous waste consignment notes. Paper or electronic both count, but you must be able to produce them on request.
Do you need one for food waste?
Yes. Food waste is controlled waste and a transfer is a transfer. Separate collection obligations may also apply depending on your nation and premises type.
Does the contractor copy cover me?
No. Both parties keep their own copy and both can be asked for it. If a contractor holds the only record, you cannot discharge your duty of care without them.
Getting the Documentation Right on a Clearance
The paperwork is not the difficult part of a site clearance. Separating the streams at source is, and the documentation simply follows whatever separation actually happened. Where clearances go wrong on evidence, it is almost always because everything was loaded together and the description was written afterwards to fit.
If you have a building to clear and want the file to hold up, talk to us about a survey. We will set out which streams your site is likely to produce and what documentation each one generates.