EWC Codes Explained: How to Classify Your Waste Correctly

Every waste transfer note completed in the UK must include a European Waste Catalogue (EWC) code. Yet for many businesses, selecting the right 6-digit code is the least understood part of the waste transfer note process. This guide explains what EWC codes are, how they are structured, how to find the right one for your waste, what mirror entries mean, and what happens when the wrong code is used, with specific reference to the most common codes for commercial and construction waste.

What Are EWC Codes?

The European Waste Catalogue (EWC) is a harmonised classification system for waste, originally established by Commission Decision 2000/532/EC and subsequently consolidated. Following the UK's departure from the EU, the EWC has been retained in domestic law through the List of Wastes (England) Regulations 2005 (SI 2005/895) and equivalent Scottish and Welsh instruments, as modified and retained under the European Union (Withdrawal) Act 2018.

EWC codes are 6-digit hierarchical identifiers that classify every type of controlled waste. They are used across all waste documentation in the UK:

Waste transfer notes (WTNs), for non-hazardous controlled waste
Consignment notes, for hazardous waste under the Hazardous Waste (England and Wales) Regulations 2005
Waste return forms submitted to the Environment Agency
Environmental permit applications and compliance returns

Using the correct EWC code is a legal requirement, not an optional best practice. Under the Duty of Care Code of Practice (2016), the waste description on a WTN must include the EWC code, and that code must accurately reflect the waste being transferred. An incorrect code can invalidate a WTN, expose both parties to enforcement action, and, where hazardous waste is misclassified as non-hazardous, constitute a serious criminal offence.

Legal requirement: EWC codes must appear on every waste transfer note and consignment note. The code must accurately reflect the waste being transferred. This obligation flows from the Environmental Protection (Duty of Care) Regulations 1991 (SI 1991/2839) and the Hazardous Waste (England and Wales) Regulations 2005 (SI 2005/894).

The Structure of EWC Codes

EWC codes are organised into a three-tier hierarchy: chapters, sub-chapters, and individual waste codes. There are 20 chapters, each representing a broad category of waste origin or type.

The 20 Chapters

The chapters range from Chapter 01 (wastes from exploration, mining, quarrying, physical and chemical treatment of minerals) to Chapter 20 (municipal wastes, including separately collected fractions). The chapter relevant to your waste is determined by the origin or activity that produced it, not by the material alone. This is an important point: the same material, say, wood, may be classified under Chapter 03 (wastes from wood processing), Chapter 17 (construction and demolition waste), or Chapter 20 (municipal waste), depending on where it comes from.

Sub-Chapters (4-digit level)

Within each chapter, sub-chapters narrow the classification by material type or specific process. For example, within Chapter 17 (Construction and demolition wastes):

17 01, Concrete, bricks, tiles and ceramics
17 02, Wood, glass and plastic
17 03, Bituminous mixtures, coal tar and tarred products
17 04, Metals (including their alloys)
17 05, Soil (including excavated soil from contaminated sites), stones and dredging spoil
17 06, Insulation materials and asbestos-containing construction materials
17 08, Gypsum-based construction material
17 09, Other construction and demolition wastes

Individual Waste Codes (6-digit level)

The 6-digit code identifies the specific waste type within its sub-chapter. Continuing the example above:

17 01 01, Concrete
17 01 02, Bricks
17 01 03, Tiles and ceramics
17 01 07, Mixtures of concrete, bricks, tiles and ceramics other than those mentioned in 17 01 06 (non-hazardous)

The process for finding the right code is therefore: identify the broad origin of the waste (chapter) → narrow by material type (sub-chapter) → select the specific 6-digit code → check whether a mirror entry applies.

Finding the Right Code

The EA's technical guidance document WM3, "Classifying and Assessing Waste", is the authoritative reference for waste classification in England. It sets out the methodology for applying EWC codes, including how to handle complex or mixed waste streams, and when laboratory analysis may be required to confirm classification.

The step-by-step process for any waste type:

Identify the source activity: what process or activity produced the waste? A construction site, a food production facility, an office? This determines your chapter.
Identify the material type: what is the waste made of? This determines your sub-chapter.
Select the 6-digit code: find the specific code within your sub-chapter that most accurately describes the waste. If no specific code exactly matches, use the catch-all code for that sub-chapter (usually ending in 99 or 04).
Check for mirror entries: does your chosen code have a hazardous (*) equivalent? If so, assess whether your waste contains the dangerous substances referenced. If it does, the hazardous code applies.
Document your decision: where there is any ambiguity, document why you selected the code you did. This is particularly important for mirror entries where an assessment was required.

Mirror Entries: Hazardous or Non-Hazardous?

Mirror entries are pairs of EWC codes, one for the hazardous version of a waste, one for the non-hazardous version, that cover the same broad waste type. The hazardous version is marked with an asterisk (*). Whether the hazardous or non-hazardous code applies depends on whether the specific waste contains particular dangerous substances.

Common examples of mirror entries relevant to construction waste:

17 01 06* (mixtures of concrete, bricks and tiles containing dangerous substances) vs 17 01 07 (mixtures not containing dangerous substances)
17 05 03* (soil and stones containing dangerous substances) vs 17 05 04 (soil and stones other than those mentioned in 17 05 03)
17 09 03* (other construction and demolition waste containing dangerous substances) vs 17 09 04 (mixed construction and demolition waste not containing dangerous substances)

For a mirror entry, you must make an assessment of whether the waste contains the dangerous substances described. This assessment may be based on:

Knowledge of the process that produced the waste (e.g., soil from a site with known contamination history)
Visual inspection (e.g., presence of tar, asbestos fibres, or chemical contamination)
Material safety data sheets or site records
Laboratory analysis (required for uncertain cases, particularly contaminated soil)

Warning: If you select a non-hazardous EWC code (no asterisk) for waste that should be classified as hazardous (asterisk code), the waste will move on a WTN rather than a consignment note. This is a criminal offence under Regulation 19 of the Hazardous Waste (England and Wales) Regulations 2005, exposing both the producer and carrier to prosecution and unlimited fines.

Common EWC Codes for Commercial Waste

The following codes are used most frequently by offices, retail businesses, food businesses, and other commercial premises in the UK:

20 01 01, Paper and cardboard
20 01 02, Glass
20 01 08, Biodegradable kitchen and canteen waste (food waste)
20 01 10, Clothes
20 01 11, Textiles
20 01 21*, Fluorescent tubes and other mercury-containing waste (HAZARDOUS)
20 01 25, Edible oil
20 01 33*, Batteries and accumulators specified in 16 06 01, 16 06 02 or 16 06 03 (HAZARDOUS)
20 01 35*, Discarded electrical and electronic equipment other than those mentioned in 20 01 21 and 20 01 23 containing hazardous components (HAZARDOUS)
20 01 36, Discarded electrical and electronic equipment other than those mentioned in 20 01 21, 20 01 23 and 20 01 35
20 01 39, Plastics
20 03 01, Mixed municipal waste (the catch-all for general commercial waste)
20 03 04, Septic tank sludge

Note that Chapter 20 codes are specifically for waste with a municipal character, commercial premises producing waste similar to household waste in nature. Manufacturing, processing, and industrial businesses will generally use codes from the chapter specific to their industry activity.

Common EWC Codes for Construction and Demolition Waste

Construction, demolition, and refurbishment projects generate some of the largest volumes of controlled waste in the UK. The following Chapter 17 codes cover most common construction waste streams:

17 01 01, Concrete
17 01 02, Bricks
17 01 03, Tiles and ceramics
17 01 07, Mixtures of concrete, bricks, tiles and ceramics (non-hazardous)
17 02 01, Wood (timber)
17 02 02, Glass
17 02 03, Plastics
17 03 02, Bituminous mixtures other than those mentioned in 17 03 01 (non-hazardous)
17 04 01, Copper, bronze, brass
17 04 05, Iron and steel
17 04 07, Mixed metals
17 05 04, Soil and stones other than those mentioned in 17 05 03 (non-hazardous)
17 06 05*, Construction materials containing asbestos, ALWAYS HAZARDOUS
17 08 02, Gypsum-based construction materials other than those mentioned in 17 08 01 (plasterboard, non-hazardous)
17 09 04, Mixed construction and demolition wastes other than those mentioned in 17 09 01, 17 09 02 and 17 09 03 (non-hazardous)

A critical point for construction waste: 17 06 05* (construction materials containing asbestos) is always hazardous, there is no non-hazardous mirror entry for asbestos-containing materials. Any material containing asbestos, however small the quantity, must be classified as hazardous waste and handled under the full hazardous waste consignment note regime.

Key point: 17 09 04 (mixed construction and demolition waste) is a commonly used catch-all for mixed C&D waste on sites, but it only applies where the waste genuinely contains no hazardous substances. If contaminated material (soil with hydrocarbons, asbestos fragments, old paint containing lead) is mixed in, the correct code may be 17 09 03*, and the waste must be handled as hazardous.

What Happens If You Use the Wrong Code?

EWC code errors are a known enforcement priority for the Environment Agency. Regulatory officers carry EWC code references and routinely cross-check waste descriptions on WTNs against the codes recorded. Inconsistencies between the description and the code, for example, a WTN describing "construction rubble" but coded as 20 03 01 (mixed municipal waste), are an immediate red flag.

The consequences of using the wrong EWC code range from administrative to criminal:

Invalid WTN: if the EWC code does not reflect the actual waste, the WTN does not accurately describe the transfer and may be treated as invalid, leaving both parties without a compliant record for that transfer.
Waste going to an inappropriate site: environmental permits specify which EWC codes a site is authorised to receive. If waste arrives at a facility with the wrong EWC code on the WTN, it may be accepted on the basis of a code the facility is permitted for, when actually the waste is something the facility should not be accepting. This can lead to enforcement action against the receiving facility and the producer.
Hazardous waste moved on a WTN: the most serious case. If waste is hazardous (asterisk code) but is moved on a standard WTN using a non-hazardous code, this is an offence under Regulation 19(1) of the Hazardous Waste (England and Wales) Regulations 2005. Both the consignor and carrier can be prosecuted. The penalty is an unlimited fine on conviction.

For more on what constitutes controlled waste versus special/hazardous waste, and how the classification decisions interact with your documentation obligations, see our article oncontrolled waste vs special waste and our complete guide to what is a waste transfer note.

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Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific legal guidance, consult a qualified environmental law solicitor.