Season Tickets for Waste Transfers: What Are They and When to Use Them

What Is a Season Ticket for Waste Transfers?

A season ticket, also widely called an annual waste transfer note, a standing order WTN, or a period WTN, is a single written document that covers multiple transfers of the same type of waste between the same two parties over a period of up to 12 months. Instead of completing a separate Waste Transfer Note for every individual collection, both the waste producer and the waste carrier agree a single document that governs all collections during the agreed period.

For businesses with regular, recurring waste collections, weekly skip collections, fortnightly commercial refuse lifts, monthly trade waste pick-ups, a season ticket dramatically reduces paperwork without sacrificing any legal protection. When properly completed, it is fully equivalent to a stack of individual WTNs for every collection during the period.

The season ticket concept is widely used in practice but is not always well understood. Many businesses use them without realising they have specific legal requirements, or without appreciating the circumstances in which they cannot be used. This guide covers everything you need to know.

Legal Basis for Season Tickets

The legal basis for season tickets is the Environmental Protection (Duty of Care) Regulations 1991 (SI 1991/2839), as amended. Regulation 2 of those Regulations, read together with the DEFRA Duty of Care Code of Practice (2016), permits parties to an ongoing waste transfer arrangement to complete a single written document covering a period of up to 12 months, provided:

• The same type of waste will be transferred on each occasion
• The same parties (transferor and transferee) will be involved throughout
• The document contains all the information required by the Regulations for each individual transfer, plus the period and frequency

The term "season ticket" does not appear in the statute, it is a colloquial term that has become universally understood in waste management practice. The Regulations simply allow for a "written description" document to cover multiple transfers, and the season ticket is the industry's name for this arrangement.

The underlying duty of care obligations under section 34 of the Environmental Protection Act 1990 apply equally to season ticket arrangements as to individual WTNs. A season ticket does not reduce or waive any element of the duty of care; it simply satisfies the written documentation requirement more efficiently for recurring transfers.

When Can You Use a Season Ticket?

A season ticket can be used when all of the following conditions are met:

Same Waste Description on Every Transfer

The waste being transferred must be of the same type and character on every occasion covered by the season ticket. The description on the season ticket must accurately describe the waste that will be transferred throughout the period. If the waste type changes, for example, if a business starts producing a different type of packaging waste mid-year, the existing season ticket cannot cover the new waste type. A new or amended season ticket, or individual WTNs for the different waste, will be required.

Same Transferor and Transferee

The season ticket covers a specific relationship between a specific transferor and a specific transferee. It cannot be used if either party changes. If you change your waste carrier, you need a new season ticket with the new carrier (or individual WTNs until one is set up).

Regular and Predictable Pattern of Transfers

Season tickets work best where transfers follow a regular, predictable schedule, weekly, fortnightly, monthly. The season ticket must state the anticipated frequency of collections. Transfers that are genuinely irregular and unpredictable are harder to accommodate within a season ticket framework.

Both Parties Agree

A season ticket is a mutual agreement between the transferor and the transferee. Both parties must sign it. It cannot be imposed unilaterally.

Duration and Validity

A season ticket can cover a maximum period of 12 months. The document must specify:

• A clear start date
• A clear end date (which must be no more than 12 months after the start date)

The season ticket automatically expires on the stated end date. It does not auto-renew. If transfers are continuing after the end date, a new season ticket must be signed and dated before the old one expires, or individual WTNs must be used for any transfers that occur after expiry.

A season ticket can be for any period up to 12 months, it does not have to be exactly 12 months. A six-month season ticket is equally valid. Some businesses choose shorter periods to allow for regular review of the arrangement and to reduce the risk of the season ticket becoming inaccurate as circumstances change.

What Must a Season Ticket Include?

A valid season ticket must contain all the same information required on an individual WTN, plus additional information specific to the seasonal arrangement:

Standard WTN Information (Required on Every Season Ticket)

• Waste description, an accurate written description of the waste covered by the season ticket, specific enough to allow appropriate handling and disposal. Must include the relevant EWC/LoW code(s)
• Quantity indication, an indication of the typical quantity per transfer (even if this varies somewhat, an expected range should be stated)
• Container type, the type of container or containment method typically used for these transfers
• Place of transfer, the address(es) from which waste is typically collected
• Transferor details, full business name, address, contact details, and SIC code
• Transferee details, full business name, address, and registration number (CBDU/CBDL or environmental permit/exemption number)
• Signatures of both parties, both the transferor and the transferee must sign the season ticket before it takes effect

Additional Season Ticket-Specific Information

• Start date and end date, the period covered by the season ticket (maximum 12 months)
• Anticipated frequency of collections, e.g. "weekly every Monday", "fortnightly on the first and third Friday of each month", "monthly on the last working day of each month". This should be as specific as practicable

Even with a valid season ticket in place, both parties are advised to maintain their own internal records of each individual collection, the date, the actual quantity collected, any variations from the standard description. These records are not legally mandated for season ticket arrangements, but they demonstrate good compliance practice and assist in any investigation or dispute.

When You Cannot Use a Season Ticket

A season ticket is not appropriate in the following situations:

• One-off or genuinely irregular transfers, if the transfer is a single occurrence or irregular enough that a start/end date and frequency cannot meaningfully be stated, an individual WTN is required
• Changing waste types, if the waste you produce varies significantly from collection to collection (e.g. sometimes general office waste, sometimes hazardous waste), a season ticket cannot cover all of these. Use individual WTNs or multiple season tickets, each covering one stable waste type
• Change of carrier or receiving facility, if your carrier changes, the season ticket with the old carrier no longer applies. You need either a new season ticket with the new carrier or individual WTNs in the interim
• Hazardous waste, hazardous waste (waste with an asterisk EWC code, as classified under the Hazardous Waste (England and Wales) Regulations 2005) requires a consignment note for each individual movement. Season tickets cannot substitute for consignment notes in the hazardous waste regime. Each hazardous waste consignment must be individually documented and notified
• Where the receiving facility or destination changes, the season ticket records where waste is going. If the disposal or treatment facility changes mid-period, the season ticket may not accurately record the destination, which could be a problem if the waste is traced

Pros and Cons vs Individual Notes

Season tickets and individual WTNs each have their place. The choice depends on the regularity and consistency of your waste transfers.

Advantages of Season Tickets

• Significant reduction in paperwork, a single document covers a year of collections instead of 52 individual WTNs (for weekly collections)
• Lower risk of missing individual transfers, with a season ticket in place, the documentation risk shifts from "did we complete a note this week?" to "do we have a valid season ticket and is it current?"
• Easier to manage, a single document to store and retrieve, rather than a large volume of individual notes
• Formalises the commercial relationship, a season ticket between a business and its waste carrier is a clear, documented arrangement that both parties have committed to
• Ideal for regular commercial relationships, skip hire companies that collect from the same customer every month, waste contractors with scheduled collection routes, and similar arrangements are well suited to season tickets

Disadvantages and Risks of Season Tickets

• No automatic updating, if anything changes (carrier, waste type, address), you must issue a new season ticket or revert to individual WTNs. The old season ticket does not automatically adapt
• Does not record individual collection details, a season ticket does not, by itself, record the date, time, and actual quantity of each individual collection. Good compliance practice requires supplementary records of actual collections
• Expiry risk, if the season ticket expires and no one notices, transfers may occur without valid documentation until a new one is signed
• Inappropriate for variable or one-off waste, businesses with variable waste outputs may find individual WTNs give a more accurate record of actual transfers

Record-Keeping Requirements for Season Tickets

Both the transferor and the transferee must retain a copy of the season ticket for a minimum of two years from the end date of the season ticket period, not two years from when it was signed.

For example, if a season ticket runs from 1 January 2026 to 31 December 2026, both parties must retain the document until at least 31 December 2028. This is a longer effective retention period than it might initially appear, because the clock starts running from the end of the period rather than the start.

As with individual WTNs, records can be kept in any format, paper or digital, provided they can be produced for inspection by the Environment Agency or another waste regulation authority on request.

For more on WTN documentation requirements, see our main guide on what is a waste transfer note. For industry-specific guidance on season tickets in skip hire contexts, see our article on WTNs for skip hire companies.