Waste Transfer Note vs Consignment Note: What’s the Difference?

What Is a Waste Transfer Note?

A waste transfer note (WTN) is the standard legal document required every time non-hazardous controlled waste changes hands in England and Wales. The obligation comes from section 34 of the Environmental Protection Act 1990 and the Environmental Protection (Duty of Care) Regulations 1991 (as amended). If you run a skip hire business, a construction firm, a landscaping company, or any operation that produces, carries, or receives non-hazardous waste, the WTN is the document you use daily.

A compliant WTN must record: a description of the waste, the EWC code, the quantity transferred, the date and time of transfer, details of the transferor and transferee (including waste carrier registration numbers), the place of transfer, and the type of container. Both parties, the person handing over the waste and the person receiving it, must sign the note or otherwise confirm the transfer.

WTNs must be retained for a minimum of two years from the date of the transfer. They can be in paper or digital format. For regular, recurring transfers of the same waste type between the same parties, a season ticket (a single WTN covering multiple transfers over a period of up to 12 months) can be used instead of individual notes for each load.

What Is a Consignment Note?

A consignment note (CN) is the legal document required for the movement of hazardous waste in England and Wales. It is governed by the Hazardous Waste (England and Wales) Regulations 2005 (SI 2005/894), specifically Schedule 2, and carries significantly more detailed requirements than a standard WTN.

Hazardous waste is any waste classified as hazardous under the List of Wastes (the UK's retained version of EU Commission Decision 2000/532/EC). Waste types marked with an asterisk (*) in the List of Wastes are either absolute hazardous entries (always hazardous) or mirror hazardous entries (hazardous if the waste exhibits one or more of the 15 hazard properties, HP1 to HP15). Examples include asbestos (17 06 05*), waste oil (13 02 05*), solvents (14 06 01*), and fluorescent tubes (20 01 21*).

A consignment note must record significantly more information than a WTN, including:

• Full details of the consignor (the producer or holder of the waste), including their premises code where applicable
• Full details of the carrier, including their waste carrier registration number and a declaration that they are authorised to carry the specific waste type
• Full details of the consignee (the receiving facility), including their environmental permit number
• The EWC code (which must be a hazardous code, i.e., an asterisk entry), the hazard properties (HP codes) exhibited by the waste, and any applicable UN classification for transport
• The quantity of waste in tonnes or kilograms
• The type and number of containers
• Special handling requirements

The consignment note has a multi-part structure. After the waste arrives at the receiving facility, the consignee must return a completed copy to the consignor within 72 hours, confirming receipt. All parties (consignor, carrier, and consignee) must retain their copies for a minimum of three years from the date of the movement.

Key Differences at a Glance

The following table summarises the core differences between waste transfer notes and consignment notes:

When You Need a Waste Transfer Note

A WTN is required for every transfer of non-hazardous controlled waste. This covers the vast majority of commercial and industrial waste movements in England and Wales: general construction waste, office waste, garden waste, scrap metal, non-hazardous skip waste, and similar materials.

Specifically, you need a WTN when:

• A business produces non-hazardous waste and hands it to a waste carrier for removal
• A waste carrier delivers non-hazardous waste to a permitted treatment, recovery, or disposal facility
• Non-hazardous waste changes hands between any two parties in the waste chain (e.g., from a broker to a carrier, or from one carrier to another)
• A householder hands waste to a business (the business needs a WTN for its duty-of-care records, although the householder themselves is exempt from the duty of care)

The WTN applies to all waste that is classified as controlled waste under the Environmental Protection Act 1990, which includes household, commercial, and industrial waste, but not agricultural waste from agricultural premises (which is separately regulated) or specific excluded waste categories such as certain mining wastes.

When You Need a Consignment Note

A consignment note is required whenever hazardous waste is removed from the premises where it was produced or is transferred between parties. The trigger is the waste classification, not the quantity. Even a single fluorescent tube, if removed from business premises by a waste carrier, legally requires a consignment note.

You need a consignment note when:

• Any waste classified as hazardous under the List of Wastes is removed from the premises where it was produced
• A waste carrier collects hazardous waste from any non-domestic premises
• Hazardous waste is transferred between a carrier and a permitted treatment or disposal facility
• Hazardous waste is moved between different premises of the same company (the internal transfer still constitutes a "movement" under the Regulations)

Common Hazardous Waste Scenarios

Many businesses encounter hazardous waste more often than they realise. The following are the most common scenarios where a consignment note is required instead of a standard WTN:

• Asbestos removal (EWC 17 06 05*): All asbestos-containing materials are absolute hazardous waste, regardless of the type of asbestos or its condition. Licensed asbestos removal contractors must use consignment notes. The waste must go to a facility specifically permitted to accept asbestos.
• Fluorescent tubes and lamps (EWC 20 01 21*): These contain mercury and are classified as hazardous. Offices, retail premises, and industrial units routinely produce this waste when replacing lighting. A consignment note is required for each collection.
• Contaminated soil (EWC 17 05 03*): Excavated soil from sites with historical contamination (e.g., former petrol stations, industrial land, gas works) is hazardous if it contains dangerous substances above threshold concentrations. Construction and demolition contractors frequently encounter this.
• Waste oil (EWC 13 02 05*, 13 02 06*): Engine oil, hydraulic fluid, gear oil, and other mineral oils from vehicle maintenance, machinery servicing, and industrial processes are hazardous. Garages, haulage companies, and manufacturing businesses produce this regularly.
• Solvents (EWC 14 06 01* and related codes): Cleaning solvents, degreasers, thinners, and other organic solvents are typically hazardous due to flammability (HP3) and toxicity (HP6). Common in painting and decorating, manufacturing, and vehicle repair.
• Lead-acid batteries (EWC 20 01 33*): Car batteries, forklift batteries, and UPS batteries contain lead and sulphuric acid. Vehicle workshops, warehouses, and data centres produce these.
• Paint containing organic solvents (EWC 08 01 11*): Oil-based and solvent-based paints, lacquers, and varnishes are hazardous. Water-based paints (EWC 08 01 12) are generally non-hazardous and can use a standard WTN.
• Refrigerants and F-gases (EWC 16 05 04*): Gases from air conditioning and refrigeration units are hazardous. Their removal requires F-Gas certified engineers, and the resulting waste requires a consignment note.

Multiple Consignment Notes

Where a producer regularly sends the same type of hazardous waste to the same consignee via the same carrier, the Hazardous Waste (England and Wales) Regulations 2005 allow for a multiple consignment note. This is the hazardous waste equivalent of a season ticket for standard WTNs.

A multiple consignment note covers a series of movements over a defined period, avoiding the need to complete a separate consignment note for each individual collection. However, it must still record the specific details of each individual movement (date, quantity, and container details for each collection), and it can only be used when the waste description, EWC code, carrier, and destination remain the same across all movements.

Multiple consignment notes are commonly used by:

• Garages and workshops with regular waste oil collections
• Manufacturers with scheduled solvent waste removals
• Large office buildings with periodic fluorescent tube collections
• Hospitals and healthcare facilities with regular clinical waste (where also classified as hazardous) pickups

When You Need Both

Some waste loads require both a waste transfer note and a consignment note. This occurs when a single collection or vehicle load contains both non-hazardous and hazardous waste that must be documented separately.

Common scenarios where both documents are needed:

• Mixed construction site clearances: A skip or grab lorry collects general construction rubble (non-hazardous, requires WTN) and a separate containerised collection of asbestos materials (hazardous, requires CN) from the same site on the same visit.
• Office refurbishment: General office furniture and fittings (non-hazardous, WTN) plus fluorescent tubes and old IT equipment containing hazardous components (hazardous, CN).
• Vehicle workshop clear-out: General scrap metal and cardboard packaging (non-hazardous, WTN) plus waste oil drums and used lead-acid batteries (hazardous, CN).
• Demolition projects: The bulk of demolition waste is non-hazardous (concrete, brick, timber) and covered by WTNs, but asbestos-containing materials, lead paint waste, and contaminated soil require separate consignment notes.

In all of these cases, the hazardous and non-hazardous waste streams must be documented on their respective document types. You cannot combine them onto a single WTN, and you cannot list non-hazardous waste on a consignment note. Each waste stream, each document.

Penalties for Getting It Wrong

The penalties for using the wrong documentation, or failing to use any documentation at all, differ between the two regimes, reflecting the greater environmental and public health risks associated with hazardous waste.

WTN non-compliance:

• Failure to complete a WTN for non-hazardous waste: unlimited fine on summary conviction
• Failure to retain WTNs for two years: unlimited fine
• Providing false or misleading information on a WTN: unlimited fine and/or imprisonment
• The Environment Agency can also issue civil sanctions, including variable monetary penalties (VMPs), compliance notices, and enforcement undertakings

Consignment note non-compliance:

• Failure to complete a consignment note for hazardous waste: unlimited fine and/or up to two years imprisonment
• Failure to retain consignment notes for three years: unlimited fine and/or imprisonment
• Providing false or misleading information on a consignment note: unlimited fine and/or up to two years imprisonment
• Failure to register as a hazardous waste producer (where required): unlimited fine
• Using a standard WTN instead of a consignment note for hazardous waste: treated as failure to comply with the Hazardous Waste Regulations, carrying the same penalties
• The EA has increased enforcement activity around hazardous waste documentation in recent years, with particular focus on the construction, demolition, and vehicle maintenance sectors

Practical Steps

To ensure you are using the correct documentation for every waste movement:

1. Classify every waste stream before first collection. Check the EWC code against the List of Wastes. If the code has an asterisk, the waste is hazardous and requires a consignment note. If it is a mirror entry, assess the waste properties to determine the correct classification.
2. Maintain a waste stream register. List every waste type your business produces, with its EWC code and classification (hazardous or non-hazardous). Review this register annually or whenever your operations change.
3. Check your carrier's registration. Ensure your waste carrier is registered to carry hazardous waste if any of your waste streams are hazardous. Not all registered waste carriers are authorised for hazardous waste.
4. Use the right document for each stream. WTN for non-hazardous controlled waste. Consignment note for hazardous waste. Never combine hazardous and non-hazardous waste on the same document.
5. Store documents for the correct period. Two years for WTNs, three years for consignment notes. Digital storage is acceptable for both document types.
6. Register as a hazardous waste producer if required. If your premises produces 500 kg or more of hazardous waste in any 12-month period, you must register with the Environment Agency and include your premises code on all consignment notes.