Waste Transfer Notes

The need for a written description of a waste to accompany every waste movement so that the person receiving it knows what it is and can deal with it appropriately has been one of the four fundamental duties of the Waste Duty of Care since it was introduced into legislation in s.34 of the Environmental Protection Act 1990. Over the years, this gradually evolved into a requirement for (in England and Wales) a “Waste Transfer Note” or “WTN”.

WTN 500Detailed requirements for the content of a WTN were brought up to date in Regulation 35 of The Waste (England & Wales) Regulations 2011 (SI 2011/988), all of which was incorporated onto the standard form produced by the Environment Agency and readily available online. However, the use of this form was not mandatory providing that any alternative WTN form contained all of the information required by Regulation 35. This permitted larger waste companies to produce their own versions of it for issue to their customers whenever waste was collected from site.

On 6th April 2014, s.6 of the 2014 amendment to the Waste Regs (SI 2014/656) replaced “transfer note” in Regulation 35 with “written information”, permitting a much wider range of documentation than formal WTNs, such as invoices or skip exchange notes – however the need to provide all the Reg.35 information remains.

At the same time “edoc“, the “electronic Duty of Care” online waste documentation and tracking system, has come into use, permitting companies to register their waste activity online, and to register and track waste movements electronically without the need for paper documentation.

Overall, the relaxation of WTN requirements permit a far more flexible approach to proving compliance with the waste Duty of Care, but does not remove any of the obligations on waste producers to be able to demonstrate and document compliance with the Duty if challenged by the Regulators, including provision of all the information required by Regulation 35 that would previously have been documented on a formal Waste Transfer Note.


One Response to Waste Transfer Notes

  1. Pingback: Waste Duty of Care | bps eco ltd

%d bloggers like this: