In the last post we established that a waste transfer note is a record of a transfer between two parties, that both parties carry the duty to keep it, and — importantly — that Digital Waste Tracking doesn’t make it go away. The note still has to exist. So it’s worth knowing exactly what has to be on it, because “we did a transfer note” and “we did a compliant transfer note” are not the same thing, and the gap between them is where enforcement happens.
The note doesn’t have to be a particular form. The Environment Agency, Natural Resources Wales, SEPA and the NIEA all publish templates, but you’re free to use your own document — an invoice, an email, anything — provided it carries all the required information and is signed by both parties. What follows is that required information. Get all of it on the page and the format genuinely doesn’t matter.
The waste itself
A written description of the waste. Plain English, specific to what’s actually in the load. This is the field people are laziest about and it’s the one most likely to bite. “General waste” or “rubbish” is not a description — it tells the next holder nothing about how to handle the material safely, which is the entire point of the field. Describe what’s in it: “mixed dry recyclables — paper, card, plastic packaging” or “inert construction waste — soil, brick, concrete.” The producer is the party best placed to describe their own waste, and the responsibility to get it right sits with them, not the carrier.
The EWC code. The six-digit European Waste Catalogue code (also called the List of Waste, or LoW, code) that classifies the waste by its source and type. The description and the code work together — a correct code with a vague description still isn’t adequate, and the regulators are explicit about that. Using the wrong code is one of the most common ways a note gets invalidated. A load of mixed commercial waste is 20 03 01; the moment that same skip is filling with construction material it’s a different code entirely, typically something in chapter 17. The code has to match what’s really in the load on the day, not what the producer’s account usually carries.
The quantity. Weight or volume, plus an indication of how it’s contained — loose, bagged, in a skip, in a drum, in bulk. Number of containers if that’s how it’s measured.
The parties
Who’s handing it over and who’s receiving it — names and addresses of both. And critically, the capacity each party is acting in: producer, registered carrier, or holder of an environmental permit. If it’s a registered carrier, their carrier registration number goes on the note. If it’s a permitted site receiving it, the permit number goes on. This is the field set that lets a reader (or a regulator) confirm the waste went from someone entitled to hand it over to someone entitled to take it. Missing the carrier registration number is, alongside the EWC code, one of the two fields most commonly left off.
Both signatures. The note is signed by both parties to the transfer. Electronic signatures are fine.
The place, date and the bits people forget
Where and when the transfer happened — the address of the transfer and the date and time.
The SIC code of the transferor. This is the Standard Industrial Classification (2007) code describing the transferring business’s economic activity — not the waste, the business. It’s been a statutory requirement on controlled waste transfer notes in England and Wales since the 2011 Regulations, and the equivalent applies across the UK. You’ll find your code on the Companies House register. It’s a small field that’s very easy to omit and just as easy to include once you know yours.
A waste hierarchy declaration. A statement confirming the producer has applied the waste hierarchy — reduce, reuse, recycle, recover, dispose, in that order of preference. On a template it’s usually a tick box. It’s a genuine legal requirement under Regulation 12 of the 2011 Regulations, not decoration.
Season tickets — the bit everyone gets wrong
Here’s the one that causes the most confusion, and the most accidental non-compliance.
If you’re moving the same waste, between the same parties, under the same circumstances, repeatedly, you don’t need a fresh note for every single collection. You can use what’s universally called a season ticket: a single transfer note that covers all those repeated transfers for a period of up to twelve months.
This is a sensible provision. A pub having its general waste collected three times a week doesn’t generate a new and meaningfully different transfer each time, and forcing a signed note per collection would be pointless paperwork. The season ticket lets one note stand in for the lot.
But there are two things people get wrong about it.
The first: a season ticket only holds while everything stays the same. Same waste description, same EWC code, same parties, same arrangement. The moment any of that changes — a new waste stream appears, the carrier changes, the description no longer fits — the season ticket no longer covers that transfer and you need a new note. People treat a season ticket as a year’s blanket immunity. It isn’t. It’s a shortcut that’s only valid while the thing it describes is genuinely unchanged.
The second, and this is the one that catches people out at audit: a season ticket does not remove the obligation to record each individual transfer. The note itself can omit the per-collection date and time, but you’re then expected to keep a separate schedule logging each actual collection that took place under it. A season ticket with no underlying record of what was collected and when is a season ticket that doesn’t evidence anything. The note says “these transfers will happen”; the schedule proves they did.
And the retention rule shifts slightly too. A season ticket has to be kept for two years from the end of the period it covers — so a twelve-month ticket is effectively a three-year record once you account for the period itself plus the two-year tail.
Why this matters going into DWT
Every field above survives Digital Waste Tracking. The description, the code, the parties and their capacities, the quantity, the signatures, the duty of care — none of it is being retired. What DWT does is take a defined subset of this information and require it to be reported into a central system as well as recorded between the parties.
Which is why it’s worth being fluent in the note now. When we get to what DWT actually asks for, you’ll see it’s a smaller, tighter set of fields than the full note — and it’ll be a lot clearer why each one is there if you already know the document it’s drawn from.
Next in this series: what Digital Waste Tracking actually is, and what it expects of you.