Hazardous Waste Consignment Notes Guide for UK Businesses

If your business produces, carries, or receives hazardous waste in the UK, you are legally required to use a hazardous waste consignment note for every movement. This document travels with the waste from the moment it leaves your site until it reaches its final destination. Getting it wrong can mean fines, delays, or rejected loads. This guide covers what you need to know to complete consignment notes correctly, with specific rules for England and Wales.

What Is a Hazardous Waste Consignment Note?

A hazardous waste consignment note is the official paperwork that must accompany any hazardous waste when it is moved. It records the waste description, the parties involved, and the journey from producer to consignee. The note is prepared before the waste is moved and must stay with the waste until it arrives at the final disposal or recovery facility. Without a correctly completed note, the movement is not compliant with the regulations.

When Do You Need a Consignment Note?

You need a consignment note for every movement of hazardous waste produced by a business. There are a few exceptions. A note is not needed for domestic hazardous waste (except asbestos) moved from a household to an initial collection point. Waste being imported or exported under international waste shipment controls is also exempt. However, asbestos waste from domestic properties does require a consignment note. Additionally, radioactive waste that also has hazardous properties and is not covered by certain exemptions must be moved using a consignment note.

The Five Parts of a Consignment Note (A to E)

The standard consignment note is divided into five parts, each with a specific purpose and responsible party.

Part A: Notification Details

This section contains information about the waste producer or holder, the waste carrier, and the consignee (the receiving site). It also includes the consignment note code and details of the movement such as the date and the address of the collection and destination. In Wales, this part also includes the premises code issued by Natural Resources Wales; premises registration was abolished in England in April 2016, so English producers do not need one.

Part B: Waste Description

Here you describe the hazardous waste in detail. You must provide the European Waste Catalogue (EWC) code for each waste type, the quantity in tonnes or kilograms, the physical form, and any special handling requirements. The Standard Industrial Classification (SIC) code for the process that produced the waste is also required.

Part C: Carrier Certification

The carrier signs and dates this section to confirm they have collected the waste and that the information in Parts A and B is correct to the best of their knowledge. The carrier must be a registered waste carrier with the Environment Agency or the relevant regulator.

Part D: Consignor Certification

The consignor (the person transferring the waste) completes this part. In England, Part D must not be signed before the carrier arrives to collect the waste. In Wales, the consignor completes Part D at the time of collection. This is a notable difference between the two nations.

Part E: Consignee Certification

The consignee (the receiving site operator) completes this part when the waste arrives. It confirms receipt, the quantity received, and the EWC code. The consignee must also report all consignments received to the regulator through quarterly consignee returns. In England these go to the Environment Agency, and in Wales to Natural Resources Wales, within one month of the end of each quarter (31 March, 30 June, 30 September and 31 December). The consignee must also send a return to the waste producer or holder within the same deadline.

How to Create a Consignment Note Code

The consignment note code identifies each movement and must follow a specific format. The format differs between England and Wales.

England

In England, the code format is XXXXXX/YYYYY. The first six characters (XXXXXX) are the first six letters or numbers of the producer's company name. If the name is shorter than six characters, use the letter Q to fill the remaining spaces. After the slash, you add exactly five letters or numbers that you choose. For certain special cases, a suffix letter is added after the code: V for ship waste, F for fly-tipped waste, D for consignee return derogation, and P for continuous piped waste.

Wales

In Wales, the code format depends on whether the producer is registered or exempt. Registered producers use a 6-character premises code provided by Natural Resources Wales, followed by a slash and 5 characters of their own choice. Exempt producers use EXE followed by 8 letters or numbers. Fly-tipped waste consignments use FLY followed by 8 letters or numbers.

England vs Wales at a Glance

RequirementEnglandWalesRegulatorEnvironment AgencyNatural Resources WalesPremises registrationNot required (abolished April 2016)Required for most producers; premises code issued by NRWCode formatFirst 6 characters of company name + /5 chosen charactersNRW premises code + /5 chosen characters (EXE or FLY prefix formats for exempt or fly-tipped waste)Part D timingMust not be signed before the carrier arrivesCompleted at the time of collectionConsignee returnsQuarterly to the Environment Agency, within one month of quarter endQuarterly to Natural Resources Wales, within one month of quarter end

Who Completes Which Parts?

The producer or holder of the waste must complete Parts A and B before the waste is removed. The carrier completes Part C. The consignor signs Part D, and the consignee completes Part E. It is important that all parties check the information before signing. Mistakes can lead to a non-compliant note and potential enforcement action.

Copy Retention

Copies of hazardous waste consignment notes must be kept for at least three years. This applies to producers, carriers, and consignees. The notes form part of your waste audit trail and may be requested by the Environment Agency or Natural Resources Wales during an inspection. Retaining them digitally can save space and make retrieval easier.

Differences Across the UK Nations

England and Wales are covered by the guidance above, but Scotland and Northern Ireland have their own regulations and regulators. Scotland uses a special waste consignment note system managed by SEPA (Scottish Environment Protection Agency), and Northern Ireland is regulated by the Northern Ireland Environment Agency. The core principles of a five-part note and duty of care are similar, but the exact code formats, premises registration, and return deadlines may differ. Businesses moving hazardous waste into or out of Scotland or Northern Ireland should check the specific guidance from the relevant regulator before moving any waste.

Common Mistakes to Avoid

One frequent error is using the wrong consignment note code format, especially when waste crosses from England into Wales or vice versa. Another is failing to complete Part B with the correct EWC and SIC codes. Missing or incorrect codes can cause the consignee to reject the load. Also, remember that Part D must not be completed early in England, while in Wales it is completed at the time of collection. Being aware of these differences prevents delays at the weighbridge.

Digital Consignment Notes and the Future

Paper consignment notes are still widely used, but the industry is moving towards digital solutions. DEFRA's Digital Waste Tracking programme will require receiving sites in England, Wales and Northern Ireland to submit waste data electronically from October 2026 (with Scotland following from January 2027), and waste carriers, brokers and dealers from October 2027. While the regulations on consignment notes themselves are not changing immediately, using digital tools now can help your business prepare for the mandatory tracking system. Digital notes also reduce the risk of lost paperwork and make record-keeping simpler.

Frequently Asked Questions

What happens if I lose a consignment note copy?

You must retain copies for at least three years. If you lose a paper copy, you should contact the other parties involved (carrier or consignee) to obtain a duplicate. The regulator may request evidence of compliance during an inspection, so it is best to keep backup copies, preferably in a digital format.

Can I use a consignment note from another UK nation?

The consignment note format must meet the requirements of the nation where the waste is produced. If waste is produced in England and moved to Wales, the England format applies. If waste is produced in Wales, the Wales format applies. Using the wrong format can invalidate the note. Always follow the rules of the producer's location.

Do I need a consignment note for small quantities of hazardous waste?

Yes, there is no de minimis exemption for hazardous waste from businesses. Every movement, no matter how small, must be accompanied by a consignment note. The only exceptions are for certain domestic wastes (except asbestos) and movements covered by international waste shipment controls.

When does the consignee have to submit consignee returns?

Consignees must report all hazardous waste they receive through quarterly consignee returns, submitted within one month of the end of each quarter (for example, by 30 April for the quarter ending 31 March). In England the return goes to the Environment Agency, and in Wales to Natural Resources Wales. A separate return must also be sent to the waste producer or holder within the same deadline. Failure to submit returns is a breach of the regulations and can result in enforcement action.

What if the waste type changes during transport?

The consignment note must reflect the waste at the time of collection. If waste is mixed or treated en route, a new consignment note may be required. Mixing hazardous waste with non-hazardous waste is generally prohibited, so the waste should remain as described on the original note until it reaches the permitted treatment facility.

Getting your hazardous waste consignment notes right is essential for legal compliance and smooth operations. Understanding the five parts, the correct code format for your nation, and the differences between England and Wales will help you avoid common pitfalls. Always keep your copies for at least three years, and keep an eye on the upcoming digital waste tracking requirements so your business stays ahead of the changes.