How to Fill Out a Hazardous Waste Consignment Note

How to Fill Out a Hazardous Waste Consignment Note

Hazardous waste moves under different rules to ordinary controlled waste. You can't use a regular Waste Transfer Note for asbestos, contaminated soil, used oils or fluorescent tubes — you need a Hazardous Waste Consignment Note (HWCN). Get it wrong and you're looking at refused loads at the gate, broken paper trails and, in the worst cases, formal enforcement.

This guide walks through each part of the consignment note, who completes which section, and the mistakes that come up most often. It's written for England, with notes at the end on what changes in Wales, Scotland and Northern Ireland.

What is a Hazardous Waste Consignment Note?

A consignment note is the legal document that accompanies hazardous waste from the point of production to the point of disposal or recovery. It's required under the Hazardous Waste (England and Wales) Regulations 2005, and it does three jobs at once: it tracks who handled the waste, it evidences your duty of care, and it gives the receiving site the technical detail needed to handle the load safely.

Think of it as the hazardous waste equivalent of a standard waste transfer note — but with stricter rules around content, form structure, and how long you have to keep it.

When You Need One Instead of a Standard WTN

A consignment note is required whenever you move hazardous waste in England or Wales. "Hazardous" has a specific legal meaning: entries in the List of Wastes marked with an asterisk (*), or any waste that displays one or more hazardous properties from HP1 to HP15.

Common examples include:

• Asbestos in any form, including bonded cement sheets

• Contaminated soils from remediation works

• Used engine oils and oily filters

• Solvents, paint and printing waste

• Fluorescent tubes and certain LED lamps

• Lead-acid and lithium batteries

• Refrigerants and fridges containing CFCs or HFCs

• Some categories of clinical waste

If the waste is non-hazardous, a standard waste transfer note is enough — the step-by-step guide to filling out a WTNcovers that process. If you're not sure whether a particular waste is hazardous, the Environment Agency's waste classification technical guidance walks through the assessment.

The Five Parts of a Consignment Note

A consignment note is split into five parts, A to E. Different people complete different parts at different stages of the journey.

Part A — Notification Details

Completed by the consignor — usually the producer of the waste, or the holder if waste has been bulked up at a transfer station.

You'll need:

• The consignment note code (see the next section)

• Producer or holder name and address

• Collection point address, if different from the producer's main address

• The 2007 Standard Industrial Classification (SIC) code that best describes the activity producing the waste — this is the SIC for the process producing the waste, which may differ from your main business SIC code" as a parenthetical. It's one of those things people get wrong by defaulting to their Companies House SIC. GOV.UK

• Any special handling requirements for the carrier or receiving site

Part B — Description of the Waste

Still completed by the consignor. This is the technical heart of the document and where most mistakes happen.

You need to include:

• The six-digit EWC code for each waste type on the load. If you're unsure, our EWC code finder is the quickest way to look one up

• Hazard codes (HP1–HP15) that apply to each waste

• Physical form: solid, liquid, sludge or mixed

• Quantity in kilograms or litres

• Container type and number — drums, IBCs, skip, vacuum tanker

• The chemical or biological components present, with concentrations where relevant

• The process that produced the waste

If multiple waste streams are on the same load, each must be listed separately. You can't combine an asbestos load and a used-oil load into a single line entry.

Part C — Carrier's Certificate

Completed by the carrier collecting the waste. Includes:

• Carrier name, address and waste carrier registration number — which should match the entry on the EA public register of waste carriers

• Vehicle registration number

• Date and time of collection

• Carrier signature

If multiple carriers handle the waste between producer and consignee, each completes their own carrier section, typically using a continuation schedule.

Part D — Consignor's Certificate

Completed by the consignor at the moment of handover. It confirms the information in Parts A and B is accurate, the waste has been packaged and labelled correctly, and the carrier is authorised to take it. The consignor signs, dates, and keeps a copy.

Part E — Consignee's Certificate

Completed by the consignee — the receiving site — once the load arrives. Includes the consignee's name, address and permit or exemption reference, the quantity received (which must reconcile with the quantity sent), the recovery or disposal operation code (R-code or D-code), and the date and time of receipt. Any rejected loads, and the reason, go in here too.

The consignee returns a signed copy to the consignor within the timeframe set out in the regulations, and submits a quarterly return to the Environment Agency listing every consignment received.

The Consignment Note Code Explained

Every consignment note needs a unique code in this format:

[Six characters] / [five characters]

The first six characters are derived from the producer's premises. Since 1 April 2016, England no longer requires producers to register hazardous waste premises with the Environment Agency, so producers use the first six characters of their business name — uppercase, ignoring spaces and punctuation. Wales is different: producers generating more than 500kg of hazardous waste per year must still register with Natural Resources Wales and use the NRW-issued premises code instead of the business-name format.

The five characters after the slash are a unique reference for that specific consignment, typically a sequential number. Any combination of letters and numbers works, as long as no two consignments share the same full code in the same calendar year.

For example, a company called "Northern Roofing Services Ltd" might use NORTHE/00142 for their 142nd consignment of the year, as long as no two consignments share the same full code in the same calendar year. (Our HWCN generator auto-formats the code and tracks sequence numbers per producer.)

Common Mistakes That Catch Carriers Out

A few patterns crop up again and again in rejected loads and EA queries:

1. EWC code mismatches. The code on Part B doesn't match the actual waste, or a non-hazardous code is used for an asterisked waste. The single most common reason consignment notes get queried.

2. Missing hazard codes. An EWC code without the corresponding HP codes leaves the receiving site guessing.

3. Quantities that don't reconcile. Part B says one weight, Part E says another, with no rejection note explaining the gap.

4. Wrong consignment code format. Spaces, special characters, or codes reused inside the same calendar year — all of these create traceability problems.

5. Carrier registration not checked. Consignors are still responsible for verifying the carrier is registered. The public register is free and takes thirty seconds.

6. Loads sent to a site without the right permit. The consignee's permit must cover the EWC code being received.

The thread running through all of these is duty of care — the legal principle, set out in Section 34 of the Environmental Protection Act 1990, that every holder of waste must take all reasonable steps to ensure it ends up where it should.

Most of these come down to form structure. Our free HWCN generator won't let you submit a note with a malformed consignment code or a missing hazard code — it's the fastest way to avoid the patterns above.

How Long to Keep a Consignment Note

Producers, carriers and consignees must each keep their copy of the consignment note for three years from the date of consignment. Consignees must also keep a register of all hazardous waste received for the same three-year period.

That's a year longer than the two-year retention period for standard waste transfer notes, so don't merge them in the same filing system without flagging the difference clearly.

Going Digital

Consignment notes have historically been paper-heavy, but electronic records are permitted provided they capture all the required information, are signed by the relevant parties, and can be produced on request. Our free HWCN generator produces a compliant consignment note in under a minute — it structures Parts A to E correctly, validates the consignment code format, and outputs a PDF you can email or print. No account required.

For your wider compliance file — standard transfer notes, carrier registration evidence, duty of care checks — WTNcloud handles all of it digitally...

Wales, Scotland and Northern Ireland — Quick Notes

• Wales uses the same 2005 Regulations as England, regulated by Natural Resources Wales — but with two key divergences: producers generating more than 500kg of hazardous waste per year must register premises with NRW (England abolished this in 2016), and NRW accepts either SIC 2003 or SIC 2007 codes on the note.

• Scotland runs a different system entirely. Hazardous waste is called "special waste" and is governed by the Special Waste Regulations 1996 (as amended). The document is a Special Waste Consignment Note, with its own pre-notification rules to SEPA.

• Northern Ireland has its own Hazardous Waste Regulations (Northern Ireland), regulated by the NIEA. The form is broadly similar but the registration arrangements differ.

If you operate across borders, treat each as a separate compliance regime. Don't assume an English consignment note format is valid north of the border or across the Irish Sea.

Key Takeaway

A hazardous waste consignment note is more involved than a standard transfer note, but the structure is logical once you've worked through it: who, what, when, where, and what's it doing on the way. Get the EWC and hazard codes right, build the consignment code properly, check the carrier and consignee are authorised, and keep all three copies for three years.

Ready to go digital? Start with 20 free WTNs/HWCNs at WTNcloud — no card required.