What to Include in a Waste Transfer Note for Skip Hire Collections

If you run a skip hire business or hire a skip for commercial purposes, you need a waste transfer note (WTN) for every load of non-hazardous controlled waste that leaves your site or is collected from a customer. This document is a legal requirement under the Environmental Protection Act 1990, the Environmental Protection (Duty of Care) Regulations 1991, and Regulation 35 of the Waste (England and Wales) Regulations 2011. Getting the details right keeps you compliant and avoids penalties that can run to thousands of pounds.

What Is a Waste Transfer Note?

A waste transfer note is a record that documents the transfer of non-hazardous controlled waste from one person or business to another. It is sometimes called a 'duty of care note' because it fulfils the legal duty of care that anyone handling waste has to ensure it is managed properly from production to final disposal. When you hire a skip from a licensed contractor, the skip hire company should produce and sign a waste transfer note covering the waste in the skip. The law does not prescribe a standard format; the note can be on an invoice or a receipt as long as it contains all the required information.

Who Needs a Waste Transfer Note for Skip Hire?

Waste transfer notes are required for transfers of commercial waste. If you are a skip hire company collecting waste from a construction site, a shop, an office, or any business premises, you must have a WTN for each collection. Domestic occupiers disposing of their own household waste do not need a waste transfer note. That means a householder hiring a skip for a home renovation project does not need a WTN, but the skip hire company still needs one for the waste when it leaves the skip yard or is transferred to a disposal facility. If you transport skips that contain waste, you must also register as a waste carrier and keep waste transfer notes or consignment notes for hazardous waste.

What Information Must a Waste Transfer Note Include?

A valid waste transfer note must contain specific details about the waste and the parties involved. According to the regulations, the following elements are required:

• A description of the waste (what it is, its composition, and any relevant physical characteristics)

• The European Waste Catalogue (EWC) code that classifies the waste

• The SIC code of the business that produced the waste (Standard Industrial Classification code)

• The quantity of waste (usually in tonnes, cubic metres, or number of loads)

• The time and place of the transfer

• The name and address of the transferor (the person or business transferring the waste, typically the producer)

• The name and address of the transferee (the person or business receiving the waste, such as the skip hire company or disposal site)

• The carrier registration number of the waste carrier involved

• Signatures of both the transferor and the transferee

Both parties must sign and retain their own copy of the waste transfer note. If you are the skip hire operator, you should keep copies of all WTNs you issue or receive. The note can be handwritten or digital, but it must be completed at the time of transfer or as soon as reasonably possible.

Can a Waste Transfer Note Cover Multiple Loads?

Yes. A 'season ticket' waste transfer note can cover multiple transfers of the same type of waste over a period of up to 12 months. This is useful for skip hire companies that regularly collect identical waste from the same customer, such as mixed construction waste from a long-term project. The season ticket WTN reduces paperwork by allowing one document to cover multiple collections, but only if the waste type, the parties involved, and the place of transfer all stay the same. The note must still include all the required information, and the period of validity must be stated. If any of those details change, you need a new season ticket or a single note for that transfer, and it is not suitable for one-off collections.

Hazardous Waste and Consignment Notes

Hazardous waste requires a hazardous waste consignment note instead of a waste transfer note. Common hazardous wastes in skip hire include asbestos, used oils, solvents, paints, batteries, and chemicals. If you accept a skip that contains hazardous material, you must use the consignment note system. Consignment notes must state where the waste is being disposed of and be kept for three years, whereas waste transfer notes are kept for two years. The consignment note also requires more detailed information about the waste's hazardous properties and the waste transfer process. If you are unsure whether a waste is hazardous, check the EWC code or consult the Environment Agency guidance.

Penalties for Failing to Have a Waste Transfer Note

Operating without a valid waste transfer note carries serious consequences. Local councils can issue a £300 fixed penalty notice for failing to produce a waste transfer note when required. On prosecution, the fine can be unlimited. If the Environment Agency requests a waste transfer note and you cannot produce it within seven days, you are liable for criminal prosecution. This applies to both the waste producer and the waste carrier. For a skip hire business, being caught without proper documentation can damage your reputation and result in lost contracts with disposal sites and customers who require proof of compliance.

How to Store and Retain Waste Transfer Notes

Waste transfer notes must be kept for at least two years from the date of transfer. This applies to both paper and digital copies. If you use paper notes, store them in a safe place where they can be retrieved quickly if the Environment Agency or local council requests them. If you use digital records, ensure you have backups and a system that allows you to produce a note within seven days. Many skip hire operators now use digital platforms that automatically store WTNs in the cloud, making it easy to search for and share documents when needed. Failure to keep records for the required period leaves you exposed to enforcement action.

The Future of Waste Tracking: Digital Records

The UK government is replacing paper waste transfer notes with mandatory digital waste tracking records submitted to a central government service. The rollout is phased: waste receiving sites in England, Wales and Northern Ireland must use the service from October 2026, Scotland follows in January 2027, and waste carriers, brokers and dealers — including skip hire operators — are required to use it from October 2027. For skip hire businesses, that means moving away from paper receipts and invoices as WTNs and adopting digital tools that can send and store records automatically, well before your own deadline arrives — not least because the disposal sites you tip at will already be recording every load digitally from October 2026. The official Duty of Care Waste Transfer Note template is available from GOV.UK, but digital versions that meet the same legal criteria are also acceptable.

Frequently Asked Questions

Do I need a waste transfer note for a skip at my home?

No. If you are a domestic occupier and the waste is your own household waste, you do not need a waste transfer note. The skip hire company, however, must still have a WTN for the waste when it is taken to a disposal or recycling facility.

Can I use an invoice as a waste transfer note?

Yes. There is no standard format for a waste transfer note, so an invoice or receipt can serve as a WTN as long as it contains all the required information, including waste description, EWC code, SIC code, quantity, carrier registration number, and signatures.

What happens if I lose a waste transfer note?

If the Environment Agency requests a WTN and you cannot produce it within seven days, you risk criminal prosecution. Keep copies in a safe place and consider using a digital system to store backups. For lost paper notes, contact the other party involved in the transfer to request a duplicate.

How long do I need to keep waste transfer notes?

Waste transfer notes must be kept for at least two years from the date of transfer. Hazardous waste consignment notes must be kept for three years. Both paper and digital records are acceptable, but they must be accessible if requested by an enforcement officer.

What is the difference between a WTN and a consignment note?

A waste transfer note is for non-hazardous controlled waste. A hazardous waste consignment note is required for hazardous waste, such as asbestos or chemicals. Consignment notes must include the disposal destination and be kept for three years, whereas WTNs are kept for two years.