Hazardous Waste Consignment Notes: When a Standard WTN Isn't Enough

Standard Waste Transfer Notes cover non-hazardous waste. But if your business produces anything classified as hazardous — and many do without realising it — you need a different document: a hazardous waste consignment note. The requirements are stricter, the penalties for getting it wrong are higher, and the paperwork has to be right before the waste leaves your premises.

This guide covers which waste types trigger the consignment note requirement, how to complete one, and the duties that come with producing hazardous waste.

What makes waste "hazardous"

Waste is hazardous if it has one or more hazardous properties listed in Annex III of the Waste Framework Directive (retained in UK law). The 15 hazardous properties include:

• HP1 Explosive — waste capable of producing gas at a rate that could cause damage
• HP3 Flammable — waste with a flash point below 60°C
• HP4 Irritant — waste causing skin or eye irritation
• HP5 Specific target organ toxicity — waste that damages organs through single exposure
• HP7 Carcinogenic — waste containing substances known to cause cancer
• HP14 Ecotoxic — waste that presents risks to the aquatic environment

You don't need to memorise all 15. What matters is recognising the common hazardous waste types in business settings.

Hazardous waste that businesses commonly produce

You don't need to be a chemical plant to produce hazardous waste. These are found in ordinary offices, shops, and workshops:

Waste	EWC Code	Why it's hazardous	Commonly produced by
Fluorescent tubes and LED tubes	20 01 21*	Contain mercury	Every office with strip lighting
Batteries (lead-acid, NiCd, lithium)	20 01 33*	Toxic metals, flammable electrolyte	Offices, retail, workshops
WEEE with hazardous components	20 01 35*	Lead solder, mercury backlights, brominated flame retardants	Offices disposing of old IT equipment
Waste paint with solvents	08 01 11*	Organic solvents (flammable, toxic)	Maintenance, decorating
Used engine/lubricating oils	13 02 08*	Mineral oils (ecotoxic)	Workshops, vehicle maintenance
Cleaning solvents	14 06 03*	Halogenated or non-halogenated solvents	Commercial cleaning, workshops
Printer toner cartridges (some)	08 03 17*	Contains solvents/heavy metals	Offices with laser printers

The asterisk (*) in the EWC code marks it as hazardous. If you see an asterisk, you need consignment notes instead of standard WTNs. Use our free EWC Code Finder to quickly look up the code for your waste — asterisk codes appear alongside their non-hazardous equivalents, so you'll see straight away whether consignment-note documentation applies. Not sure where to start? Our free Hazardous Waste Checker walks you through a few questions and tells you whether your waste needs a Consignment Note.

When you must use consignment notes

A consignment note is required for every movement of hazardous waste from your premises. Unlike standard WTNs, there's no season ticket option — each individual collection needs its own consignment note.

The legal basis is The Hazardous Waste (England and Wales) Regulations 2005 (as amended). These regulations require:

1. Pre-notification — you must notify the Environment Agency before the first removal of hazardous waste from your premises (unless exempt)
2. Consignment note completion — a multi-part form completed jointly by the producer, carrier, and receiving facility
3. Record retention — keep your copy for a minimum of 3 years (longer than the 2 years required for standard WTNs)

How a consignment note differs from a WTN

Requirement	Standard WTN	Hazardous Waste Consignment Note
Season ticket option	Yes (up to 12 months)	No — individual note per collection
Retention period	2 years minimum	3 years minimum
Parts	2-part (producer + carrier)	5-part (producer, carrier, consignee, EA notification, producer's copy)
EA notification	Not required	Each consignment is reported to the EA by the consignee (receiving site); no producer premises registration since 2016
SIC code required	Yes	Yes
EWC code required	Yes	Yes — must be an asterisk (*) code
Quantity	Estimated acceptable	Must be accurately determined
Carrier requirements	Standard waste carrier registration	Must hold upper tier registration

The 500kg threshold

The 500kg threshold matters because it changes the level of scrutiny your hazardous waste attracts. Premises producing more than 500kg of hazardous waste in any 12-month period are higher-volume producers, and the Environment Agency expects robust consignment-note records to match.

It is worth being clear about what the threshold no longer means: until 2016, premises producing more than 500kg of hazardous waste a year had to register (notify) with the Environment Agency. That premises registration was abolished on 1 April 2016 by The Hazardous Waste (England and Wales) (Amendment) Regulations 2016, which revoked the notification requirement. There is no longer any hazardous waste producer registration or fee in England. Traceability is now maintained through the consignment-note system, with receiving sites (consignees) reporting consignments to the EA.

Whatever your volume, you need consignment notes for every movement of hazardous waste. Producing less than 500kg does not exempt you from proper documentation.

To put 500kg in context: it's roughly 25 fluorescent tubes (about 100g each = 2.5kg), so most offices producing only lighting waste will be well under the threshold. But if you also dispose of batteries, old IT equipment, and maintenance chemicals, the total adds up faster than expected.

How to complete a consignment note

The standard consignment note form has five sections:

Part A — Producer's details (you complete this):

• Your business name, address, SIC code
• A consignment note code (a unique reference you assign to each consignment, in the format of your premises ID or business name followed by a unique number)
• Description of waste and EWC code
• Quantity (weight in kg)
• Number and type of containers
• Physical form (solid, liquid, sludge, powder, gas)
• Hazardous property codes (HP1–HP15)
• Process giving rise to the waste

Part B — Carrier's details (carrier completes):

• Carrier name, address, registration number
• Vehicle registration
• Collection date and time

Part C — Consignee's details (receiving facility completes):

• Facility name, address, permit number
• Date received
• Quantity accepted (may differ from Part A if some waste is rejected)

Parts D and E are notification copies — one for the Environment Agency, one retained by the producer.

You can download blank consignment note forms from GOV.UK.

Common mistakes

Mixing hazardous and non-hazardous waste. If you put a fluorescent tube in the general waste bin, that entire bin load may be reclassified as hazardous waste. This turns a simple general waste collection into a hazardous waste problem — with the associated paperwork and cost implications.

Using standard WTNs for hazardous waste. A Waste Transfer Note is not valid documentation for hazardous waste. If the Environment Agency checks your records and finds WTNs where consignment notes should be, that's a compliance failure.

Underestimating your hazardous waste volume. Many businesses don't realise how much hazardous waste they produce until they actually add it up. Check your totals — fluorescent tubes, batteries, WEEE, cleaning chemicals, and maintenance products all count. While the producer premises registration was abolished in 2016, knowing your volume still matters for choosing the right carrier and disposal route.

Not checking the carrier's registration tier. Hazardous waste carriers must hold upper tier waste carrier registration. A lower tier registration is not sufficient. Verify using the Waste Carrier Licence Checker.

What this means for your duty of care

Your waste duty of care obligations are heightened for hazardous waste. The "reasonable measures" standard is higher: you're expected to know what hazardous waste your business produces, ensure it's properly classified, documented, and transferred only to carriers and facilities with the correct authorisations.

Penalties for hazardous waste offences are severe. Standard waste duty of care offences carry unlimited fines on summary conviction, and hazardous waste offences under the 2005 Regulations can result in unlimited fines and up to 2 years imprisonment on conviction on indictment.

Action steps

1. Audit your waste for hazardous items. Check every waste stream against the EWC code list — any code with an asterisk is hazardous.
2. Calculate your annual hazardous waste volume. There is no longer a producer registration to complete (it was abolished in 2016), but knowing whether you're over 500kg helps you plan collections and choose the right carrier.
3. Switch from WTNs to consignment notes for any hazardous waste movements.
4. Verify your carrier holds upper tier registration — use our free checker tool.
5. Store consignment notes for 3 years minimum (not the 2-year WTN retention period).

---

This guide is for general information only and does not constitute legal advice. Hazardous waste classification is complex — for specific queries, consult a qualified waste management consultant or the Environment Agency.