Defra plots reform of Waste Transfer Note system

By Will Date

Defra has unveiled plans to provide greater flexibility over the types of documents that can be used as an alternative to Waste Transfer Notes (WTNs).

A consultation, launched today (December 9) under the governments Red Tape Challenge, seeks views on the scope of WTNs and whether businesses should be allowed to use documents such as invoices as an alternative to transfer notes, to reduce the burden of the regulations.

Defra is aiming to provide greater flexibility around Waste Transfer Notes in order to cut red tape
Defra is aiming to provide greater flexibility around Waste Transfer Notes in order to cut red tape

The option would be available for all businesses opting not to use the governments Electronic Duty of Care (Edoc) tool, which is set to be available from January 2014 (see story) and provides an online platform for completing WTNs.

Duty of Care

Under UK law, all businesses have a Duty of Care to ensure they produce, store, transport and dispose of their waste without harming the environment. One of their responsibilities is to complete a transfer note every time waste is passed from one party to another and keep them for at least two years.

But, the current system results in at least 23.5 million WTNs being produced a year with around 50 million pieces of paper being stored at any one time something which many businesses say they find burdensome.

The EDoC tool is intended to make it easier for businesses to comply with the Duty of Care, whilst also reducing the amount of paperwork that they will be required to store in order to meet the requirements of the regulations.


Defra estimates that as many as 80% of WTNs will be issued through the new Edoc system, but it is proposing to allow the 20% who do not use it to provide additional documentation to provide them with greater flexibility to fulfil their Duty of Care requirements in respect of the description of waste.

Defra proposes to amend regulation 35 of the 2011 Waste (England and Wales) Regulations giving a clearer option to use alternative types of documentation, such as invoices, orders and receipts to record the written description of waste instead of transfer notes.

According to the Department, this greater flexibility will mean businesses will have alternatives to filling in a separate waste transfer note when transferring or handling controlled waste.

Chris Deed, the Environment Agency’s Edoc programme manager welcomed the consultation, stating that it helped highlight the benefits of using the electronic system.

He said: “The whole ethos behind Edoc is to create a simple, cost-effective means for businesses to comply with the duty of care for waste. Millions of individual business waste transfers are recorded every year, using up paper and taking up costly space, not to mention the administrative headache of filing, storing and searching for individual records if they are need.”

Related Links

Defra consultation


Meanwhile, other changes outlined in the consultation include a revision of the written description of waste required to be recorded on transfer notes and to enable relevant convictions to be taken into account to enable the Environment Agency to refuse or revoke a waste carrier, broker or dealer registration.

Stakeholders have been asked to provide responses to the consultation by January 20.

Subscribe for free

Subscribe to receive our newsletters and to leave comments.

The Blog Box

Other Publications from
The Environment Media Group

Back to top