Guides · Duty of care

What is a waste transfer note and do I need one?

A waste transfer note records a handover of waste: who produced it, who took it, what it was, how much, and where it went. Any business transferring commercial waste in England needs one, and both sides must keep a copy for two years.
Ask about the annual note service

What is a waste transfer note?

A waste transfer note is a receipt for a handover of waste. It is not a licence, not a certificate, and not proof that anything was recycled. Both sides sign it and both sides keep a copy for two years.

Whose responsibility is the waste transfer note?

The duty sits with the business that produced the waste, not the company that took it away. Under the Environmental Protection Act that duty of care does not stop when the vehicle pulls off.
If waste is later found fly-tipped and traced back to you, paying someone to take it away is not a defence. The transfer note is. Without notes going back two years, the liability for every load you have handed over sits with you.
Capital Recycle waste sacks collected under a duty of care transfer note in London
The duty sits with you, not your collector, and it is separate from any contract. Full detail: do I legally need a commercial waste contract?

What has to be on a waste transfer note?

A valid note carries the producer's details and the address the waste came from, the carrier's details and licence number, an accurate description of the waste with its List of Waste code, the quantity and container type, the date and place, and both signatures.
  • The carrier's licence number
    Capital Recycle is CBDU466346, checkable on the Environment Agency public register. A note without a licence number on it is not doing its job.
  • A List of Waste code
    Mixed commercial general waste is 20 03 01. Paper and cardboard packaging is 15 01 01. Container glass is 15 01 07.
  • The real address
    The site the waste actually came from, not a head office.
  • Quantity and containers
    Sacks, bins or loose, and how much.

Do you need a transfer note for every collection?

No. Where the same waste moves from the same address to the same carrier on a repeating basis, one annual transfer note covers a year of collections against that description.
That is how most recurring sack and bin accounts work: one note a year, renewed on its anniversary, rather than a piece of paper every Tuesday. Capital Recycle runs this as a £65 + VAT yearly service, issued and held on file.

Are waste transfer notes going digital?

Yes, in stages. Defra and the Environment Agency are introducing a digital waste tracking service, and the duty to use it arrives at different times depending on what kind of operator you are.
  • Waste receiving sites
    Permitted and licensed sites that receive waste must use the service from October 2026 in England and Wales, and January 2027 in Scotland and Northern Ireland.
  • Waste carriers, brokers and dealers
    The duty starts from October 2027. Capital Recycle is a registered carrier, so that is the date that applies to us.
  • Everyone else
    If your business produces waste and hands it to a collector, you are not a receiving site or a carrier, so the service does not place a registration duty on you.
There is an annual charge of £26 for any legal entity that creates or edits records on the service, applying once use becomes mandatory.

What does digital tracking mean for your business?

For a business that simply produces waste and hands it over, nothing changes about your own duty of care. You still need an authorised carrier, an accurate description of the waste, and records you can produce on request.
What changes is the medium further along the chain. Carriers can continue to issue paper transfer notes until October 2027, and switch to digital records from that date. Capital Recycle will make that switch on schedule, and the record you rely on carries on either way.
Your two-year retention duty is unchanged throughout. Treat any supplier telling you that you personally must register, or that transfer notes are being scrapped, with caution and check the position on GOV.UK.
The dates, the cost and the claims worth checking are covered in full in what is digital waste tracking and does it apply to my London business?

When do businesses actually get asked for transfer notes?

Most often it is a client or landlord audit asking for twelve months of notes at a week's notice. After that a tender with an environmental section, and least often a fly-tipping trace, which is considerably more expensive than the other two.
If the notes are in a drawer, that is fine. If the collector holds them and is not answering the phone, it is not.
See commercial waste collection
Separation rules changed what a compliant setup looks like. Full detail: what the new recycling rules mean for your business.

Need your paperwork straight?

Ask about the annual transfer note service and we will tell you what it covers. Call 0207 101 4003 or use the contact form.
Contact us