Hazardous Waste Consignment Note

What is a hazardous waste consignment note?

When waste is classified as hazardous, a simple transfer note is not enough. Each movement must be accompanied by a hazardous waste consignment note: a controlled document that records the waste, its hazardous properties, the producer, the carrier and the receiving site, under a unique code that lets regulators track the movement end to end.

It is the stricter sibling of the standard waste transfer note: more detail, a per-movement document rather than an annual one, and longer retention.

Why it matters for batteries and vapes

Waste lithium batteries are routinely classified as hazardous, and whole waste vapes are treated the same way because of the lithium cell inside. That is why every standard collection Cell Comply arranges travels on a consignment note, handed over on the day of collection.

Damaged goods raise the stakes further. A swollen, crushed, leaking or overheating battery is the clearest case: it must move as hazardous waste with the damage declared, and usually with stricter packaging under the dangerous-goods rules as well. Treating a hazardous movement as if it were ordinary waste, with only a transfer note or nothing at all, is one of the most common gaps inspectors find.

What’s on the note: Parts A to E

The standard England and Wales consignment note is completed in five parts, each owned by a different party in the chain:

• Part A: the consignment. The unique consignment note code (two blocks separated by a slash, based on an identifier for the business), plus the addresses of the premises the waste is leaving and the site it is going to.
• Part B: the waste. The description, the six-digit waste classification code, the quantity, the physical form, the chemical or biological components that make it hazardous, the hazard property (HP) codes, and the carriage details where dangerous-goods rules apply, such as the UN number for lithium batteries.
• Part C: the carrier’s certificate. The carrier confirms who is transporting the waste, their registration, and the vehicle details.
• Part D: the consignor’s declaration. The person sending the waste signs to confirm the description is accurate and, where required, that a packaging and carriage check has been done.
• Part E: the consignee’s certificate. The receiving site confirms what was actually received, accepted or rejected, and the management method it went to.

Getting Part B right is where most battery waste problems begin. A vague description, the wrong waste code or missing HP codes can lead to a load being rejected at the gate, and the paper trail then shows the error against your name.

How the note gets completed in practice

Each movement needs its own note, and every party keeps a copy. In a brokered collection the sequence usually looks like this: the broker or carrier prepares the note in advance from the information you supply, you check and sign the consignor’s parts before the load leaves, the carrier signs at collection, and the receiving site completes its certificate and returns the final copy. That returned copy is the proof your duty of care relies on.

How long must you keep consignment notes?

• Producers and holders: at least three years, kept at or for the premises the waste left.
• Receiving sites: at least three years.
• Carriers: at least twelve months.

Three years is longer than the two-year retention expected for non-hazardous transfer notes, and insurers, auditors and licensing officers increasingly ask to see the file, not just the latest note.

England, Wales, Scotland and Northern Ireland

The consignment note described here is the England and Wales document. England removed hazardous waste premises registration in April 2016, so the consignment code is built on a business identifier rather than a premises number. Wales retains premises registration through Natural Resources Wales for most producers, and the Welsh code reflects it. Scotland and Northern Ireland run their own special waste consignment procedures under separate rules, so multi-nation operators should not assume one process covers every site.

Digital waste tracking and e-consignment notes

Paper and PDF e-consignment notes are being replaced by digital records. Under Digital Waste Tracking (DWTS), hazardous waste movements, including battery and vape waste, will be recorded through a single online service designed to hold the same information as today’s notes. Receiving sites must use it from October 2026, with carriers and brokers expected to follow from October 2027. Consignment notes remain the legally required document until then, and clean waste descriptions and codes now will make the switch painless.

A concrete example

A warehouse isolates several swollen lithium packs after a returns inspection. Because the packs are damaged, the collection is arranged as a hazardous movement: the broker prepares the note with the damage declared in Part B, the packs travel in UN-approved packaging, the carrier and receiving site complete Parts C and E, and the warehouse files its copy for at least three years.

Common misconceptions

• “A transfer note works for hazardous waste.” Hazardous movements need a consignment note, not a transfer note.
• “One note can cover the year.” A season ticket transfer note is a non-hazardous concept. Hazardous waste needs a note for every movement.
• “All the paperwork is the carrier’s problem.” The producer signs the declaration and keeps the records. If Part B is wrong, the gap is yours.
• “Consignment notes can be discarded with the rest.” They must be retained for at least three years.

Because damaged batteries also raise transport questions, hazardous movements frequently overlap with dangerous-goods rules. For a route that handles classification, packaging and documentation together, with the consignment note handed over on the day of every collection, see bins & collections, or formalise the process with a compliance review & setup.

This entry is general information about UK vape, WEEE and battery compliance terminology, not legal advice. Rules change and individual circumstances differ — always confirm your obligations against current GOV.UK guidance or a qualified adviser.