Duty of Care

Hazardous Waste Consignment Note

Definition

A hazardous waste consignment note is the controlled document that must accompany every movement of hazardous waste in England and Wales. Damaged or defective lithium batteries can be hazardous, so they often need one.

Last reviewed 8 June 2026

What a consignment note is

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, with consignment codes that let the movement be tracked.

It is the stricter sibling of the standard waste transfer note.

Why it matters

For battery and vape compliance, the consignment note is most relevant to damaged goods. A swollen, crushed, leaking or overheating lithium battery can exhibit hazardous properties, which can change how it must be classified, packaged, moved and documented.

Treating a hazardous movement as if it were ordinary waste — with only a transfer note, or none at all — is a serious gap.

Who it applies to

  • Producers of hazardous waste, including businesses that accumulate damaged lithium batteries or devices.
  • Carriers and consignees moving and receiving that waste, who complete their parts of the note.

A concrete example

A warehouse isolates several swollen lithium packs after a returns inspection. Because the packs are damaged and potentially hazardous, the collection is arranged as a hazardous movement: the load travels under a consignment note, packaged and handled accordingly, and the note is retained for at least three years.

Common misconceptions

  • “All used batteries are hazardous.” Not necessarily; condition and classification decide it. Sound batteries for recycling are often handled differently from damaged ones.
  • “A transfer note works for hazardous waste.” Hazardous movements need a consignment note, not a transfer note.
  • “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, see battery collection coordination, or formalise the process with a compliance review & setup.

Frequently asked questions

What is a hazardous waste consignment note?

It is the document that must travel with hazardous waste each time it moves, recording the waste, its hazard properties, the parties and the destination. It is the hazardous-waste equivalent of a waste transfer note.

Are lithium batteries hazardous waste?

It depends on their condition. Damaged, defective, swollen or leaking lithium batteries can display hazardous properties and may need to move under a consignment note. Sound, intact batteries collected for recycling are often handled differently — confirm the classification for your waste.

How long must consignment notes be kept?

Hazardous waste consignment notes should be kept for at least three years. That is longer than the two-year retention expected for non-hazardous waste transfer notes.

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.

Need help with hazardous waste consignment note?

Cell Comply helps UK businesses turn battery, WEEE and takeback obligations into a documented, defensible process.