Duty of Care

Waste Transfer Note (WTN)

Definition

A waste transfer note (WTN) is the document that records the handover of non-hazardous waste from one party to another. It describes the waste, identifies the parties, and is the core evidence behind the waste duty of care.

Last reviewed 8 June 2026

What a WTN records

A waste transfer note captures the moment non-hazardous waste changes hands. It is the paper (or digital) trail that says: this waste, in this quantity, was passed from this business to this authorised carrier or site, on this date.

It is the everyday workhorse document of the waste duty of care for non-hazardous material.

Why it matters

If a regulator or auditor asks “where did this waste go?”, the transfer note is your answer. An accurate, retained WTN demonstrates the waste left through a lawful route; a missing or vague one leaves a gap even when the waste was handled correctly.

Retention matters too: non-hazardous transfer notes should be kept for at least two years.

Who it applies to

  • The transferor — the business handing over the waste.
  • The transferee — the carrier or facility receiving it, who must be authorised.

Both parties rely on the same note as evidence.

A concrete example

A retailer’s returned vapes are collected for recycling. The collection generates a transfer note describing the waste, its EWC code, the weight, the container, the date, and both parties’ details. Filed centrally, that note is what proves the return route holds together at the next audit.

Common misconceptions

  • “A WTN covers any waste.” Non-hazardous waste uses a transfer note; hazardous waste needs a consignment note instead.
  • “A description like ‘general waste’ is enough.” Vague descriptions undermine the record; an accurate description and EWC code are expected.
  • “You can bin it after the collection.” Transfer notes have to be retained — at least two years for non-hazardous waste.

To get collections that come with correct transfer documentation as standard, see battery collection coordination, or build a complete records routine with a compliance review & setup.

Frequently asked questions

What is a waste transfer note?

It is a record of the transfer of non-hazardous waste between parties. It describes the waste, names who handed it over and who received it, and supports the duty of care. Hazardous waste uses a consignment note instead.

How long must I keep a waste transfer note?

Waste transfer notes for non-hazardous waste should be kept for at least two years. WEEE distributor takeback records have their own retention expectations, and hazardous waste consignment notes are kept for at least three years.

What should a waste transfer note contain?

Typically a description of the waste and its EWC code, the quantity, how it's contained, the date and place of transfer, and the details of both parties including relevant waste carrier registration.

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 waste transfer note (wtn)?

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