Waste Transfer Note Requirements: What Must Be Included for Every Collection

A waste transfer note missing a single required field is technically non-compliant. For liquid waste carriers doing 6–10 collections per day, that's a lot of notes to get right. Here's the complete requirements checklist for every WTN you issue on a cesspit or tanker round — what must be included, what's optional, and where operators most commonly leave gaps.

The Legal Basis

Waste transfer note requirements come from two pieces of legislation:

Section 34 of the Environmental Protection Act 1990 — establishes the duty of care and the requirement for a written description of waste at every transfer
The Waste (England and Wales) Regulations 2011 — sets out what the transfer note must contain and how long to keep it

The gov.uk guidance on waste transfer notes summarises the requirements in plain language.

Every Required Field

1. Waste Description (in Words)

Describe the waste clearly: "Septic tank sludge" or "Cesspit waste" for domestic liquid waste. Don't use vague terms like "sewage" or "liquid waste" without further detail — the description must let anyone handling the waste identify what it is and manage it safely.

2. EWC Code

The European Waste Catalogue code classifying the waste. For liquid waste collections:

20 03 04 — Septic tank sludge (domestic cesspits and septic tanks)
19 08 09 — Grease trap waste
20 03 06 — Waste from sewage cleaning (drain jetting)

The EWC code is mandatory — a written description alone isn't enough. If you collect different waste types on the same round, each needs its correct code recorded separately.

3. Quantity

The volume collected, in litres or gallons. For tanker operators, estimate based on the tank gauge reading or known cesspit capacity. Record the actual volume collected, not the tank's total capacity (unless you pumped it empty).

4. How the Waste Is Contained

For liquid waste: "Vacuum tanker" plus the vehicle registration number. This links the WTN to a specific tanker for audit purposes.

5. Date and Time of Transfer

When the waste was collected. Record the actual collection time, not when you completed the paperwork later.

6. Place of Transfer

The full address of the collection site. For rural properties without a clear postcode, include a grid reference, what3words location, or property name with sufficient detail to identify the site.

7. Name and Address of the Transferor (Waste Producer)

Your customer's details. For domestic customers: name and property address. For business premises: also include the Standard Industrial Classification (SIC) code.

8. Name and Address of the Transferee (Waste Carrier)

Your business details: registered name, business address, and contact information.

9. Waste Carrier Registration Number

Your Environment Agency upper tier waste carrier, broker, and dealer registration number. This is publicly verifiable on the EA public register.

10. Category of Each Person

Whether the transferor is the waste producer, importer, or holder. For domestic cesspit collections, the homeowner is the waste producer.

11. Disposal Site Details

The name and permit number of the licensed site where you discharged the waste. This is often overlooked — recording where the waste ended up is as important as recording where it came from.

12. Signatures

Both the carrier and the waste producer must sign the transfer note. For recurring customers, a standing authorisation (signed season ticket) can cover multiple collections.

What Counts as a Valid Note

There is no required format. The gov.uk template is widely used, but any document containing all 12 fields above is legally valid. This includes:

The official gov.uk PDF form
A custom-designed paper form with your branding
A digital record from a WTN app or software system
An invoice that includes all required WTN information

The flexibility on format is useful — it means your existing invoice could double as a WTN if it contains all required fields.

Retention Requirements

Both parties must keep their copy for at least 2 years from the date of transfer. You must produce it within 7 days if requested by the Environment Agency or local authority. Paper and digital records are both acceptable.

For season tickets covering recurring customers, keep the ticket and all individual collection records for 2 years after the last transfer covered by the ticket.

Where Liquid Waste Operators Most Commonly Fall Short

Missing EWC code. The waste description in words is present but the code is omitted. Both are required.

No disposal site permit number. The site name is recorded but not the EA permit reference. Enforcement officers want the permit number, not just "Riverside Treatment Works."

Incomplete multi-stop records. One WTN for the whole round instead of per-property entries. Each collection is a separate transfer and needs its own record.

Expired carrier registration. Your registration appears on every WTN. If it's lapsed, every note issued since expiry is non-compliant. Check yours on the EA public register.

Illegible carbon copies. If an enforcement officer can't read the note, it doesn't meet the "produce within 7 days" requirement. This alone is a strong argument for going digital.

For step-by-step guidance on filling in each field for liquid waste, see our how to complete a waste transfer note for liquid waste. For templates you can use on the round, see our free WTN templates for liquid waste. For the underlying environmental rules that operators need to verify before each visit, see our septic tank regulations guide for operators.

PumpRound pre-populates every required WTN field from customer records — no re-entering the same details for recurring customers, no missing codes or illegible copies. Join the waitlist for early access.

Sources

This guide covers England. Scotland, Wales, and Northern Ireland have separate requirements. This is not legal advice.