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Compliance

Do you still need a waste transfer note after Digital Waste Tracking?

29 October 2026 · CarrierNote

Updated

Yes. After Digital Waste Tracking, every load of non-hazardous waste that leaves a business still needs a waste transfer note, and it can be on paper or on screen. Both businesses sign it and keep it for two years. Regulation 35 of the Waste (England and Wales) Regulations 2011 sets the rule, and receiving sites joining the service in October 2026 didn't change it.

Digital Waste Tracking is DEFRA's online service for recording waste movements. It hasn't changed the transfer note rule. What it changed, in October 2026, is that the site where you tip now records the load digitally as well. Carriers, brokers and dealers are due to join the service in October 2027.

The note is still the law

The transfer note is part of the waste duty of care, set by section 34 of the Environmental Protection Act 1990. What goes on it is in regulation 35 of the Waste (England and Wales) Regulations 2011. Neither has been switched off.

GOV.UK's guidance for businesses still reads the same way it did before Digital Waste Tracking began. For each load you move off your premises, you need a transfer note. Both businesses sign it, both keep it for two years, and either of you shows it to the Environment Agency or the council when they ask. Our post on what must be on a waste transfer note has the full list of what it carries.

What changed in October 2026

Since October 2026, every permitted or licensed receiving site in England and Wales has had to report the waste it takes in on DEFRA's service. A receiving site is anywhere that holds a permit or licence to take waste in, such as a transfer station or a treatment plant. Sites in Scotland and Northern Ireland follow in January 2027.

That is a record the site makes, about the load as it arrives. It sits alongside your transfer note and does its own job. GOV.UK's guidance on transfer notes, read on 29 October 2026, still asks for one on every load, with the same two-year keeping period.

So when you tip a load today, the paperwork you had in September still applies. The site logs the load on the service as well, and it has until the end of the second working day after the waste arrives to finish that record. Our post on the two-working-day rule explains how that clock is counted.

What happens for carriers in October 2027

DEFRA's policy paper sets out the carrier phase in three steps:

  • Autumn 2026. A private beta opens to an invited group of carriers, brokers and dealers.
  • Spring 2027. A public beta opens, so any carrier can use the service before it's required.
  • October 2027. The service becomes mandatory for waste collectors.

In its response to the consultation on the service, DEFRA says the service's requirements will take over from the duty to complete transfer notes and hazardous waste consignment notes. It hasn't yet said when that happens for a carrier, and the rules for the carrier phase haven't been published. Until they are, keep making and keeping transfer notes as you do now. Our Digital Waste Tracking dates page carries every date in one place, and we update it when DEFRA moves one.

Paper or on screen is your choice today

None of this stops you moving off a paper pad now. GOV.UK says each side keeps a paper or electronic copy. Regulation 35 allows the note itself to be electronic, so long as it can be shown in a visible and legible form, and then it's signed electronically. A note filled in and signed on a phone at the kerbside meets the same rule as a carbon copy torn off a pad.

The record your tip makes on DEFRA's service and the note you hand over hold a lot of the same facts: what the waste is, its EWC code (the six-digit European Waste Catalogue number that says what a waste is), how much there is, and who had it. Getting those facts right on the note now is the habit the carrier phase will ask for.

Hazardous waste

Hazardous waste moves on a consignment note (the paperwork that travels with every load of hazardous waste) instead of a transfer note. Those rules carry on too. Our post on hazardous waste consignment notes covers who keeps which copy and for how long.

Scotland and Northern Ireland

This post follows the rules in England and Wales. Scotland has its own duty of care regulations from 2014, and Northern Ireland has its own from 2013. If your waste moves in either nation, check the guidance from SEPA (the Scottish Environment Protection Agency) or NIEA (the Northern Ireland Environment Agency).

CarrierNote fills in the waste transfer note on a phone at the kerbside, has both sides sign it there and then, and keeps it for as long as the law asks. It's being built for the carrier phase in October 2027 too. See how it works at carriernote.co.uk/product.

Sources

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