Hazardous Waste Consignment Notes: UK Business Guide (2026)
Hazardous waste requires a consignment note, not an ordinary waste transfer note. What it must contain, consignment codes, the 3-year retention, consignee returns, and EA rules.
Quick answer: Hazardous (special) waste in the UK requires a consignment note — a more detailed document than a standard waste transfer note — to track the waste from producer to final disposal. Each consignment has a unique code. The note must be kept for at least 3 years by producer, carrier, and disposal site, and the producer should retain the consignee returns that confirm proper disposal. Required under the Hazardous Waste Regulations and enforced by the Environment Agency (SEPA in Scotland, NRW in Wales).
Hazardous waste vs ordinary waste
Ordinary (non-hazardous) waste uses a waste transfer note. Hazardous waste needs the more rigorous consignment note system because of the greater risk. See our waste transfer notes guide for the non-hazardous process.
What counts as hazardous waste
- Asbestos
- Lead-acid and lithium batteries
- Solvents, paints, inks, adhesives with hazardous content
- Waste oils and oil filters
- Fluorescent tubes and energy-saving lamps (mercury)
- Hazardous WEEE (electrical equipment with hazardous components)
- Clinical and infectious waste
- Chemicals, pesticides, and laboratory waste
- Refrigerants and equipment containing them
Hazardous wastes are identified by EWC (List of Wastes) codes marked with an asterisk (*).
What a consignment note contains
- A unique consignment note code
- Producer/holder details and premises
- Description of the hazardous waste and EWC code(s)
- The hazardous properties (HP codes)
- Quantity and containers
- The chemical/biological composition
- Carrier details and registration
- Consignee (disposal/recovery site) details and permit
- Declarations and signatures at each stage
The consignment journey
- Producer completes Part A (description) and Part B (producer declaration)
- Carrier completes their part on collection
- Consignee (disposal site) completes their part on receipt
- Each party keeps a copy
- Consignee return — the disposal site later confirms what was done with the waste
Consignee returns
After receiving hazardous waste, the consignee sends quarterly returns confirming the treatment or disposal of each consignment. The producer should receive and retain these — they're your proof the hazardous waste was properly dealt with, not dumped.
Retention
- Producer — consignment notes 3 years; consignee returns retained
- Carrier — 3 years
- Consignee — 3 years
Registration (England)
In England, the requirement to register premises as a hazardous waste producer with the Environment Agency was abolished in 2016. You no longer register, but you must still use consignment notes for every hazardous waste movement. Scotland (SEPA) and Wales (NRW) have their own arrangements — check locally.
Digital waste tracking
The UK is rolling out mandatory digital waste tracking, which will replace paper consignment notes with a central electronic system. Businesses handling hazardous waste should prepare for the transition.
Common hazardous waste mistakes
- Treating hazardous waste as ordinary waste (using a WTN instead of a consignment note)
- Not retaining consignee returns
- Wrong or missing EWC/HP codes
- Using an unpermitted disposal site
- Mixing hazardous and non-hazardous waste (can make the whole load hazardous)
- Discarding consignment notes before 3 years
FAQs
Is asbestos always hazardous waste?
Yes — asbestos waste is hazardous and requires a consignment note plus disposal at a licensed facility. Never mix with general waste.
What about small quantities of hazardous waste?
England removed the lower threshold — consignment notes apply to hazardous waste movements regardless of quantity. (Historically there was a 500kg exemption; check current rules.)
Can I take hazardous waste to the tip myself?
Household hazardous waste — sometimes, at designated HWRC facilities. Business hazardous waste — must go via a registered carrier with a consignment note.
What are HP codes?
HP (Hazardous Property) codes 1-15 describe the specific hazards — HP1 explosive, HP4 irritant, HP7 carcinogenic, etc. They must be recorded on the consignment note.
Related guides
Last reviewed 2026-06-08 by Jamie Dawson, Editor.
