Businesses in the UK have a legal obligation under the Duty of Care regulations to manage waste responsibly. Central to this obligation are two critical documents: the Waste Transfer Note (WTN) and the Waste Transfer Season Note. While both serve as proof of compliance, they differ significantly in scope and application. This guide clarifies their distinctions and provides practical advice on when to use each.
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1. The Legal Foundation: Duty of Care
The Duty of Care (Environmental Protection Act 1990) requires businesses to ensure waste is handled legally from production to disposal. This includes verifying that waste carriers are licensed and documenting every transfer of waste. Failure to comply can result in fines or legal action.
2. What is a Duty of Care Waste Transfer Note?
A Waste Transfer Note (WTN), also called a Duty of Care Certificate, is a legal document that records the transfer of non-hazardous waste between two parties (e.g., a business and a waste carrier). It must include:
- Details of the waste (type, quantity, container).
- Contact information for both parties.
- Waste carrier license numbers.
- The transfer date and destination site.
Key Features:
- Single Use: Required for each individual transfer of waste.
- Legal Requirement: Mandatory for all non-hazardous waste movements.
Example Scenario: A café contracts a waste company for a one-off collection of cardboard packaging. A WTN must be completed for this single transfer.
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3. What is a Duty of Care Waste Transfer Season Note?
A Season Note (or Annual Waste Transfer Note) is a consolidated document covering multiple transfers of the same non-hazardous waste between the same parties over up to one year. It simplifies compliance for recurring waste arrangements.
Key Features:
- Multi-Use: Replaces individual WTNs for repeated transfers under identical conditions.
- Time-Bound: Valid for a maximum of 12 months, after which it must be renewed.
- Specificity: Only applicable if waste type, origin, destination, and parties remain unchanged.
Example Scenario: A supermarket with daily food waste collections by the same contractor can use a Season Note to cover all transfers for a year, avoiding daily paperwork.
4. Key Differences Between WTNs and Season Notes
| Aspect | Waste Transfer Note (WTN) | Season Note |
|---|---|---|
| Frequency | Single transfer | Multiple transfers over ≤1 year |
| Complexity | Required for every waste movement | One document covers recurring transfers |
| Flexibility | Adaptable to varying waste types/contractors | Fixed terms (waste type/parties must not change) |
| Legal Scope | Mandatory for all non-hazardous waste | Only for non-hazardous, consistent waste |
5. When to Use Each Document
Use a Waste Transfer Note (WTN) When:
- Transferring waste infrequently (e.g., occasional construction debris).
- Waste type or contractor changes (e.g., switching from general recycling to hazardous waste disposal).
- One-off events (e.g., office clearances or seasonal clean-ups).
Use a Season Note When:
- Waste is collected regularly (e.g., weekly paper recycling or daily food waste).
- Parties and waste type remain consistent (e.g., a long-term contract with a single waste carrier).
- Simplifying compliance for high-frequency transfers (e.g., retail or hospitality sectors).
6. Compliance Tips and Best Practices
- Verify Licenses: Always check waste carriers’ licenses using the Environment Agency’s public register.
- Retain Records: Store WTNs and Season Notes for at least two years.
- Review Annually: Update Season Notes if waste streams, contractors, or regulations change.
- Audit Trail: Use digital tools (e.g., Wastebolt or Mandata’s systems) to automate documentation.
7. Consequences of Non-Compliance
Failure to use the correct documentation can result in:
- Fines up to £5,000 (unlimited for hazardous waste).
- Reputational damage.
- Legal liability for fly-tipping if waste is mismanaged.
8. Conclusion
Both WTNs and Season Notes are essential for fulfilling the Duty of Care, but their usage depends on transfer frequency and consistency. Regular waste producers benefit from Season Notes to reduce administrative burdens, while occasional transfers require individual WTNs. By understanding these distinctions, businesses can streamline compliance, avoid penalties, and contribute to ethical waste management.
For further guidance, consult the UK Government’s Waste Duty of Care Code of Practice.
This post adheres to the latest regulations as of July 2025 and reflects best practices from industry and governmental sources. Always confirm requirements with local authorities or legal advisors.