The Environment Agency doesn’t book inspections in advance. An officer can turn up at your yard, your customer’s site, or pull you over on the road. When they do, the first thing they ask for is your waste transfer notes.
Most waste carriers don’t think about this until it happens to them. By then it’s often too late.
Here’s what EA inspectors actually look for, what happens if your notes don’t hold up, and how to make sure yours do.
Why the EA inspects waste carriers
The EA inspects waste carriers to enforce the duty of care under Section 34 of the Environmental Protection Act 1990. Their job is to make sure waste is being transferred legally, going to licensed sites, and classified correctly.
They run targeted operations — checking carriers who’ve received complaints, following up on fly-tipping incidents, or simply spot-checking vehicles in areas where illegal dumping is common. If you carry waste regularly, the question isn’t if you’ll be inspected. It’s when.
What inspectors check
Inspectors are looking at a specific set of things. Know these and you know what to get right.
1. Do you have a WTN for every load?
Every transfer of controlled waste needs a note. Not one per day. One per transfer. If you picked up from three sites and delivered to one, that’s three separate notes.
Inspectors may ask to see notes for loads you’ve already delivered. You’re legally required to keep them for 2 years (3 years for hazardous waste). If you can’t produce them, that’s a problem.
2. Is the waste description accurate?
The note needs to describe what the waste actually is. “Mixed waste” is vague enough to raise questions. “Mixed construction and demolition waste including concrete, bricks, and timber” is better.
They may compare the description to what’s in your vehicle. If the note says green waste and your tipper is full of rubble, you’ve got a bigger issue than a paperwork problem.
3. Are the EWC codes correct?
This is where most carriers fall short. Every type of waste has a 6-digit European Waste Catalogue code. Inspectors know these codes. They’ll spot a wrong one.
Common mistakes:
- Using the same code for every job regardless of waste type
- Leaving the field blank and hoping no one notices
- Mixing up similar codes (e.g. 17 09 04 mixed construction waste vs. 17 05 04 uncontaminated soil and stones — same chapter, very different classification)
Not sure which code applies to a load? Use the free EWC code lookup — search by waste type and it’ll find the right code.
4. Does the receiving site have a valid permit?
You’re responsible for where the waste ends up. If you deliver to a site and don’t record their environmental permit number, you’ve failed your duty of care — even if the site turns out to be legitimate.
Inspectors can check permit numbers on the spot. If you’ve been delivering to a site that doesn’t have one, you’re in serious trouble regardless of how good your paperwork is otherwise.
5. Are both parties’ details complete?
The note must include the full name, address, and contact details of both the transferor (you) and the transferee (the receiving site). It needs your waste carrier licence number. It needs signatures from both parties.
Missing signatures invalidate the note. An incomplete address leaves you exposed. Inspectors go through this field by field.
6. Is your carrier registration current?
You can’t legally carry controlled waste without being registered with the EA as a waste carrier. Inspectors will verify this. Upper-tier registration costs £154 and lasts 3 years. Lower-tier (for businesses carrying only their own waste) is free.
If your registration has lapsed, you’re carrying illegally.
What happens if something’s wrong
There’s a range of outcomes depending on what the inspector finds and how serious it is.
Verbal or written warning — for minor issues, first offences, or obvious administrative errors. The inspector tells you what’s wrong and expects you to fix it. No fine, but it goes on record.
Fixed penalty notice — up to £300 for failing to produce a WTN when asked. This is the standard enforcement tool for on-the-spot issues.
Formal caution or prosecution — for deliberate non-compliance, patterns of offending, or cases involving fly-tipping. Fines on conviction can reach £5,000 per note in a magistrates’ court. Serious cases go to the Crown Court where there’s no upper limit.
Suspension or revocation of carrier registration — the EA can revoke your registration if they find evidence of repeated or serious offences. Without registration, you can’t operate.
The EA publishes enforcement actions. If your business gets prosecuted, it’s publicly searchable.
How to be ready
You don’t need to wait for an inspection to get your paperwork right. Here’s what to sort now.
Create notes at the point of transfer. Not at the end of the day. Not from memory on Friday afternoon. The date on the note needs to match when the transfer actually happened.
Keep a complete record. Every note, for every load, going back 2 years. Whether that’s a carbon copy book, scanned PDFs, or a digital system — it needs to be accessible quickly. Inspectors don’t wait while you search through boxes.
Check your EWC codes. Go through the types of waste you carry regularly and make sure you’ve got the right code for each one. The EWC lookup tool lets you search by description to find the correct code.
Get permit numbers from receiving sites. Before you deliver to a new site, ask for their environmental permit or exemption reference. A legitimate site will give it to you without hesitation.
Make sure your carrier registration is in date. Log in to the EA’s public register and check. If it’s within 3 months of expiry, renew it now.
Use a template that covers all the required fields. If you’re using a paper book, make sure it includes everything: both parties’ details, waste description, EWC code, quantity, container type, permit number, signatures. The free WTN generator covers every field and produces a properly formatted PDF you can print or send digitally.
For a full walkthrough of every field on a waste transfer note:
What changes in October 2026
From October 2026, DEFRA’s new digital waste tracking system takes effect. Paper notes don’t disappear overnight, but waste carriers will be required to record transfers electronically and submit data to a central government database.
This actually makes EA inspections easier — for both sides. Inspectors will be able to verify transfers in real time against the central record. If your digital note matches what’s on the system, you’re fine. If something doesn’t match, they’ll know immediately.
The underlying requirements stay the same: correct EWC codes, accurate waste descriptions, valid permit numbers, proper records. The difference is that everything becomes searchable and cross-referenceable.
For a full explanation of what’s changing and when:
If you’re still filling in paper notes by hand, the tools above will get you through. But if you want to be ready for October 2026 — and you want an inspection to be a non-event rather than a problem — WTN App creates a compliant digital waste transfer note in 30 seconds from your phone. Works offline. EWC code search built in. Customer signs on screen.
Join the waitlist to get early access when it launches.