Every waste transfer note needs two things to describe the waste: an EWC code and a written description. Most carriers get the EWC code right (or close enough). The written description is where things fall apart.
Here’s what the law requires and how to get it right every time.
What the law says
The Environmental Protection (Duty of Care) Regulations 1991 require that every waste transfer note includes a written description of the waste that is detailed enough to allow the waste to be correctly identified and handled.
That means someone reading your note should understand:
- What the waste actually is
- Whether it’s hazardous or not
- How it should be handled
- Where it came from (the process or activity that produced it)
“Mixed waste” doesn’t cut it. “Rubbish” definitely doesn’t cut it.
Good descriptions vs bad descriptions
Here’s what the EA considers adequate versus inadequate:
| Bad description | Good description |
|---|---|
| Mixed waste | Mixed construction waste: broken concrete, timber offcuts, brick rubble, packaging materials. Non-hazardous. From house extension demolition. |
| Soil | Excavated topsoil and subsoil from foundation trenching. No visible contamination. Non-hazardous. |
| Wood | Untreated softwood timber offcuts and broken pallets. Non-hazardous. From warehouse clearance. |
| General rubbish | Household clearance waste: furniture, carpet, bagged clothing, small electricals. Non-hazardous. |
| Plasterboard | Gypsum plasterboard sheets, dry, non-contaminated. From internal wall demolition. Non-hazardous. |
The pattern is simple: what it is + what condition it’s in + where it came from + whether it’s hazardous.
The four parts of a good waste description
1. What the waste is
Name the materials. Be specific. Instead of “construction waste”, list the main components: “concrete rubble, timber offcuts, broken bricks, and metal fixings.”
If it’s a single material, name it precisely. “Untreated softwood timber” is better than “wood”. “Plasterboard” is better than “building materials”.
2. Its condition
Is it wet or dry? Contaminated or clean? Broken or intact? Bagged or loose?
This matters because it affects handling. Wet plasterboard and dry plasterboard go to different places. Contaminated soil and clean soil have different EWC codes.
3. Where it came from
The source of the waste tells the receiving site how to classify and handle it. “From domestic kitchen refurbishment” is different from “from industrial chemical plant clearance” even if the physical waste looks similar.
You don’t need an essay. A short phrase is enough: “from house demolition”, “from office clearance”, “from garden landscaping”.
4. Whether it’s hazardous
State it explicitly. If the waste is non-hazardous, say so. If it contains hazardous components (asbestos, lead paint, chemicals), flag them.
If there’s any chance the waste could be hazardous and you’re not sure, treat it as hazardous until proven otherwise. That means a consignment note instead of a standard WTN.
EWC codes and descriptions work together
The written description doesn’t replace the EWC code. You need both.
The EWC code is the formal classification — it tells systems, regulators, and receiving sites exactly what category the waste falls into. The written description adds the context that a 6-digit number can’t convey.
For example, EWC code 17 09 04 covers all “mixed construction and demolition wastes.” But that could be anything from a skip of clean brick rubble to a mixed load with plasterboard, timber, and insulation. The written description clarifies what you’re actually carrying.
Need to find the right EWC code? Use our free EWC code lookup. Type what the waste is and it’ll show you the matching 6-digit codes.
What happens with a bad description
An inadequate waste description is a Section 34 duty of care breach. In practical terms:
- The receiving site can reject your load. If the description on the note doesn’t match what’s in the skip, they’ll turn you away. That’s a wasted trip and an unhappy customer.
- EA inspectors will flag it. During a site inspection or roadside check, inspectors specifically look at waste descriptions. “Mixed waste” on its own is an automatic fail.
- Fines of up to £5,000 per incorrect or inadequate transfer note.
- It undermines your defence. If something goes wrong downstream (illegal dumping, contamination), a vague description means you can’t prove you did your due diligence.
Practical tips for drivers
If your drivers fill in waste transfer notes on site, give them these rules of thumb:
- Look at the waste before you write. Open the skip, check the bags, see what’s there. Don’t guess.
- List the main materials. Three or four specific materials is enough for most loads.
- Add “non-hazardous” or flag hazardous items. Make it explicit.
- Mention the source. “From domestic loft clearance” or “from shop fit-out demolition” — one line is enough.
- Don’t copy the EWC description word for word. The written description should add detail the code doesn’t capture.
Or skip the hassle entirely. With WTN App, drivers tap the waste type and the EWC code fills in automatically. The app prompts for a written description and flags if it looks too short. No training manuals needed.
A good waste description takes 30 seconds to write. A bad one can cost you £5,000 and a rejected load. Be specific, be honest, and make it clear what’s in the load. If you want to generate a properly formatted note right now, use our free WTN generator.