Guide
Business waste management
Your legal duty of care for waste, waste transfer notes, and avoiding fly-tipping liability.
You have a legal duty of care for your business waste from the moment it's produced until it's disposed of. This applies to all businesses regardless of size. Breaking these rules can lead to unlimited fines and up to 5 years in prison.
Your duty of care
Under the Environmental Protection Act 1990, you must:
- store waste safely and securely
- only transfer waste to registered waste carriers
- complete a waste transfer note or consignment note for each transfer
- keep records for the required period
- take all reasonable steps to prevent illegal disposal
Waste transfer notes
Complete a waste transfer note every time you transfer non-hazardous waste to another person. This includes when your regular waste collector takes it away.
Season tickets for regular collections
If you have regular waste collections of the same type going to the same place, use a season ticket instead of writing individual transfer notes each time.
Hazardous waste
Hazardous waste has stricter requirements. You need consignment notes instead of transfer notes, and longer record-keeping periods.
Healthcare & Social Care businesses only
Healthcare providers typically exceed the 500kg hazardous waste threshold due to clinical waste, cytotoxic waste, sharps, and pharmaceutical waste. You must:
- Register your premises with the Environment Agency before your first hazardous waste collection (£37 online)
- Segregate clinical waste by colour-coded bags (orange for infectious, yellow for cytotoxic, purple for cytostatic)
- Use licensed clinical waste carriers - standard waste carriers cannot handle clinical waste
- Complete consignment notes for each collection with EWC codes (18 01 03 for infectious, 18 01 06 for cytotoxic)
Improper disposal of clinical waste can lead to regulatory action from both the Environment Agency and CQC.
Manufacturing & Engineering businesses only
Manufacturing businesses often produce multiple hazardous waste streams that require careful management:
- Common hazardous wastes: Cutting oils, solvents, paints, plating solutions, chemical residues, contaminated packaging
- Premises registration: Required if producing >500kg hazardous waste per year - most manufacturing sites exceed this
- Packaging producer responsibility: If you handle >50 tonnes packaging AND >£2m turnover, you must register for packaging EPR
- Plastic packaging tax: Applies if you produce/import 10+ tonnes of plastic packaging with <30% recycled content (£210.82/tonne)
Check your waste carrier is registered
Always verify that anyone taking your waste is registered before you transfer it. You can be held liable if your waste is fly-tipped, even if you paid what looked like a legitimate company.
Digital waste tracking (from April 2026)
A new mandatory electronic system will replace paper waste transfer notes in England. This will track waste from production to final destination.
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Identify your waste streams
List all waste types your business produces. Note any that may be hazardous - oils, solvents, fluorescent tubes, batteries, asbestos.
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Check waste carrier registration
Before any waste transfer, verify the carrier is registered on the public register for your nation.
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Complete waste transfer notes
For each non-hazardous waste transfer, complete a waste transfer note with all required information. Keep for 2 years.
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Use consignment notes for hazardous waste
Hazardous waste needs consignment notes. Keep producer records for 3 years at your premises.
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Set up season tickets for regular collections
For regular waste collections of the same type to the same destination, use a season ticket valid up to 12 months.
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Prepare for digital tracking
From April 2026, England will require digital waste tracking. Review your current record-keeping systems.