Section 34 Waste Transfer Notes Without the Paperwork: Inside WasteLinks Compliance

Most waste businesses still treat compliance as a thing that happens after the job. Print a transfer note, scribble a signature, stuff it in a binder, hope nobody asks for it in the next two years. The Environment Agency is rarely impressed when they do.

WasteLinks was built the opposite way round. Every collection through the platform produces a legally compliant Section 34 Waste Transfer Note (WTN) on its own, with the right EWC code, the destination facility, both parties' declarations, photographic evidence and a 24-month searchable archive. No binder needed.

This post breaks down exactly what we have shipped, what we are building before public launch, and how it all lines up with the Digital Waste Tracking mandate that arrives for carriers in October 2027.

What is a Section 34 Waste Transfer Note?

A WTN is the paper (or digital) record that proves a transfer of controlled waste between two parties. Section 34 of the Environmental Protection Act 1990 puts a Duty of Care on anyone who imports, produces, carries, keeps, treats, disposes of, or as a broker has control of controlled waste. Part 9 of the Waste (England and Wales) Regulations 2011 sets out what the WTN must contain and how long you keep it.

In plain English: if your business throws anything out that is not strictly domestic waste, somebody has to fill in a form, both parties sign it, and you both have to keep a copy for two years. Get it wrong and you are personally on the hook for whatever happens to that waste downstream, including fly-tipping.

Each WTN needs to cover:

• Date and place of the transfer
• Description of the waste, with its 6-digit EWC code from the UK List of Waste
• Quantity and type of container
• Hazardous flag where applicable
• Transferor (producer): name, address, SIC code, type of premises
• Transferee (carrier): name, address, EA carrier registration with its tier
• Both parties' declarations of Duty of Care
• Both signatures

Get one element wrong and the document is not compliant. Multiply that by every skip, bin lift and shred bag your business handles in a year and you can see why most carriers run their compliance on Excel and prayer.

How WasteLinks Generates WTNs Automatically

Six things happen behind the scenes between the driver tapping Complete Job and the customer receiving an email.

1. The carrier is verified against the Environment Agency live

When a vendor signs up for WasteLinks, we do not just take their carrier number on trust. We hit the Environment Agency Public Register the second they enter it. We look up the registration, confirm the company name actually matches what they typed (after stripping suffixes like "Ltd" so a typo does not block a real business), check the tier, and for upper-tier (CBDU) registrations we verify the 3-year expiry has not lapsed.

If any of that fails, they cannot list services. If it passes, every check is logged with the EA''s published data licence version and the canonical URI of the record. When an auditor asks how we knew the carrier was legitimate at the point of the transfer, the answer is in our database.

2. The EWC code is assigned automatically

EWC codes are where most paper WTNs come unstuck. Pick the wrong code and even a £100 administrative fine can escalate quickly if the load turns out to have hazardous content that should have triggered different paperwork.

WasteLinks maps every one of our 29 service types to the correct EWC entry. Skip hire and grab hire get 17 09 04 (mixed construction and demolition wastes). Confidential shredding gets 20 01 01 (paper and cardboard). Clinical waste gets 18 01 04 for non-infectious or 18 01 03* for sharps. WEEE gets 20 01 36. Asbestos gets 17 06 05*. The asterisk-suffixed entries are absolute hazardous classifications, and they automatically flip the WTN''s hazardous flag and put a warning banner across the top of the document.

If your service does not fit a standard mapping, we default to 20 03 99 (municipal wastes not otherwise specified) and your admin can refine it. The point is the document is always legally valid out of the box.

3. The destination facility is captured

A WTN that says "place of transfer: 123 High Street" tells you where the carrier picked up. It tells you nothing about where the waste actually went. That is half the chain of custody missing.

Carriers on WasteLinks register their permitted facilities in their vendor dashboard, with each facility''s EA environmental permit number. When the driver completes a job they pick the destination from a list on their phone. The WTN then shows section "1a: Destination / Permitted Facility" with the receiving site''s name, address, facility type, and EA permit. Auditor sees both ends. Job done.

4. Photographic evidence sits on the document

The driver app captures up to five photos per collection. They get resized server-side so the PDF stays sensible, embedded into the full WTN, and timestamped with the collection phase. If a customer ever disputes a delivery, the proof is on the same page as the legal paperwork.

5. The customer receives the WTN immediately

Within seconds of the driver tapping Complete Job, the customer gets an email. Attached is a slim version of the WTN without photos (small enough to always make it through corporate email filters). In the body is a prominent button to download the full version with all the photographic evidence, plus a clear reminder that they must keep it for two years.

6. The carrier has a permanent searchable archive

In the vendor dashboard there is a Transfer Notes section that lists every WTN the business has ever issued. Filter by date range, by customer, by service type, by EWC code, or by destination facility. Open any one in a new tab. Or hit the "Download All as Zip" button and get every matching WTN bundled into one file with a manifest.csv of all the metadata. Default view is the trailing 24 months, which matches the statutory retention window.

Drop the zip onto your file server at the end of the year. Whoever runs your DMS now has the archive without you ever having to manually export anything.

More Compliance, Already Built In

Several further compliance pieces have shipped since this platform first went live. Here is where they stand today.

Companies House verification

Every vendor is now cross-referenced against the Companies House register at signup: we confirm active status, an allowed company type, no active insolvency, and no disqualified directors. Fraudulent shell-company carriers do not make it past signup.

EA expiry alerts

We already capture every carrier''s licence expiry date when we verify them. A daily job now runs automatically: it emails the vendor 30 days (and again 7 days) before expiry, blocks new bookings against an expired registration, and notifies admins. No customer should ever accidentally hire an unlicensed carrier through us.

Vendor authorised-signature capture

The driver''s digital confirmation already constitutes the transferee''s attestation. Vendors now capture a one-time authorised signature during onboarding so the carrier''s named signatory appears as a graphical signature on every WTN, matching the approach BiffaPro and Reconomy use.

SIC code and premises type capture

The transferor''s SIC code is a required field on a fully compliant WTN. It is captured on the customer profile and printed on every transfer note, with a sensible default applied where a customer has not yet provided it.

The Big One: DEFRA Digital Waste Tracking 2026 and 2027

The most significant regulatory change to UK waste in a decade arrives in two phases.

DEFRA''s Digital Waste Tracking Service replaces the current paper and PDF system with a single national digital record of every waste movement, submitted by API. The phased rollout looks like this:

• October 2026: mandatory for waste receivers (transfer stations, materials recovery facilities, treatment sites) in England, Wales and Northern Ireland
• January 2027: same scope, live for Scotland via SEPA
• October 2027: mandatory for waste carriers, brokers and dealers

DEFRA''s public beta API is live now, and DEFRA has explicitly stated they want commercial waste-management software providers to integrate. WasteLinks is building toward exactly that.

By the time the carrier-phase deadline lands in October 2027, every job completed through WasteLinks will be submitted to DEFRA''s tracking service automatically. Drivers will not do anything differently. Carriers will not need to bolt on a separate compliance product. The submission happens in the background the moment a job completes.

Our integration roadmap targets the Receipt of Waste API by Q4 2026 (ahead of the receivers'' deadline, since many of our vendors also operate receiving sites), and the carrier-side submission flow during 2027.

If you are a carrier on the platform when DWT becomes mandatory, you will already be doing it. That is the whole point.

Why This Matters For Your Business

If you produce waste (an office, restaurant, construction site, retail chain, anything that throws things out), every collection booked through WasteLinks gives you a legally compliant WTN you can hand to the Environment Agency on demand. No more chasing the carrier weeks later for a copy, no more spreadsheet of incomplete records, no more EWC-code guesswork.

If you carry waste, your manual WTN process effectively disappears. Drivers spend less time on paperwork. Office staff are not hunting through binders at year-end. Audit responses are a single zip download away. And when DWT becomes mandatory in October 2027, you will already be inside the only mandatory submission system. No scramble.

The platform was built for UK regulation. The WTN, the EWC codes, the EA verification, the 2-year retention archive, the destination tracking. These are not bolt-on features. They are the foundation the rest of the product sits on.

Frequently Asked Questions

Do I legally have to keep waste transfer notes?

Yes. Under section 34 of the Environmental Protection Act 1990 both the transferor (waste producer) and the transferee (waste carrier) must retain a copy of every Waste Transfer Note for at least two years, and produce it to the Environment Agency on request. For hazardous waste consignment notes the retention period is three years.

What information must a UK Section 34 Waste Transfer Note contain?

A compliant WTN must include the date and place of the transfer, a description of the waste with its 6-digit EWC code, the quantity and type of container, identification of the transferor and transferee with their full addresses, the carrier''s Environment Agency registration number with its tier, both parties'' Duty of Care declarations, and signatures from both sides. WasteLinks populates all of these fields automatically.

What is an EWC code?

An EWC code is a 6-digit classification from the European Waste Catalogue, adopted in the UK as the List of Waste. Every category of waste has its own code so regulators and treatment facilities know exactly what they are handling. Codes ending in an asterisk are absolute hazardous entries, which trigger additional consignment-note requirements.

When does the DEFRA Digital Waste Tracking mandate start?

The mandate rolls out in phases. Waste receivers in England, Wales and Northern Ireland must use the service from October 2026. Scotland follows in January 2027. Waste carriers, brokers and dealers must use it from October 2027. WasteLinks vendors will be integrated ahead of those dates so submission happens automatically.

Can I download all my Waste Transfer Notes at once?

Yes. The Transfer Notes section in the vendor dashboard lets you filter by date range, customer, service type, EWC code or destination facility, then download every matching WTN as a single zip file with a CSV manifest of all the metadata. The default view covers the trailing two years to match statutory retention.

Does WasteLinks verify that the carrier is actually licensed?

Every vendor on the platform is verified live against the Environment Agency Public Register at signup, with the registered company name compared strictly, the carrier tier captured, and (for upper-tier registrations) the 3-year expiry checked. Vendors who fail verification cannot list services. Expiry alerts run daily, warning vendors 30 and 7 days before their registration lapses.

What happens if my carrier''s licence expires mid-contract?

Bookings cannot be placed against an expired registration. The vendor receives email alerts 30 days before expiry and is blocked from accepting new bookings until they renew, protecting customers from accidentally hiring an unlicensed carrier.

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Built in the UK, for UK regulation. If you are a carrier ready to spend less time on compliance paperwork, or a business tired of wondering whether your skip hire firm actually held a licence on the day, take a look around the platform.