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Environmental · Mandatory · Construction

Hazardous Waste Consignment Note

A consignment note required for the transfer of hazardous waste from site.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. Hazardous Waste Regs 2005 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basisHazardous Waste (England and Wales) Regulations 2005
StatusMandatory — required for every movement of hazardous waste
Prepared byPrincipal Contractor
Common typesAsbestos, contaminated soil, lead paint, fluorescent tubes
Retention3 years

1. Hazardous Waste — The Highest-Risk Waste Stream

Hazardous waste is waste that has properties which make it harmful to human health or the environment. On construction sites, the most common hazardous wastes are asbestos-containing materials, contaminated soils, lead paint, fluorescent tubes and other mercury-containing lamps, oil-contaminated materials, solvent-based paints and coatings, and batteries. These materials have the potential to cause serious harm if they are not identified, segregated, stored, transported, and disposed of correctly.

Every movement of hazardous waste must be accompanied by a Hazardous Waste Consignment Note — a five-part document that tracks the waste from the producer through the carrier to the consignee (the receiving facility). The consignment note system is more rigorous than the standard Waste Transfer Note used for non-hazardous waste because of the greater risk associated with hazardous materials. The Environment Agency can trace every movement of hazardous waste back to the producer using the consignment note trail.

The Hazardous Waste (England and Wales) Regulations 2005 require premises that produce more than 500 kg of hazardous waste in any twelve-month period to register with the Environment Agency as a hazardous waste producer. This registration must be in place before the first consignment of hazardous waste leaves the site. The regulations also require advance notification of consignments in certain circumstances.

Asbestos removal requires licensed contractors

Asbestos removal and disposal must be handled by licensed contractors only — unlicensed asbestos disturbance is a criminal offence. The Control of Asbestos Regulations 2012 require that any work with asbestos-containing materials is carried out by a contractor holding a licence from the Health and Safety Executive (HSE), unless the work falls within the limited exemptions for low-risk, short-duration tasks. Asbestos waste must be double-bagged, labelled, and transported to a facility licensed to accept it.

2. What a Consignment Note Must Include

The Hazardous Waste Consignment Note is a five-part document. Each part must be completed accurately at the appropriate stage of the waste movement. The following table summarises the five parts and the additional requirements.

PartDetail
Part A — ProducerCompleted by the waste producer (the construction site). Includes the producer's name, address, premises code, SIC code, description of the waste, EWC code, hazardous properties (e.g. H7 carcinogenic, H5 harmful), physical form, quantity, container type, and the number of containers. The producer must also declare whether the waste is subject to any special handling requirements.
Part B — CarrierCompleted by the waste carrier at the point of collection. Includes the carrier's name, address, vehicle registration, waste carrier registration number, date and time of collection, and confirmation that the waste matches the description in Part A. The carrier signs to confirm acceptance of the waste for transport.
Part C — ConsigneeCompleted by the receiving facility (the consignee) on receipt of the waste. Includes confirmation that the waste received matches the description on the consignment note, the date and time of receipt, the permit or licence number of the receiving facility, and any discrepancies between the waste received and the description provided. The consignee returns a copy to the producer to confirm receipt.
Consignment note numberEvery consignment note has a unique pre-printed serial number. This number is used to track the consignment through the system. The Environment Agency uses consignment note numbers to monitor the movement of hazardous waste and to investigate incidents of illegal disposal.
Advance notificationCertain consignments require advance notification to the Environment Agency — particularly first consignments from a premises, or where the waste is being sent to a facility for the first time. The notification must be made at least 72 hours before the waste is collected, unless a blanket notification arrangement is in place.

3. Common Mistakes

1

Not using the correct five-part consignment note form

Hazardous waste cannot be transferred using a standard Waste Transfer Note. It must use the specific five-part Hazardous Waste Consignment Note prescribed by the Hazardous Waste Regulations 2005. The five-part structure ensures that the producer, carrier, and consignee each retain their own copy and that the Environment Agency can trace the complete chain of custody. Using a WTN instead of a consignment note for hazardous waste is a regulatory breach.

2

Mixing hazardous waste with non-hazardous waste

Hazardous waste must be segregated from non-hazardous waste at all times. Mixing hazardous waste (such as asbestos, contaminated soil, or oil-soaked rags) with non-hazardous construction waste contaminates the entire load, turning it all into hazardous waste. This dramatically increases disposal costs, creates regulatory non-compliance, and may result in the receiving facility rejecting the load. Separate, clearly labelled storage areas must be maintained for hazardous waste on site.

3

Not confirming the disposal facility licence

Before sending hazardous waste to any facility, the producer must confirm that the facility holds an environmental permit that authorises it to accept the specific type of hazardous waste being consigned. Not all permitted facilities can accept all types of hazardous waste. Sending hazardous waste to a facility that is not licensed to receive it is an offence committed by both the producer and the carrier. The permit number of the receiving facility must be recorded on Part C of the consignment note.

4

Asbestos bagged or labelled incorrectly

Asbestos waste must be double-bagged in clearly labelled, heavy-duty polythene bags or wrapped in polythene sheeting and labelled with the standard asbestos warning. Bags must be sealed and intact before transport. Loose, torn, or unlabelled asbestos waste will be rejected by the carrier and the receiving facility. Incorrectly packaged asbestos also creates an airborne fibre release risk during handling and transport, which is a serious health hazard and a criminal offence under the Control of Asbestos Regulations 2012.

4. Frequently Asked Questions

What is the difference between a Hazardous Waste Consignment Note and a Waste Transfer Note?

A Waste Transfer Note (WTN) is used for transfers of non-hazardous controlled waste and is a two-party document signed by the transferor and transferee. It must be retained for 2 years. A Hazardous Waste Consignment Note is used for every movement of hazardous waste and is a five-part document completed by the producer (Part A), the carrier (Part B), and the consignee (Part C), with copies retained by each party and the Environment Agency. It must be retained for 3 years. The consignment note system is more detailed because hazardous waste poses greater risks to human health and the environment, and the Environment Agency needs a complete audit trail to track every movement from source to final disposal.

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This guide is for general informational purposes only and does not constitute legal advice. While every effort is made to ensure accuracy, regulations change and individual project circumstances vary. Construction Suite is a trading name of Xzist Digital Ltd, registered in England and Wales.

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