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Does digital waste tracking replace SEPA waste data returns and transfer notes in Scotland? No. What a Scottish yard still files after 1 January 2027.

Wednesday 11 November 2026. No. Digital waste tracking does not replace the waste transfer note, the special waste consignment note or the waste data return you email to SEPA four times a year. From 1 January 2027, seven weeks from now, a permit-level site in Scotland has one new thing to do, which is to tell Defra about each load it receives. The SEPA spreadsheet is still due on the 28th.

SEPA says so itself, in a sentence that is easy to miss. Here it is, with what the Scottish regulations say about each record that stays, and the three dates that land in January.

Does digital waste tracking replace transfer notes in Scotland?

No. SEPA: “The introduction of the new Digital Waste Regulations in Scotland will not immediately remove or change any of your existing duty of care or waste reporting requirements currently in place.”

The same page says the aim is “to join up and eventually replace, multiple existing outdated paper-based systems”. Eventually is the word to read twice. In January the first phase adds a record and takes none away.

What does the law say about the transfer note in Scotland?

Scotland has its own regulations for it, the Environmental Protection (Duty of Care) (Scotland) Regulations 2014. Regulation 3 says the two sides must make sure a transfer note is “completed in writing and signed by each of them”. Regulation 5 says both keep it “for a period of two years from the date of transfer of the waste”. And if SEPA asks to see one, regulation 6 gives you “7 days from the date of the request”.

The note carries the six-digit waste code and the SIC code of what the transferor does. Nothing in the 2026 regulations touches any of it.

Do I still need special waste consignment notes?

Yes. Scotland still calls hazardous waste special waste and still runs it under the Special Waste Regulations 1996, which England and Wales left behind in 2005. SEPA: “All special waste produced in Scotland must be consigned using a special waste consignment note (SWCN) bearing a unique SEPA-issued code, regardless of its destination within the UK.” An undepolluted car is 16 01 04*, which is special waste. So are the batteries and the oils that leave your yard.

A breaker meets the note from both ends.

• When a note arrives with a load. You are the consignee. You complete Part E and, in the regulation’s words, “forthwith furnish one copy to the Agency for the place to which the consignment has been transported”. SEPA asks for that copy by email.
• When your own special waste leaves. Every note carries a code bought from SEPA. “SA codes cost £15 each and are used for single movements or carriers rounds.” “SB codes cost £10 each and are used for the consignment of special waste consisting only of lead acid motor vehicle batteries.” SEPA sells them online and no longer supplies paper notes.
• Before it leaves. Regulation 12 asks for SEPA’s copy “not more than one month and not less than 72 hours before the removal of the consignment”. SEPA’s guidance on consigning special waste then stands that down for most of what a yard does: “SEPA do not expect to be pre-notified nor will SEPA take enforcement action where the place from which the waste is being moved and the destination are both located in Scotland.”

So a load that stays in Scotland needs the code and the note, and SEPA does not expect notice. A load going over the border is the one to ask SEPA about first.

Does it replace the SEPA waste data return?

No. It is one of the “waste reporting requirements” SEPA says do not change. SEPA’s returns page: “All operators of waste activities at a registration or permit level are required to submit waste data returns to SEPA on a quarterly or annual basis.” It goes in on SEPA’s own Excel form, within 28 days of the quarter ending.

Two things in SEPA’s guidance to the form are worth knowing before January. A quarter with no waste still needs a return, which SEPA calls a nil return. And a late one counts against you: “failure to make a routine data return (including nil returns) of adequate quality within 30 days of the required submission date is considered a Major non-compliance and may affect your environmental performance rating.”

There is one more wrinkle. The new Defra duty covers permit-level sites only, and SEPA lists registration-level sites as not included. The waste data return covers both. A registration-level site is outside the new duty and inside the old one.

What lands in January 2027?

1. Friday 1 January. The Digital Waste Tracking (Scotland) Regulations 2026 come into force. It is New Year’s Day and Monday the 4th is a bank holiday too, so the first loads are due by the end of Wednesday 6 January. We worked that through in October.
2. Thursday 28 January, the waste data return. October to December 2026, on SEPA’s form.
3. 31 January, the £26. GOV.UK: “The first payment is due by 31 January 2027.” It is per organisation, not per site. The 31st is a Sunday, so pay it by Friday the 29th.

What BreakerHQ does for a Scottish yard

Pick Scotland when you sign up, or under Location in Settings, and the screens follow. The regulator named is SEPA. The transfer note cites the 2014 Regulations, not England’s, and goes by email to both sides. The gate asks which area the car came from, using SEPA’s own area codes, because the return wants it. Each quarter the Vehicles tab builds the rows for the form’s Waste accepted, Waste treated on-site and Waste sent off-site sheets for you to paste in, and tells you when the quarter is a nil return. And each car you book in can be sent to Defra now, for the practice, or from 1 January when it must be.

Three honest gaps. We do not write the special waste consignment note for the batteries and oils leaving your yard, or buy the code. That is still yours. We hold no copy of SEPA’s carrier register, so a carrier’s number is recorded as given and not checked. And the due date we show on each receipt counts weekends but not Scottish bank holidays, so around New Year it is early. It is never late.

Sign in and start

The spreadsheet is still due on the 28th. From January it has company.