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Waste transfer notes: who hands over, who carries, who receives, and which two sign

There is a carbon pad in the cab of most collection trucks in this trade, and on the top sheet of most of them is one signature, in a box labelled for the wrong person. The pad is called a waste transfer note, and the trouble with it is not the pen. It is that nobody at the doorstep is sure which way the note points. From today, BreakerHQ signs the note on the tablet, both parties, and emails each of them a copy. Before the feature, the direction, because the feature is only as good as the person who knows which box they are.

Three hats, two signatures

Every movement of waste has a direction, and the law names the people on it by what they do, not by who they are. Regulation 35(2) of the Waste (England and Wales) Regulations 2011 says the written description must "give the name and address of the transferor and the transferee and be signed by them". The transferor is the one handing the waste over. The transferee is the one taking it. Those two sign. The third hat is the carrier, the one whose vehicle it travels on. The note names the carrier and their registration number, under 35(2)(c), but the carrier does not sign unless they are also one of the first two.

One person can wear two hats, and in a breaker’s week they usually do. When your truck collects scrap from a garage, you are the carrier and the transferee, and the garage is the transferor. When the merchant’s lorry collects your shells, the merchant is the carrier and the transferee, and you are the transferor. When your own truck takes the shells to the merchant, you are the transferor and the carrier, and the merchant is the transferee. The note has a box for each hat and a line for whose number goes with it. The regulation also asks for the transferor’s SIC code, the time and place, the code and quantity of the waste, whether it is loose or in a container, and a line confirming the transferor has thought about the waste hierarchy. The pad in the cab has none of that, which is why it fills in so quickly.

Which movements take a transfer note at all

Fewer than you would think. Section 34(2) of the Environmental Protection Act 1990 says the duty of care "does not apply to an occupier of domestic property as respects the household waste produced on the property", and the Code of Practice says the requirement for waste transfer notes "specifically does not apply" to them. A private seller’s car needs no note. GOV.UK’s vehicle page adds that the householder "is not required to produce a hazardous waste consignment note for the journey from their home to the ATF" either. The pad has been signed at a lot of front doors where no paper was owed.

At the other end, some movements are too serious for a transfer note. Regulation 35(7): the regulation "does not apply where the waste transferred is hazardous waste and the consignment note" required by the hazardous waste regulations is completed. An undepolluted car from a business is hazardous waste. GOV.UK: "When an undepolluted ELV is transported you must fill in a consignment note unless it is an end of life private vehicle." A transfer note on that car is not a weaker version of the right document. It is the wrong document.

On a tablet, kept two years, shown in seven days

The pad is not required to be a pad. Regulation 35(4): the written information "may be in electronic form if the person producing it can do so in a visible and legible documentary form". 35(5): the signature "must be an electronic signature". 35(6): both parties "must keep the written information, or a copy of it, for at least 2 years and produce it to an officer of the appropriate body or of a waste collection authority on demand within 7 days". Nothing says a copy must travel with the load or be handed to the driver. The duty is a signed description, kept, and produced when asked.

Wales reads the same page. The 2011 Regulations and the 1990 Act are England and Wales instruments, the Code of Practice applies "in England or Wales", and the officer asking to see the note is from Natural Resources Wales rather than the Environment Agency. The one difference is the hazardous waste instrument: in Wales it is the Hazardous Waste (Wales) Regulations 2005, and regulation 35(7) names it beside the England and Wales one. Digital waste tracking changes none of this. Phase 1 is the waste you receive, and the note between you and the merchant carries on.

What BreakerHQ does with it

From today a transfer note is signed on the tablet, both parties, at the gate or at the seller’s door with no signal. The form asks the questions the regulation asks, in the order the doorstep asks them: what it is, who it is from, how it travelled, when and where, then the two signatures. Your side comes from Settings, so your permit number, carrier number and SIC code are never typed at a door. The other side answers one question about what they are, and the note works out the hats from that and from how the waste travelled. Both get the PDF by email within a few minutes of signal. The note is kept on the server for the yard, for at least the two years, and a copy can be downloaded or re-sent at any time, though nothing is saved to the device unless you ask.

Three honest limits. If a business brings an undepolluted car, the note refuses and says why: that movement needs a consignment note, and we do not produce consignment notes yet. The carrier check runs against the Environment Agency register, so a genuine Welsh number will warn rather than tick. And we record the name, address and signature the other party gives us. We do not verify them. The Scrap Metal Dealers Act check of who you are buying from is still yours, and the form has a place for it.

How the transfer note works

The pad in the cab had one signature in the wrong box. The note on the tablet has two, in the right ones, and it knows which way it points.