How Do I Comply With Duty of Care for Waste Transfer?

UK duty of care law requires anyone transferring controlled waste to confirm four things: the producer is identified, the carrier holds a valid registration, the waste is correctly described and classified, and the destination facility is named. All four must be documented in a Waste Transfer Note, kept for at least two years.

The four duty of care requirements

1. Producer identified The name and address of the business producing the waste must be recorded. This establishes the chain of custody from source.

2. Carrier registered The carrier must hold a valid Environment Agency waste carrier registration. Upper tier registrations (CBDU prefix) are required for most commercial carriers. An expired or lower-tier-only registration doesn't satisfy duty of care.

3. Waste correctly classified The waste must be described accurately and assigned the correct European Waste Catalogue (EWC) code. An incorrect EWC code — particularly one that misses a hazardous classification — is a compliance failure, not just a paperwork error.

4. Destination identified The receiving facility's name, address, and permit number must be recorded. You can only transfer waste to a licensed or permitted facility.

Why paper WTNs fail at this

A paper form captures the information you write on it. It can't tell you that the carrier registration number you've written down expired six months ago. It can't flag that the EWC code you've selected doesn't match the waste description. Both are common failure points in manual compliance processes.

Automating duty of care checks with WasteCheck

WasteCheck's /v1/generate-wtn endpoint checks all four requirements automatically and returns a duty_of_care object in the response:

{
  "duty_of_care": {
    "producer_identified": true,
    "carrier_verified": true,
    "waste_classified": true,
    "destination_provided": true,
    "all_checks_passed": true
  }
}

all_checks_passed is only true when all four pass. If carrier verification fails (expired registration, not found), carrier_verified returns false and all_checks_passed is false. The same applies to any of the four checks.

The compliance object in the response gives you the specific flags:

{
  "compliance": {
    "is_compliant": true,
    "flags": [],
    "warnings": []
  }
}

Possible flags include EXPIRING_WITHIN_90_DAYS, LOWER_TIER_ONLY, and LOW_CONFIDENCE (for waste classifications below the 0.7 confidence threshold).

Record-keeping

Each WTN generated through WasteCheck gets a unique reference (WTN-YYYY-MMDD-XXXX) and is stored for retrieval via GET /v1/wtn/{reference}. This satisfies the two-year record-keeping requirement without needing to build your own document storage.

Hazardous waste

If the waste is classified as hazardous, duty of care requirements are stricter. You'll need a consignment note (not a transfer note), pre-notification to the Environment Agency, and the carrier must be licensed to transport hazardous waste. WasteCheck's classification endpoint flags hazardous codes automatically and sets requires_consignment_note: true in the compliance response.

Get started

Sign up at app.wastecheck.co.uk. Full documentation at docs.wastecheck.co.uk.