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Reduce, reuse, recycle – and check you transfer notes!

Published: Tuesday 24th January 2012

Reduce, reuse, recycle – and check you transfer notes!

Businesses transferring waste to a waste carrier need to include a declaration on transfer notes that they have applied the waste hierarchy. And with the number of landfill sites predicted to fall significantly it will pay to think of the alternatives.

Reduce, reuse, recycle - and check you transfer notes! 

Since the end of September last year it has been a legal requirement for waste producers to take all such measures as are reasonable in the circumstances to apply the waste hierarchy to their waste prior to transferring it to a waste carrier for example.

The waste hierarchy puts preventing waste in the first place at the top. Once waste has been created, preparing it for re-use is the next option to consider, followed by recycling, then recovery methods such as energy from incineration, with disposal by  landfilling coming last.

You will need to add a declaration on your Duty of Care Waste Transfer Notes and Hazardous Waste Consignment Notes confirming that you have complied with this duty. The sample notes available from the Environment Agency suggest the following wording:  

'I confirm that I have fulfilled my duty to apply the waste hierarchy as required by regulation 12 of the Waste ( England and Wales ) Regulations 2011."


If your waste carriers provide pre-printed transfer notes check they have updated them to include a similar declaration.

Another issue is that the number of landfill sites for non-hazardous waste in England has been projected to fall from about 245 at present to about 55 in 2020. This equates to one per county so the distance to your nearest landfill site - and associated transport cost - is very likely to increase.

Landfill is the last option in the waste hierarchy and thinking of other options makes sense economically in many cases already due to the landfill tax which is £56 per tonne now and due to increase by £8 per year up to 2014 at least.