How to Complete a UK Hazardous Waste Consignment Note

A hazardous waste consignment note (HWCN) is the four-part form that must travel with every load of hazardous waste moved within England, Wales or Northern Ireland. You can download the official template free from GOV UK or generate one through a compliant e-duty-of-care system, fill in Parts A–D, hand a copy to the carrier, and keep your own copy on file for at least three years. Without it, the load cannot legally leave your premises.

The note is more than paperwork: it proves that you, the carrier and the receiving site have all met your Duty of Care under the Hazardous Waste Regulations 2005, helping to protect people, property and the environment while shielding your business from fines or prosecution. In the pages that follow we’ll show you how to confirm your waste is classed as hazardous, gather the right information, complete each box accurately, manage hand-over, store records and avoid the pitfalls that trip up even seasoned operators.

Step 1 – Confirm Your Waste Is Classified as Hazardous

Before you even print a consignment note you must be certain the material you are moving meets the legal definition of “hazardous waste”. UK law ties that definition to two things:

• the waste shows one or more of 15 hazardous properties (HP1–HP15), and
• it carries an asterisked six-digit entry in the European Waste Catalogue (EWC).

Fail either test and you need no HWCN; meet them and the paperwork is compulsory.

Recognising the 15 hazardous properties

If your substance ticks any of the above, move to the next check.

Identifying the correct EWC code

Match your waste against the DEFRA list or use the Safety Data Sheet to pick the six-digit EWC. An asterisk at the end flags hazardous status—for instance 20 01 21* (fluorescent tubes containing mercury). Mirror entries require chemical evidence to confirm whether the hazardous or non-hazardous code applies.

Situations where a note is not required

You can skip an HWCN for:

• Purely domestic waste collected by a council crew
• Radioactive, explosive or animal-by-product wastes governed by separate regulations
• International exports handled under a Basel notification

For everything else, plan on raising a hazardous waste consignment note before the lorry turns a wheel.

Step 2 – Obtain or Generate the Correct Consignment Note Template

Before you can start writing, make sure you are using an approved form. The Environment Agency (EA) and Natural Resources Wales (NRW) both publish the free PDF “HWCN01”, while many operators pull the same layout through licensed e-duty-of-care software that stores the data automatically. Either route is fine provided the finished note shows the A–D parts exactly as set out in the regulations.

Standard note versus multiple collection note

Use a standard HWCN for a single uplift from one premises. A multiple collection note (MCN) is allowed when one registered carrier picks up from up to 14 different producers on the same day and delivers the consolidated load straight to the consignee. List each sub-collection on the schedule page and keep the master MCN with the driver.

Creating a unique consignment note code

Every note needs a code in the format AAA999/XXXXX.

• EA sites: first six-character premises code (e.g. “ABC123”).
• NRW sites: the code issued on registration, often starting “NR”.
• SEPA uses a different “S” prefix under Scottish rules—don’t mix them up.
  If your premises is exempt or unregistered, use the postcode or an agreed identifier followed by the five random characters.

Paper versus electronic notes

Paper forms are still legal, but electronic versions with secure time-stamped e-signatures are equally valid. The key test is access: the driver must be able to show the note—printed or on a device—even in areas with no mobile signal, so download the PDF or carry a hard copy before setting off.

Step 3 – Gather All Information Before You Start Filling In

A half-completed form is the quickest way to stall a collection. Before you even open the PDF, assemble every scrap of data the note will ask for—names, permits, weights, even container counts. Having a “pre-completion pack” on your desk keeps the driver waiting minutes, not hours, and slashes the risk of last-minute corrections.

Producer / consignor data

• Premises code issued on registration (e.g. ABC123)
• Full site address and postcode exactly as registered
• Contact name, phone and email for any queries en route
• Company SIC code (optional, but useful for audits)
• Confirmation that the chosen carrier holds a valid CBDU/CBDL licence

Waste description data

• Physical form (solid, liquid, sludge, gas) and colour/odour if relevant
• Container type and quantity: DP plastic drums, IBC, sacks, etc.
• Accurate weight in kilograms—use the weighbridge or calibrated scales
• European Waste Catalogue code(s) with asterisk where hazardous
• Associated UN number, proper shipping name, packing group and hazard codes
• Any specific handling or PPE instructions

Carrier and destination details

• Carrier licence number and expiry date plus vehicle registration if known
• Name, address and permit/reference for the receiving site (EPR/WR or landfill licence)
• Intended treatment or disposal code (D10, R1, R13, etc.)—ask the consignee if unsure
• Planned collection date and ETA to assist the consignee’s booking system

Step 4 – Complete Part A: Consignor and Waste Origin Details

Part A tells regulators who produced the waste, where it arose and what you expect the receiving site to do with it. Fill it in before the driver arrives—any gaps here invalidate the whole hazardous waste consignment note.

Box A1 – Consignment note code

Write the unique code in the top-right corner, matching the reference you created earlier. Stick to a running sequence for the year (e.g. ABC123/00001, /00002…) so audits become a breeze.

Boxes A2–A4 – Premises information

Enter the exact site name and address registered with the Environment Agency, not the head office. Add a contact name and phone number that will be answered during loading; inspectors phone these first. Multi-site firms should include a department or building to speed drivers to the right bay.

Box A5 – Disposal or recovery intentions

Tick the single code that reflects the consignee’s first activity with your load:

If you’re unsure, ask the receiving site—guesswork is a common enforcement trigger.

Step 5 – Complete Part B: Describe and Classify the Hazardous Waste

Part B is the technical heart of the form. It tells the carrier exactly what is inside the vehicle and gives the consignee the data they need for safe treatment. Fill it in carefully and legibly—regulators check this section first when auditing a hazardous waste consignment note.

European Waste Catalogue codes

List each waste stream on a separate line with its six-digit EWC code and asterisk where applicable. For mirror entries, keep the laboratory report or SDS on file to justify the hazardous choice.

If you have more than eight streams, attach a continuation sheet and reference it in the margin.

Chemical composition and hazard information

Next to the EWC, record the main constituents (e.g. “>70 % hydrocarbon oil”) and the relevant HP codes. Where ADR applies, add the UN number, proper shipping name and packing group—example: UN 3077, Environmentally Hazardous Substance, Solid, N.O.S., PG III. Include CLP hazard statements if space allows; inspectors like to see “H304, H411” rather than a vague “toxic”.

Quantity, packaging and special handling requirements

Enter the total weight in kilograms, not “1 pal.” Use actual figures wherever possible—estimates invite questions. State container type and count using standard abbreviations: 2 × IBC, 6 × DP. Note any handling needs such as “keep upright”, “temperature ≤ 25 °C” or “driver to wear FFP3 mask during loading”. If the waste is subject to Limited Quantities or Excepted Quantities rules, flag that here so the carrier can apply the correct vehicle placards.

Step 6 – Complete Part C: Carrier’s Certificate

Part C is the carrier’s declaration that the load described really is the one being taken away, will be transported safely, and is heading to the named consignee. Until this box is filled in and signed, the hazardous waste consignment note is still only half-legal, so it pays to slow down for a minute and get it right.

Carrier details and licence checks

Write the waste carrier’s registration number (CBDU for upper-tier, CBDL for lower-tier) clearly in the space provided, along with the company name and address exactly as it appears on the Environment Agency register. If the note or the waste description looks wrong, the driver must refuse the load; carrying without a correct Part C can lead to an on-the-spot stop notice or a £300 fixed penalty.

Date, time and signature requirements

The driver signs Part C at the point of collection—never before. Add the actual date and the time the vehicle leaves the site. A competent employee may sign on the driver’s behalf, but “for and on behalf of” must appear next to the name. Electronic signatures are fine if they show a unique ID and time stamp (e.g. “John Smith-eID-24/09/2025 14:37”).

Multiple carriers or sub-contractors

If the load changes haulier en route, each new carrier completes a fresh Part C on a continuation sheet, quoting the original consignment note code. This preserves an unbroken chain of custody and proves who held the waste at every stage. Give each subsequent carrier a copy of the amended note and file all versions together for your three-year retention period.

Step 7 – Hand Over at the Disposal/Recovery Site and Complete Part D

Your job is almost done, but the paperwork is not finished until the receiving site signs Part D. This final section confirms the waste actually arrived, was accepted (or not) and what treatment it will undergo. Without a completed Part D, your hazardous waste consignment note remains legally open.

Arrival and verification

On arrival the consignee weighs and inspects the load, checking it matches Part B. They complete the weight box, tick either “accepted” or “part-accepted”, add the correct D or R activity code, then sign and date within 72 hours. If the site uses e-duty-of-care software, the driver should wait until the digital signature is applied or obtain an emailed copy before leaving.

Dealing with rejected or non-conforming loads

If the site refuses all or part of the consignment, they mark “Rejected”, note the reason, and the carrier must remove the waste immediately. A new consignment note (referencing the original code) is raised for any return or onward movement.

Quarterly consignee returns

The consignee must report every Part D to the Environment Agency or NRW within 30 days of quarter-end. Keep your copy; regulators use these returns to cross-check producer records during audits.

Step 8 – Distribute, File and Retain Your Consignment Note Copies

Once Part D is signed, the paperwork dance is still not over. A hazardous waste consignment note is only compliant when every party walks away with the right copy and stores it correctly for future inspections.

Who keeps which copy

Colour codes make life simple:

• White (Producer/Consignor) – stays at the site where the waste arose.
• Yellow (Carrier) – travels with the driver for the rest of the journey.
• Pink (Consignee) – kept by the receiving facility after completion of Part D.
• Blue (Regulator) – forwarded by the consignee with their quarterly return or attached digitally in an e-note system.

If you use an electronic note, generate and email the equivalent PDFs immediately so everyone’s records mirror the colours above.

Statutory retention periods

Keep every copy—paper or digital—for a minimum of three years from the collection date. This answers the common “How long should you keep a hazardous waste consignment note?” query and aligns with Regulation 57 of the 2005 rules.

Storing electronic records safely

Scan paper notes to PDF, save them with the consignment code as the filename, and back them up to two separate, secure locations. Restrict access to authorised staff, encrypt portable drives, and be able to retrieve any note within 24 hours if the Environment Agency comes knocking.

Step 9 – Verify Compliance and Avoid Common Mistakes

A finished note is only half the battle—you must also be sure it would survive an unannounced inspection. Building a simple checking routine into your shipping process stops minor slips turning into costly violations.

Frequent errors that attract enforcement

• Missing or duplicated consignment note code
• Wrong or non-hazardous EWC entry for a clearly hazardous waste
• Illegible handwriting or overwritten figures that obscure key data
• Carrier operating without a current CBDU/CBDL licence
• Part C dated the day before collection, suggesting a “pre-signed” form

Penalties and enforcement actions

Regulators can issue:

• £300 fixed-penalty notices for paperwork defects
• Immediate stop-waste or seizure notices if the load poses a risk
• Magistrates’ court prosecution, with unlimited fines and possible custodial sentences for wilful breaches
• Public naming in compliance registers—damaging for tender bids and ISO audits

Internal auditing and staff competence

• Run monthly spot-checks on 10 % of outbound notes
• Keep a “common faults” log and brief loaders and drivers quarterly
• Schedule refresher training every two years or after a regulatory change
• Record corrective actions so you can prove continual improvement during ISO 14001 or EA audits

Final Checks Before the Lorry Leaves

Before the truck rolls off, spend a final minute on this mini-audit:

• Correct HWCN01 (or approved e-note) in hand
• Unique consignment note code clear and complete
• Parts A, B and C signed with ink or secure e-signature
• Weights, containers and hazard codes reflect the load
• Driver carries the yellow carrier copy (paper or offline PDF)
• White producer copy already filed or scanned
• PPE and handling instructions explained; placards fixed

If each item is ticked, the lorry can leave fully compliant. For extra peace of mind, explore the accredited dangerous goods courses at Logicom Hub.