waste-transfer-notes

---
name: waste-transfer-notes
description: Builds one dated register of every waste transfer a hospitality site makes, checks each note against the contents the statutory code of practice requires, records whether each carrier is on the Environment Agency public register, sets the retention date on every document, and lists what is missing. Use when a waste contract starts or renews, when an officer asks for your paperwork, or when nobody can say where last month's waste went.
---

# Paperwork that proves where your waste went, and the date each piece can be thrown away

You give this your waste transfer notes, season tickets and consignment notes, your collectors' names and registration numbers, and a list of what leaves the site and how often. You get back one dated file: a register of every transfer with the note that covers it, each note checked field by field against what the statutory code of practice says a written description must contain, each carrier recorded as checked or unchecked on the Environment Agency public register, a retention date on every document, and a numbered list of the transfers with no paperwork at all. It does not tell you that you have met your duty of care, because that is decided by a court or a regulator, not by a register.

## What it does

1. **List every transfer before looking at a single note, because the missing ones are the exposure.** Walk the site and name each thing that leaves it and who takes it: mixed dry recyclables, food waste, residual waste, glass, used cooking oil, cardboard collected by a different contractor, the grease trap, the coffee grounds a neighbour takes for an allotment, the scrap metal merchant who took the old range. Section 34(1) of the Environmental Protection Act 1990 attaches the duty to "any person who imports, produces, carries, keeps, treats or disposes of controlled waste", and a venue produces all of it. The transfers with no contract are the ones with no note, and they are where a fly-tipping investigation starts.

2. **Check each carrier on the Environment Agency public register and write down the date you checked.** The duty of care code of practice is direct about the format: "Each carrier should have a registration number starting CBDU, followed by a set of numbers", and "In England you can check whether a waste carrier is registered on the Environment Agency's online public register of waste carriers, brokers and dealers using their registration number, business name, or postcode or call 03708 506 506." An upper tier registration "allows a person or organisation to transport other people's waste", which is what a venue's collector needs. Note the asymmetry the code describes: a carrier "must present evidence of registration if requested", and failing to do so without reasonable excuse is an offence, but nothing forces them to show it to you unprompted.

3. **Check each note against the contents list in the code, field by field, rather than reading it for tone.** The code says the description must be accurate and must include the classification by List of Wastes code, "its quantity and nature and whether it is loose or in a container", "if in a container, the type of container", "the time and place of transfer", "the SIC code of the transferor", "the name and address of the transferor and transferee (person receiving the waste) and their signatures", and "the capacity in which the transferor and transferee are acting (for example, as a producer, importer or registered waste carrier, broker or dealer) and their relevant authorisation to act in that capacity (for example, their permit number or registration number)". A note missing the SIC code or a signature is not a lesser note, it is an incomplete one, and the register should say which field is absent.

4. **Confirm the waste hierarchy statement is on the note, because it is the field most often blank.** The code sets it out as a separate requirement: "The description contains a statement confirming that you have fulfilled your duty to apply the waste hierarchy as required by regulation 12 of the Waste (England and Wales) Regulations 2011." Regulation 12 requires an establishment or undertaking, on the transfer of waste, to "take all such measures available to it as are reasonable in the circumstances to apply the following waste hierarchy as a priority order", being prevention, preparing for re-use, recycling, other recovery, and disposal. A pre-printed tick on a collector's form is a declaration made in your name, so it belongs in the register with the words it uses.

5. **Use a season ticket where the same waste goes to the same carrier, and diary its expiry.** The code describes it as "a single waste transfer note that covers a series of non-hazardous waste transfers", which "can last up to one year and be used for regular transfers of the same type of non-hazardous waste with the same carrier". Multiple sites served by the same carrier "can be listed in a schedule to the season ticket". It carries an extra obligation that is easy to miss: "You should keep a record of the collection times and the quantity of waste". So a season ticket does not remove the record keeping, it moves it from the note to a log, and the register needs a column saying where that log is and who writes it.

6. **Separate hazardous waste onto consignment notes and stop calling them transfer notes.** The code is emphatic that a consignment note "applies to all movements of hazardous waste including collections from businesses by registered waste carriers, movements from one premises to another within the same business and all movements from the waste producer's premises", with only two narrow exceptions, neither of which covers a venue. In hospitality the hazardous items are rarely the obvious ones: fluorescent tubes, some aerosols, waste electrical and electronic equipment, batteries, certain cleaning chemicals and anything the Simpler Recycling guidance excludes as "packaging that has contained white spirits, paints, engine oils or antifreeze". Each of these gets its own row and its own document type in the register.

7. **Note that an internal move usually needs no note, and record it anyway.** The code says a waste information note "is not required for non-hazardous waste if the waste holder does not change on the transfer of waste - for example, the waste is moved to other premises belonging to the same business", and then adds the practice that saves an argument later: "it is best practice that the business understands who has responsibility for that waste and a record is kept of internal transfers for audit purposes". A group moving waste between two pubs, or a hotel consolidating into a shared bin store, is exactly this case. Hazardous waste is the exception and still needs a consignment note even inside the same business.

8. **Set a retention date on every document and put it in the register rather than in someone's head.** The code gives the periods: "2 years for non-hazardous waste", "2 years for season tickets", and "three years for hazardous waste consignment notes". Retention matters because of what happens when it fails: "If an authorised officer of the EA, NRW or local authority asks you to provide the written description of waste, or a copy of it, and you fail to do so, they can issue a fixed penalty notice." Section 34(6) sets the wider exposure for the duty itself, a fine on summary conviction not exceeding the statutory maximum and, on conviction on indictment, a fine, which the code restates as "an offence with no upper limit on the courts' power to fine".

9. **Publish the register with the gaps at the top, and date the whole file.** Three groups, clearly headed: transfers with no note at all, notes missing a required field, and carriers not yet checked on the register. Each item names the collector, the waste stream, the date range affected and one action with an owner. Then the file's build date and, beside every quoted requirement, the date that source was read. Section 34(10) is the reason to keep the code's wording rather than a summary of it: a code of practice issued under section 34(7) "shall be admissible in evidence and if any provision of such a code appears to the court to be relevant to any question arising in the proceedings it shall be taken into account".

## Then it checks

1. Every waste stream leaving the site appears in the register exactly once per collector, including the ones with no contract, and none is listed only as "general waste".
2. Every note is checked against all nine contents requirements from the code, and each missing field is named rather than the note being marked incomplete.
3. Every carrier row records a registration number, whether it was checked on the Environment Agency public register, and the date of that check, with no row reading "known to us" or "they said they are registered".
4. Every hazardous item is on a consignment note rather than a transfer note, and no hazardous item sits in a season ticket.
5. Every document carries a retention date calculated from its own transfer date using the period for its type, and no retention date is earlier than today without being flagged.
6. Nothing in the file states that the site has met its duty of care, and every quoted requirement names its source and the date that source was read.

Any check fails: name it, redo that step once. Failed twice: say what is wrong and stop.

## Rules
- Public information only.
- Never invent a fact, a number or a quote.
- Anything sent in someone's name says whose name it is. A waste transfer note is signed by a person and the register records which person.
- Never sign or complete a transfer note on the owner's behalf, and never fill a missing field with a plausible value. A signature and a description are legal declarations by the transferor, and a guessed List of Wastes code is a misdescription rather than a tidy record.
- Never record a carrier as registered without a check date. The code makes the check a reasonable measure, and an unchecked assumption recorded as a check is worse than an empty cell because it stops anyone checking.
- Never tell an owner they have met their duty of care or that their paperwork is compliant. That is decided by a regulator or a court, and the code is admissible evidence in that decision.
- Never state a fine amount, a typical penalty, or the likelihood of enforcement. The statute provides for a fine with no upper limit on indictment and quoting a figure invites an owner to price the risk.
- Refuse to backdate a note, to reconstruct a transfer note for a collection that has already happened without the carrier's involvement, or to record an estimated quantity as a measured one.
- This output is a working document prepared for the owner to check with their waste collectors and, where enforcement is in prospect, with their solicitor or the Environment Agency, before it is relied on. It gathers published requirements, records what the site holds and names the gaps. It is not legal advice and it does not certify that the duty of care has been met.

## Built from
- Environmental Protection Act 1990, section 34, as in force on 16 September 2026, https://www.legislation.gov.uk/ukpga/1990/43/section/34, read 16 September 2026: the scope of the duty in step 1, the written description requirement at section 34(1)(c)(ii), the penalties at section 34(6) in step 8, and the admissibility of the code at section 34(10) in step 9.
- Defra and the Environment Agency, "Waste duty of care: code of practice (accessible version)", statutory guidance issued under section 34(7), https://www.gov.uk/government/publications/waste-duty-of-care-code-of-practice/waste-duty-of-care-code-of-practice, updated 26 November 2018, read 16 September 2026: the CBDU format and register wording in step 2, the full contents list for a written description in step 3, the waste hierarchy statement in step 4, the season ticket rules in step 5, the consignment note rules in step 6, the internal transfer position in step 7, and the retention periods and fixed penalty in step 8.
- The Waste (England and Wales) Regulations 2011, SI 2011/988, regulation 12, https://www.legislation.gov.uk/uksi/2011/988/regulation/12/made, read 16 September 2026: the five-step priority order that the hierarchy statement in step 4 is declaring compliance with.
- Environment Agency, "Register of Waste Carriers, Brokers and Dealers", https://environment.data.gov.uk/public-register/view/search-waste-carriers-brokers, no publication date shown on the page, read 16 September 2026: the live register the carrier check in step 2 and check 3 is made against.
- GOV.UK, Department for Environment, Food and Rural Affairs, "Simpler recycling: workplace recycling in England", https://www.gov.uk/guidance/simpler-recycling-workplace-recycling-in-england, published 29 November 2024, last updated 3 October 2025, read 16 September 2026: the requirement to use a registered collector, and the list of excluded packaging that has contained white spirits, paints, engine oils or antifreeze used to spot hazardous items in step 6.

This is a working document prepared for the owner to check with their waste collectors and their own adviser before it is relied on. It is not legal advice and it does not certify that the duty of care has been met.

# waste-transfer-notes

## You are given
Every waste document a hospitality site holds, as supplied files: waste transfer notes, season tickets and their schedules, hazardous waste consignment notes, invoices used in place of notes, and any log of collection times and quantities. Alongside them: a list of every waste stream leaving the site with the collector who takes it and the collection frequency, already compiled by Claude; each collector's name and carrier registration number; for each carrier, whether a check against the Environment Agency public register was made and on what date; Claude's judgement of which streams are hazardous and which are not, with the reason; the list of required written-description fields taken from the statutory code of practice, with the code's URL and the date it was read; and the retention period for each document type. Where a judgement or a check is missing it arrives as the word `not supplied`.

## Produce
Write into a `./waste-transfer-notes-output/` folder:

1. `transfer-register.csv` with these columns in this order: `transfer_ref`, `waste_stream`, `hazardous`, `collector_name`, `carrier_registration_number`, `document_type`, `document_reference`, `transfer_date_or_period`, `quantity_recorded`, `quantity_basis`, `container_type`, `loose_or_contained`, `document_supplied`, `retention_period`, `retention_expiry_date`. `transfer_ref` is T001 upward. `hazardous` is `yes`, `no` or `not supplied` and is copied from the input, never decided here. `document_type` is exactly one of `waste transfer note`, `season ticket`, `consignment note`, `invoice used as a note`, `none supplied`. `quantity_basis` is exactly one of `weighed`, `read from document`, `estimated by site`, `not supplied`. `retention_period` is `2 years`, `3 years` or `not applicable`.
2. `note-field-check.csv` with columns: `transfer_ref`, `document_reference`, `low_ewc_code`, `quantity_and_nature`, `loose_or_container_stated`, `container_type_stated`, `time_and_place_of_transfer`, `transferor_sic_code`, `transferor_name_and_address`, `transferee_name_and_address`, `both_signatures_present`, `capacity_of_each_party`, `authorisation_number_of_each_party`, `hierarchy_statement_present`, `hierarchy_statement_verbatim`, `fields_missing_count`. Every field column except the last two is exactly one of `present`, `absent`, `illegible`. `hierarchy_statement_verbatim` is copied exactly from the document or left empty.
3. `carrier-check.csv` with columns: `collector_name`, `carrier_registration_number`, `number_matches_cbdu_format`, `register_checked`, `register_check_date`, `registration_tier_recorded`, `streams_collected`, `evidence_of_registration_supplied`. `register_checked` is `yes` only where a check date was supplied, otherwise `no`. `number_matches_cbdu_format` is a pattern test on the supplied string and is `yes`, `no` or `not supplied`.
4. `hazardous-separation.csv` with columns: `transfer_ref`, `waste_stream`, `hazardous`, `document_type`, `correct_document_for_type`, `note`. `correct_document_for_type` is `yes` where a hazardous stream sits on a consignment note or a non-hazardous stream sits on a transfer note, season ticket or invoice, and `no` otherwise. Every `no` row is also listed in `gaps.md`.
5. `season-tickets.csv` with columns: `document_reference`, `collector_name`, `waste_streams_covered`, `sites_in_schedule`, `start_date`, `end_date`, `duration_days`, `exceeds_one_year`, `collection_log_location`, `collection_log_maintained_by`. `exceeds_one_year` is `yes` where `duration_days` is greater than 365.
6. `retention-diary.csv` with columns: `document_reference`, `document_type`, `transfer_date_or_period`, `retention_period`, `retention_expiry_date`, `already_expired`, `where_the_original_is_held`, `format`. `format` is `paper` or `electronic`. `already_expired` is computed against 16 September 2026 or the build date supplied, whichever is later, and says which was used.
7. `gaps.md` - a numbered list of: every waste stream in the input with no document supplied; every note with one or more `absent` fields, naming each field; every note with no hierarchy statement; every carrier with no register check date; every carrier registration number that fails the CBDU pattern; every hazardous stream not on a consignment note; every season ticket exceeding one year or with no collection log location; every document whose retention date has already passed; and every quantity recorded as `estimated by site`.

## Rules
- Codex measures, records and checks. It never invents, never completes a missing field on a note, never rewords a description supplied by the owner or the carrier, and never makes the hazardous or non-hazardous judgement that was supplied to it.
- Never write a List of Wastes or European Waste Catalogue code that is not printed on the supplied document. A guessed code is a misdescription, not a tidy record.
- Never mark a field `present` unless it is readable on the supplied document. Where a document could not be opened, every field is `illegible` and the document is listed in `gaps.md`.
- Never write `yes` into `register_checked` without a supplied check date, and never infer a registration from a collector's name appearing on an invoice.
- Never state that the duty of care has been met, that the paperwork is compliant, or that a penalty will or will not follow. Those statements go nowhere in any file.
- Never write a fine amount, a typical penalty, an enforcement rate or an industry average. None is to appear in any file.
- Never create, backdate or reconstruct a transfer note. Where a transfer has no document, the row says `none supplied` and the transfer is listed in `gaps.md`.
- Quantities are read from a document or weighed. Anything else is recorded with `quantity_basis` of `estimated by site` and is never presented as a measurement.
- Use British English, GBP for money and DD Month YYYY for every date. No em dashes in any file you write, and any supplied text containing one is recorded verbatim and flagged in `gaps.md`.
- Every file ends with this line: this is a working document prepared for the owner to check with their waste collectors and their own adviser before it is relied on; it is not legal advice and it does not certify that the duty of care has been met.

## Return
The absolute path of each file written, the row count of each CSV, the number of waste streams in the register and how many have a document supplied, the number of notes checked and the total count of `absent` fields with the three most common fields named, the number of notes carrying a hierarchy statement, the number of carriers with a register check date and the number without, every carrier registration number failing the CBDU pattern, the count of hazardous streams on the wrong document type with each named, the number of season tickets exceeding one year, the number of documents whose retention date has already passed and the date used for that comparison, the count of quantities recorded as estimated, and the `gaps.md` item count.