Waste transfer notes for window installers

What Section 34 says

Section 34 of the Environmental Protection Act 1990 sets the duty of care for anyone who produces, imports, keeps, treats or transports controlled waste in England and Wales. You must take all reasonable measures to:

• Prevent the waste from escaping your control or anyone else's.
• Prevent any breach of the environmental permitting regime by another person.
• Make sure the waste is only transferred to an "authorised person", usually a registered waste carrier or a permitted facility.
• When you transfer the waste, give a written description of it sufficient to allow the next holder to handle it lawfully.

That last point is the waste transfer note: the written description, plus the signatures and references that prove the chain.

Get any of those wrong and the offence is yours, whoever you handed the load to. The maximum penalty is unlimited.

Who counts as the waste producer

A common mistake in the window trade is thinking the old windows are the homeowner's waste. The moment your fitters lift a frame off the wall and load it into the van, you are the waste producer and the waste holder, and your name goes on the eWTN.

That applies whether you're:

• A one-man installer doing a single replacement window on a Saturday;
• A regional firm running ten vans on housing-association stock;
• A fabricator delivering and installing on a one-off commercial job;
• A trade counter offering an "old windows taken away" upsell on behalf of a customer.

The waste belongs to whoever had it when it left the site, and on a replacement job that's almost always you.

Skipping the paperwork because it's "only one or two frames" is still an offence. Section 34 has no minimum.

What an eWTN must contain

Under the Waste (England and Wales) Regulations 2011, a waste transfer note, paper or electronic, has to record a set list of information. A compliant eWTN identifies:

• The waste itself: a written description of what's being transferred, with the European Waste Catalogue (EWC) code. For mixed uPVC frames pulled from a domestic replacement, that's typically 17 02 03 (plastic from construction and demolition). Sealed units fall under 17 02 02 (glass) or, where coated, alternative codes. Mixed C&D loads have their own codes again.
• Quantity: weight or, where you can't weigh it, an honest estimate by volume or count. "One transit van load, approximately 0.4 tonnes" is fine, but just writing "some" isn't.
• How the waste is contained: loose, in a skip, in a cage, in bulk bags.
• The transferor: your business name, address, and your role in the chain (waste producer or current holder).
• The transferee: the carrier you're handing it to, including their carrier registration number.
• The site of transfer: where, when, and from which address the load was collected.
• SIC code: the Standard Industrial Classification code for the business producing the waste. For most window installers that is 43.34 (painting and glazing) or 43.32 (joinery installation), depending on how your firm is registered at Companies House.
• Carrier registration: confirmation that the carrier is registered with the Environment Agency and at what tier (lower or upper).
• Waste hierarchy declaration: written confirmation that the producer has applied the waste hierarchy under Regulation 12 of the 2011 Regulations.
• Signatures: both parties confirm and sign. On an eWTN this is usually a digital tick or a system audit log.

If your transfer note doesn't have all of those, it isn't compliant, whatever the letterhead looks like.

Electronic or paper notes

The Environment Agency has been pushing electronic notes for years, for good reasons.

• Harder to lose. A paper note in a folder in the back of a transit is gone the moment the folder gets damp. An eWTN sits in your inbox and your carrier's system.
• Faster to issue. An eWTN is usually with you within 24 hours of collection. We do that as standard from all our hubs.
• Cleaner audit trail. Annual returns and council framework audits want tonnage totals. eWTNs give you that without typing it all up.
• No carbon copies. There are no half-legible signatures on triplicate paper, and nobody has to post you the carrier copy a week later.

Paper notes are still legal.

How long to keep them

Waste transfer notes must be kept for a minimum of two years from the date of transfer and produced on request to the Environment Agency, a council or any authorised officer. Hazardous waste consignment notes (a different document, under the Hazardous Waste (England and Wales) Regulations 2005) must be kept for three years.

uPVC frames aren't hazardous waste under normal conditions. Some old stock contains lead stabilisers, which have been phased out, but mixed-frame loads from normal domestic replacement work are handled as non-hazardous construction waste under 17 02 03. If a load includes anything hazardous (asbestos sealant or certain coatings, for example), that goes on a separate hazardous waste consignment note and you keep it for three years.

We'd say don't bin anything under five years old. Digital storage costs nothing, and an audit or a framework re-tender will ask for history going back further than the legal minimum.

Common mistakes

Almost every duty-of-care problem we see comes down to the same handful of mistakes.

Handing waste to an unlicensed mate

"My cousin's got a tipper, he'll take it for a tenner." Unless your cousin is registered with the Environment Agency as a waste carrier, and you can produce his registration number, you've just transferred waste to an unauthorised person. That's a Section 34 offence. If he fly-tips it, that's on you too, because you didn't take reasonable measures.

Accepting "we'll sort the paperwork later"

The eWTN has to exist at the point of transfer. A note written up from memory three weeks later only shows that you didn't have one at the time.

Wrong EWC code

Putting "17 09 04" (mixed C&D waste) on a clean uPVC load is wrong, costs you money, and undermines your hierarchy declaration, because a mixed-waste code says the material can't be separated for recycling, which for uPVC is plainly untrue.

Not checking carrier registration

You have to take "reasonable measures" to confirm your carrier is authorised. That means looking up their registration number on the Environment Agency's public register before the first collection, keeping a screenshot in your files, and checking again when it's due for renewal. Registrations expire every three years.

Missing waste hierarchy declaration

The hierarchy declaration is easy to forget and often missing from home-made paper notes. Every one of our eWTNs has it filled in and ticked.

If the load you handed over ends up in a hedge, the eWTN is the only thing standing between you and personal liability.

Penalties and lost contracts

Section 34 offences are prosecuted by the Environment Agency and, increasingly, by councils under their fly-tipping powers. For a window installer the realistic consequences are, roughly in order of likelihood:

• Fixed penalty notice for failing to produce a transfer note on demand, usually a few hundred pounds.
• Magistrates' court fine for repeat or serious failures: unlimited in theory, usually in the low thousands.
• Crown court prosecution for serious cases, such as waste handed to an unlicensed carrier who then fly-tipped at scale, with unlimited fines and, in extreme cases, prison for directors.
• Loss of contracts. For any installer on council, housing association or commercial framework work, a duty-of-care failure on file can knock you out at the next tender.

The contract risk is the one that bites first. For the wider picture, see why landfill is no longer an option, and for fabricators, offcut recycling.

Setting up a routine

You need a folder, a routine and a carrier who issues the paperwork on time. A setup that works:

1. Pick one waste carrier as your default for uPVC and glass and get their registration number on file (ours is printed on every transfer note we issue). Note the renewal date.
2. Use the same EWC codes every time. For domestic uPVC replacement work that's nearly always 17 02 03 for frames and 17 02 02 for sealed-unit glass.
3. Insist on eWTNs by email, within 24 hours of every collection. If your current carrier can't manage that, change carrier.
4. Keep eWTNs in one folder, by year, job or site, whichever matches how you already file job packs. Cloud storage is fine.
5. Once a year, pull a tonnage summary across all eWTNs for environmental reporting and framework renewals. Your carrier should be able to issue this for you.
6. If you're ever unsure about a load (old leaded coatings, asbestos sealant, anything hazardous) stop and ask before you load it. The right code on the right note is the difference between a routine collection and a notifiable incident.

Set up like this, it's fifteen minutes of admin a month.

How we handle the paperwork

Every collection from any of our hubs comes with a compliant eWTN, issued within 24 hours and emailed to your nominated contact. EWC codes are matched to the load type, the SIC code is taken at quote, the hierarchy declaration is built into the form, and our Environment Agency Upper-Tier Waste Carrier registration is on every note. Annual recycling reports are available on request. See the compliance section on the homepage for the full list.

We also run separate site waste skips for wood, hardcore and general waste, with the same paperwork.

If you've inherited a paperwork mess from a previous carrier, or you're going into a framework re-tender and want to tighten up, get in touch. We'll go through what you've got, show you where the gaps are and quote within hours.