WTN compliance - Updated 16 July 2026

Are Paper Waste Transfer Notes Still Legal?

Paper waste transfer notes are still part of current UK waste duty of care record keeping, but businesses can also keep electronic copies and should prepare for digital waste tracking requirements.

Key points

Current GOV.UK guidance says a paper or electronic copy can be kept for two years.
A WTN or equivalent document is needed for each load of non-hazardous waste moved off premises.
Digital waste tracking is being introduced in phases, starting with permitted waste receiving sites.
Moving to digital WTNs now can reduce admin and prepare teams for future reporting.

Current position on paper WTNs

GOV.UK guidance says businesses moving non-hazardous waste need a waste transfer note or a document with the same information, such as an invoice. Both businesses involved need to sign it and keep a paper or electronic copy for two years.

Electronic copies are already allowed

The important point is not simply whether the record is paper or electronic. The record must contain the required information, be signed where required, be kept for the retention period and be available if an enforcement officer asks to see it.

What digital waste tracking changes

Digital waste tracking will introduce mandatory digital reporting in phases. It does not mean every current paper WTN became illegal overnight, but it does mean businesses should track official guidance for when their activities come into scope.

Why switch before you have to?

Digital records are easier to search, email, back up, connect to invoices and standardise across drivers than handwritten forms.

Frequently asked questions

Can I still use paper waste transfer notes?

Current GOV.UK guidance still refers to waste transfer notes and says businesses must keep a paper or electronic copy for two years. Requirements may change as digital waste tracking phases come into force.

Is an electronic copy acceptable?

GOV.UK guidance says businesses can keep a paper or electronic copy for two years.

Will digital waste tracking replace WTNs?

Government consultation material says digital waste tracking requirements will replace existing requirements to complete waste transfer notes and hazardous waste consignment notes where a record is required.