Regulations · 4 min read · Updated 6 November 2026
IT disposal paperwork: transfer notes, consignment notes and tracking
Why the paperwork matters
Under the waste duty of care in section 34 of the Environmental Protection Act 1990, every business that produces waste must take reasonable steps to make sure it is handled, transported and treated lawfully. Old laptops, monitors, servers and phones are waste the moment you decide to get rid of them, even if they still work and are later refurbished.
The paperwork is your evidence that you met that duty. If equipment you handed over is later found fly-tipped or exported illegally, the first question a regulator will ask is who produced it and what records they kept. A certificate of data destruction proves your data was dealt with. It does not prove the waste was handled legally, so you need both.
The documents you need
| Document | When it applies | Keep it for |
|---|---|---|
| Waste transfer note | Non-hazardous IT such as laptops, desktops, LED screens, network kit | At least 2 years |
| Hazardous waste consignment note (England and Wales) | CRT monitors, CCFL-backlit flat screens, lead-acid UPS batteries and similar | At least 3 years |
| Special waste consignment note (Scotland) | Hazardous items under the Scottish regime | At least 3 years |
| Certificate of data destruction or erasure | Any device that held data | In line with your data retention policy, often 6 years |
| Asset or collection report | Every collection, listing serial numbers | With your asset register |
A single annual transfer note, sometimes called a season ticket, can cover repeated collections of the same type of waste by the same carrier, which is useful if you have regular pick-ups.
What a transfer note must show
- A description of the waste and its European Waste Catalogue code, such as 16 02 14 for non-hazardous discarded equipment or 20 01 36 for similar items from offices
- How it is contained, for example cages, pallets or locked bins
- The quantity, by weight or item count
- The place and date of transfer
- Names and addresses of both you and the carrier
- The carrier's waste carrier registration number
- The SIC code of your business
- Signatures from both parties
Most reputable collectors produce the note for you. Your job is to check it is filled in correctly before you sign, and to keep a copy.
Check the carrier before they arrive
Anyone who collects waste from a business as part of their own business must be registered as a waste carrier. In England you can search the Environment Agency public register by name or registration number in a couple of minutes. Wales, Scotland and Northern Ireland have their own registers run by Natural Resources Wales, SEPA and NIEA.
Check that the registration is current and that the name matches the company on the quote. Also ask where the equipment will be taken and whether that site holds an environmental permit or registered exemption to treat WEEE. A collector who cannot name the receiving site is a warning sign.
Digital waste tracking from October 2026
The government's digital waste tracking service became mandatory for waste receivers in England and Wales on 1 October 2026, with Scotland and Northern Ireland due to follow in January 2027. Permitted and licensed sites must record every load they receive, usually within two working days.
A later phase, currently planned for spring 2027, is due to bring in waste carriers, brokers and dealers. Producers, meaning the businesses getting rid of old IT, have no new reporting duty in this first phase, but your disposal provider may ask for extra detail at collection so the receiving site can report accurately. Paper or electronic transfer and consignment notes continue alongside the new system until the government says otherwise.
Common paperwork gaps
- No transfer note at all because the equipment was described as working stock rather than waste
- Hazardous items such as CRTs or UPS batteries mixed in with non-hazardous kit on one transfer note
- A destruction certificate with no serial numbers, so it cannot be matched to your asset register
- Notes signed by someone who has left, with no copy kept centrally
- Carrier registration never checked
A simple fix is to keep one folder per collection with the quote, transfer or consignment note, collection report and destruction certificate together.
Give one role, such as the office manager or IT lead, ownership of the folder, and store it somewhere that survives staff changes, such as a shared drive with restricted access. When an auditor, customer or regulator asks how a particular laptop was disposed of, you should be able to find the answer from its serial number in a few minutes.
Frequently asked questions
Do I need a waste transfer note if the equipment is being reused?
Usually yes. If you are discarding equipment, it is waste in law even if the collector plans to refurbish and resell it. The exception is a genuine sale of working equipment as a product to a buyer who will use it, rather than handing it over for treatment. If in doubt, ask for a transfer note, since it costs nothing and protects you.
Do I need to register as a hazardous waste producer?
Not in England, where premises registration was abolished in 2016, although consignment notes are still required. In Wales, premises that produce or hold more than 500 kg of hazardous waste a year still need to register with Natural Resources Wales. Scotland and Northern Ireland run their own systems, so check with SEPA or NIEA.
Does digital waste tracking mean I can stop keeping transfer notes?
No. For now, transfer notes and hazardous waste consignment notes are still required alongside the new service, and you should keep them for the usual two and three years. The government has said paper notes may eventually be replaced, but until official guidance changes, keep producing and storing them as before.
duty of care waste transfer notes digital waste tracking compliance
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