Digital waste tracking
Does digital waste tracking replace paper waste transfer notes?
Last checked 8 September 2026
No. Digital waste tracking is recorded alongside the existing paperwork, not instead of it. This is one of the most repeated errors written about the change, and it matters in both directions: a business that throws away its transfer notes is in breach, and one that assumes nothing has changed misses a new duty that starts on a fixed date.
What carries on unchanged
Waste transfer notes, and hazardous waste consignment notes where they apply, continue exactly as they do now. You still describe the waste correctly, you still check that whoever takes it is registered to, and you still keep the paperwork for the same period — two years for a transfer note, three for a hazardous consignment note. Quarterly consignee returns continue for the sites that file them.
The clearest evidence of this is the government’s own duty-of-care guidance, which at the time of writing still describes transfer notes, season tickets and the two-year retention period without mentioning digital waste tracking at all.
What is genuinely new
From 1 October 2026 in England and Wales, a permitted or licensed site that receives waste must record each load it takes in on the tracking service, within two working days of the day after it arrives. That duty sits with the receiving site. It does not remove a single existing document, and it places no duty at all on the business that produced the waste.
The written route the law keeps open
There is a second reason “no more paper” is wrong, and it is written into the regulations themselves. An operator who is a digitally excluded person is exempt from the duty to use the service, and instead keeps a written record of the same information — one that carries a number issued for the purpose. That number is the point: this is a formal status recognised by the regulator, not a decision an operator takes to stay on paper.
The test is set in law and it is a high bar. It covers a practising member of a religious society or order whose beliefs are incompatible with keeping electronic records, and a person for whom keeping them is not reasonably practicable for any reason — the legislation gives age, disability and location as examples. “Not reasonably practicable” is a good deal stronger than inconvenient, and whether it is met is a judgement for the regulator rather than for the operator or for us.
Almost every site will not qualify, and should plan on using the service. But an outright claim that the change ends paper is inaccurate as a matter of law, not just as a matter of tone.
Where this comes from
- The Digital Waste Tracking (England) Regulations 2026 — regulation 4 for the duty on a permitted facility, regulation 8 for the written record kept by a digitally excluded operator and the number it must carry.
- Environmental Protection Act 1990, section 34CA — subsection (12) defines “digitally excluded person”.
- GOV.UK: waste transfer notes — the duty-of-care guidance that continues to apply.
This page summarises published rules and legislation, and links to each source so you can check it. It is general information, not legal advice on your own circumstances. The Northern Ireland date has not been legislated for; Scotland has its own instrument, which this answer does not cover.