Managing controlled waste - code of practice consultation on duty of care: SG response

Section 8: Transfer Notes

Are you content with the clarity of this section and how it has changed from the current Code?

We received 17 responses to this question, of which 12 respondents answered ‘Yes’, 2 answered ‘No’, and 2 answered ‘Don’t Know’.

The majority of respondents were content with the clarity of this section and stated that it was an improvement on the current Code. Respondents highlighted the strengthened emphasis on accurate waste descriptions and traceability, and the content and purpose of Waste Transfer Notes. Respondents also noted that the section should be updated to reflect the introduction of Digital Waste Tracking.

Further points raised included:

• The need for educational campaigns aimed at householders to raise awareness of waste transfer notes.
• The inclusion of WUDS and POPs under “What is an adequate waste description”.
• Whether season tickets align with mandatory waste data tracking, and whether an invoice can be used as a waste transfer note.
• Explicit reference to electronic transfer notes.
• Guidance on retention and distribution of confidential waste certificates.
• Clarification on expectations for multi-site organisations with centralised waste governance.

Government response:

We have updated the Code to clarify that waste transfer notes must be provided for each transfer of waste, and we provided the full list what a transfer note must include as set out in the Regulations. We have also updated Sections 4 and 5 of the Code to highlight that from 1 January 2027 operators of in-scope permitted facilities receiving controlled waste must ensure the entry of information regarding that waste into the digital waste tracking system, in line with requirements established under The Digital Waste Tracking (Scotland) Regulations 2026.