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Plans to allow greater flexibility over the types of documents that can be used as an alternative to Waste Transfer Notes (WTNs) has been confirmed by Defra, despite deep divisions among councils and businesses over the issue.


This decision comes after a six week consultation which was launched in December 2013 under the governments Red Tape Challenge, which proposed amending regulations to include alternative types of documentation to WTNs, such as invoices, order and receipts, in order to reduce the burden on businesses.

Under UK law, all businesses have a Duty of Care to ensure they produce, store, transport and dispose of their waste without harming the environment. To provide evidence of this, firms must complete a WTN every time waste is passed from one part to another – and keep them for at least two years.

However, at present at least 23.5 million WTNs are being produced every year – meaning around 50 million pieces of paper being stored at any one time.

Defra and the Welsh Government directly contacted more than 700 stakeholders inviting their views on the WTN system. In total, 67 recipients responded– made up of 35 local authorities, 15 trade associations, 13 private businesses, two individuals, one charity and one government department.

Asked whether amending the regulations to include other documentation would provide any benefits, over 60% of respondents were against the proposal, with just 31.8% saying they would support the move.

In total, 23 of the 35 local authorities consulted were against the amendments, although opinions among trade associations and businesses were more evenly split – the outcome saw six trade associations in favour and eight against the proposals.

However, many of the respondents were concerned that amending the system would undermine current legislation and create confusion for regulations when checking compliance, while others proposed it would devalue the launch of the Electronic Duty of Care (Edoc) tool made available in January to provide an online platform for completing WTNs.

The councils, bodies and businesses in support of the changes argued that alternative documentation could help to reduce costs and administrative time when recording the written description of waste.

Justifying Defra’s decision to implement the amendments, the report concludes that despite acknowledging the concerns of respondents, those who found there were limited benefits or savings to be made could choose to continue using WTNs to record transfers or migrate to Edoc.

The report states:

“Given the strong government commitment in response to the Red Tape Challenge to provide for alternatives to WTNs and the support of businesses including key stakeholders such as the Federation of Small Businesses and the National Farmers Union, Defra and the Welsh Government intend to proceed with the proposed amendments to the 2011 Regulations and, from April 2014, allow alternative documentation to be used to record the written description of waste.”

In addition, the consultation queried businesses on what would encourage them to sign up to Edoc, which the Environment Agency estimates will potentially move 80% of waste transfer records online over time and become the default option for most companies.

It found that just over 19% of the 57 respondents that answered the question did not believe Edoc would provide a better system than WTNs. Many stated that cost was the main incentive for using the system, which some arguing it should remain free.


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