Special waste consignment notes in Scotland: SEPA codes, pre-notification and copies

By James Parry, head of product at Tippa · Last reviewed

In short: in Scotland, hazardous waste is called special waste. Every movement of special waste produced in Scotland needs a consignment note carrying a unique code bought from SEPA, usually an SA code at £15. The consignor, carrier and consignee each fill in their own parts of the note, and the site that receives the waste sends SEPA a completed copy straight away. You don't need to pre-notify SEPA when the waste starts and ends in Scotland. Cross-border moves have their own rules.

What special waste is and which law applies

SEPA describes special waste as waste with hazardous properties, and its guidance says it may also be called hazardous waste. In law, special waste is waste listed as hazardous in the List of Wastes (subject to any concentration limits), or waste determined to be hazardous. A code with an asterisk is hazardous: see our guide to EWC codes.

The main law is the Special Waste Regulations 1996. They were revoked in England and Wales in 2005 and do not extend to Northern Ireland, so today they are Scotland's rules. SEPA's main guidance on them is WAS-G-HAZ-02, "Consigning special waste". It applies only to producers of special waste in Scotland: producers elsewhere in the UK follow their own country's law.

The people involved have set names. The consignor is the person who causes the waste to be removed from where it is held, but not a householder for their own household waste. The carrier collects and transports it. The consignee is the person it is being taken to.

Who needs a consignment note

A consignment note is needed whenever a consignment of special waste is to be removed from the premises where it is held. SEPA puts it plainly: all special waste produced in Scotland must be consigned using a note or code issued by SEPA, wherever in the UK it is going.

SEPA's guidance also covers some common cases:

  • Moving waste around your own site: no note is expected for movements between buildings on a site owned or occupied by the same business, as long as the waste doesn't pass to anyone else. Moving it on to a waste site does need one.
  • Several businesses on one site, such as an industrial estate: movements between them need a note.
  • Movements within a group of companies, such as to another company's depot, need a note raised by the consignor.

A special waste consignment note is not a waste transfer note, and SEPA says moving special waste on a note that doesn't match the form in Schedule 1 of the regulations may be a criminal offence. Failing to meet any duty in the regulations is an offence, with a fine on summary conviction up to level 5, or on indictment a fine, up to two years in prison, or both. SEPA can also issue a fixed monetary penalty of up to £600 or a variable monetary penalty.

Getting a consignment code from SEPA

Every note must carry a unique code supplied by SEPA: two letters (SA, SB or SC) and a number, for example SA 1234567. The law says SEPA need not issue a code until its fee is paid. There are three kinds:

CodeCostUsed for
SA£15 eachSingle movements and carrier's rounds: everything not covered by SB or SC
SB£10 eachLoads made up only of lead acid motor vehicle batteries
SCFreeOnly the second and later rounds of an extended carrier's round, returning out-of-specification materials to the original manufacturer, and waste removed from a ship

Those prices are from SEPA's special waste page and its guidance, and match the regulations. To get codes:

  • By card: buy SA and SB codes online from SEPA's web payments service. The codes are issued with your receipt.
  • By BACS or purchase order: email swcnorder@sepa.org.uk.
  • SC codes for extended carrier's rounds or offshore waste landings: email swcnorder@sepa.org.uk.

Each code must be unused and not shared with another movement. SEPA may give credit for a code that was never used and never sent to SEPA. It gives no credit once a code has been notified to SEPA, even if no waste moved.

SEPA no longer supplies paper notes. Its preferred format is its Excel note, and PDF versions, a carrier's schedule and a supplementary sheet are on the same page. You can use your own design if it has the information in Schedule 1 and a SEPA code, and SEPA has agreed its format. Email swcnenquiries@sepa.org.uk before using one.

Pre-notifying SEPA

Pre-notification means sending the regulator a copy of the note before the waste moves. The regulations ask the consignor to send a copy, with Parts A and B filled in and the code entered, to the regulator for the place the waste is going. It must arrive not more than one month and not less than 72 hours before the waste is removed. Saturdays, Sundays, Good Friday, Christmas Day, bank holidays and other public holidays don't count towards the 72 hours. The regulations also list cases that don't need one, such as later loads in a succession and loads of lead acid motor vehicle batteries.

Within Scotland: not needed

SEPA has adopted a regulatory position: it does not expect to be pre-notified, and will not take enforcement action, where the place the waste is moved from and its destination are both in Scotland. Because of that, SEPA says regular repeat movements (a "succession") now go as single movements.

Waste leaving Scotland

The official sources don't line up here:

SEPA's special waste page gives swcn@sepa.org.uk for pre-notifications and says to check its guidance for when they apply. If you aren't sure whether a movement needs one, ask SEPA at swcnenquiries@sepa.org.uk before the waste moves.

Waste coming into Scotland from England

This one is clear. The English producer, holder or consignor (or the carrier, for an English multiple collection) prepares an extra copy of the English note for SEPA and sends it at least 72 hours before the waste is removed, or as soon as reasonably practicable after that if 72 hours isn't possible. They also provide an additional copy for the consignee. Otherwise the waste is consigned as a movement within England.

The parts of the note and who fills them in

A SEPA note has five sections, A to E, each completed by the right person. Handwritten notes must be in block capitals.

PartWhat it coversWho fills it in, and when
AConsignment detailsBefore the waste is removed. SEPA recommends the person holding the waste or the consignor.
BDescription of the wasteBefore the waste is removed, by the same person as Part A.
CCarrier's certificateThe carrier, when it collects the waste, and only if satisfied that Parts A and B are right.
DConsignor's certificateThe consignor, once satisfied that Parts B and C are right, the carrier is registered or exempt, and it has been told what precautions to take.
EConsignee's certificateThe consignee, on receiving the waste, after checking Parts A to D.

In Scotland the note must show the SEPA code, the six-digit EWC code and the producer's postcode. SEPA's tips for Part B:

  • Describe the waste specifically, such as "Bonded Asbestos Panels", not just "commercial" or "industrial".
  • Give each waste type its own EWC code and its own Section B, using SEPA's additional sheet if you run out of room, with an estimated total weight for each type.
  • Components and concentrations can be given as a range, such as 5-10%, if the hazards and handling don't change across it.
  • Never describe special waste with a non-hazardous code: SEPA treats non-hazardous waste put in a container with hazardous waste as hazardous.

If the waste doesn't match the paperwork at collection, the consignor and carrier can agree only minor changes to quantity or units. If the nature of the waste or how to handle it has changed, you need a new note.

One movement can't go to more than one consignee, or to more than one authorisation (permit or licence). A site that holds several authorisations and will manage the waste under more than one of them needs a separate note for each.

Who keeps which copy

The regulations still describe paper copies. The consignor keeps one and gives three to the carrier, who makes sure they travel with the waste. The consignee completes Part E on those three. It keeps one, gives one to the carrier and sends one to SEPA. SEPA also accepts notes passed electronically and digital tracking systems (see Digital Waste Tracking, below).

The consignee's copy to SEPA

On receiving the waste, the consignee must complete Part E and "forthwith furnish one copy" to SEPA. SEPA's guidance says immediately, and asks for notes to be sent electronically to swcnreturns@sepa.org.uk.

Where the load holds wastes under different EWC codes, give an accurate total weight for each type in Part E2.

Rejected loads

If you don't accept a consignment, record on Part E that you don't accept it and why. Keep one copy, send one to SEPA straight away, with any carrier's schedule, and return the other to the carrier. If no note came with the waste, send SEPA a written explanation instead, with what you know about the consignment and the carrier. The carrier must tell SEPA and ask the consignor what to do. The consignor must then tell the carrier and SEPA what it intends.

Carrier's rounds and multiple collections

A carrier's round is a journey where a carrier collects more than one consignment of special waste and takes them all to the same consignee. SEPA's guidance sets out three types of movement:

  • Single movement: one load to one consignee, on an SA or SB note, which should be completed within 24 hours.
  • Carrier's round (24 hours): one SA note plus a carrier's schedule, completed within 24 hours. Every premises collected from must be in Scotland.
  • Extended carrier's round: only where the carrier and consignee are the same company and the premises and consignee are all in Scotland. The first round uses an SA code and later rounds to the same consignee can use free SC codes. Each round allows one consignment from each consignor, one vehicle and no more than 400kg, and later rounds must be completed within 7 days.

The carrier's schedule replaces part of Section C and all of Section D for each collection. SEPA has PDF and Excel templates, or you can agree your own version. Under the regulations, the carrier fills in Parts A and B, the code and its own details before the first collection. Each consignor completes its part of the schedule before its waste is removed, and keeps a copy of the note and of its part of the schedule. When the round is delivered, the consignee completes Part E and sends SEPA a copy of both the note and the schedule. The consignor, carrier and consignee all keep a copy of the schedule.

Collections on a carrier's round can only be made within Scotland, but the waste can be delivered to a site anywhere in the UK. The pre-notification rules above apply to a round too: the law asks for a copy at least 72 hours before the first collection, and SEPA waives that when the round and its destination are in Scotland.

England and Wales: multiple collections

England and Wales have "multiple collections" instead, with round and collection numbers. They apply only to England or Wales. A site in England that receives a Scottish carrier's round enters it on its consignee return as one entry: the details of any one producer, and the total of each waste type. More in our guide to consignee returns.

Cross-border movements

Scottish waste going to England, Wales or Northern Ireland

The waste moves on a SEPA note with a SEPA code. The site that receives it must send SEPA a copy of the completed note. For England, that duty is in Schedule 7 of the Hazardous Waste Regulations, and GOV.UK says to send SEPA a copy if you reject waste from Scotland too. GOV.UK says the note of the country of origin is used, completed under that country's law.

The waste still goes on the English site's quarterly return to the Environment Agency, as a single consignment with its code converted: SA3876543 becomes SCA038/76543. Our guide to consignee returns explains the return.

English waste coming into Scotland

It moves on an English consignment note, completed under English law. Producers outside Scotland use their own country's paperwork, and the English side must pre-notify SEPA (see Pre-notifying SEPA, above).

Scotland and Northern Ireland

According to NetRegs, when special waste goes from Scotland to Northern Ireland, the receiving site sends the completed note to NIEA, which forwards a copy to SEPA. When waste comes into Scotland from Northern Ireland, the receiving site sends the completed note to SEPA.

How long to keep notes

Each party keeps a register of its notes, with any carrier's schedules (regulation 15):

WhoHow long
Consignor, at each site waste is removed fromAt least 3 years from the day the waste was removed
CarrierAt least 3 years from the day the waste was removed
Consignee with an authorisation to treat or dispose of wasteUntil that authorisation is surrendered or revoked entirely, then the register goes to SEPA
Consignee whose activities don't need that authorisationAt least 3 years from the day the waste was received

Registers can be kept in any form that meets these rules, and SEPA inspects them. But SEPA's position on digital systems says anyone using one must still keep a paper copy of each note for their own records.

Digital Waste Tracking from 1 January 2027

From 1 January 2027, permitted facilities in Scotland receiving controlled waste must report each load to the UK's digital waste tracking service, within two working days of receiving it. For hazardous waste, each record includes the code of the consignment note that travelled with the waste, or why there was none. Our guide to Digital Waste Tracking covers who must report and what.

It doesn't replace the note yet. SEPA says the new regulations "will not immediately remove or change" any existing duty of care or waste reporting requirement. So keep buying SEPA codes, completing notes and sending the consignee's copy to SEPA.

SEPA already accepts digital notes, although Scottish law doesn't yet provide for them. Its regulatory position on digital tracking systems lets you use one if each record:

  • carries a unique SEPA code (SA, SB or SC);
  • is in a form SEPA has agreed; and
  • holds all the information in Schedule 1 of the regulations.

The consignee must still send SEPA its copy straight away, and everyone involved keeps a paper copy of each note.

How Northern Ireland differs

Northern Ireland has its own Hazardous Waste Regulations (Northern Ireland) 2005, run by DAERA through the Northern Ireland Environment Agency (NIEA), and calls it hazardous waste. The main differences from Scotland:

In England and Wales, receiving sites send a quarterly consignee return instead: see our guide to hazardous waste consignee returns.

Practical checklist

  1. Check the EWC code. If it has an asterisk, the waste is special waste and needs a note.
  2. Buy a code from SEPA before the move: SA £15, SB £10 for batteries only, SC free where it applies.
  3. Use SEPA's Excel or PDF note, or your own design agreed with SEPA. Never reuse a code.
  4. Work out whether to pre-notify. Not needed within Scotland. For waste leaving Scotland, check with SEPA. Waste coming from England must be pre-notified to SEPA by the English side.
  5. Consignor completes A, B and D. Carrier completes C. Consignee checks everything and completes E.
  6. One consignee and one permit or licence per note.
  7. On a carrier's round, keep every premises in Scotland, use a carrier's schedule and finish within 24 hours.
  8. Consignee: email the completed note, with any schedule, to swcnreturns@sepa.org.uk straight away, including rejected loads.
  9. Keep a register: at least 3 years for consignors and carriers, longer for most consignees.
  10. From 1 January 2027, permitted sites also report each load to digital waste tracking, with the note's code.

Common questions

How do I get a special waste consignment code from SEPA?

Buy it online from SEPA's web payments service, and the codes come with your receipt. SA codes cost £15 each and cover most movements, including carrier's rounds. SB codes cost £10 and are only for loads made up entirely of lead acid motor vehicle batteries. SC codes are free but only for a few cases, such as later rounds in an extended carrier's round, and you order them by email from swcnorder@sepa.org.uk, which is also the address for paying by BACS or purchase order.

Do I need to pre-notify SEPA before moving special waste?

Not when the place the waste is moved from and its destination are both in Scotland: SEPA does not expect a pre-notification and will not take enforcement action. For waste leaving Scotland, NetRegs says you must pre-notify SEPA at least 72 hours and not more than one month before the move, while SEPA's own guidance says to check with the destination's regulator, so ask SEPA if you are unsure. Hazardous waste sent from England to Scotland must be pre-notified to SEPA at least 72 hours before it moves.

Who sends the special waste consignment note to SEPA after delivery?

The consignee, the site that receives the waste. On receiving it, they complete Part E and send SEPA a copy straight away. SEPA asks for completed notes by email to swcnreturns@sepa.org.uk. A site in England, Wales or Northern Ireland that receives special waste from Scotland must also send SEPA a copy of the completed note.

What is a carrier's round for special waste in Scotland?

A journey where a carrier collects more than one consignment of special waste and takes it all to the same consignee. It goes on one consignment note with one SA code, plus a carrier's schedule with a section for each collection. Every premises must be in Scotland and the round must be completed within 24 hours, although the waste can be delivered to a site anywhere in the UK.

How long do I have to keep special waste consignment notes in Scotland?

Consignors and carriers keep a register of their notes, and any carrier's schedules, for at least three years from the day the waste was removed. A consignee with an authorisation to treat or dispose of waste keeps them until that authorisation is surrendered or revoked entirely, then sends the register to SEPA. A site whose activities don't need that authorisation keeps them for at least three years from receipt.

Will Digital Waste Tracking replace special waste consignment notes in Scotland?

Not yet. From 1 January 2027, permitted facilities in Scotland receiving controlled waste must report each load to the digital waste tracking service, including the code of the consignment note that came with hazardous waste. SEPA says the new regulations will not immediately remove or change any existing duty of care or waste reporting requirements, so consignment notes, SEPA codes and the consignee's copy to SEPA carry on.

How is Northern Ireland different from Scotland for hazardous waste consignment notes?

Northern Ireland has its own Hazardous Waste Regulations (Northern Ireland) 2005, run by NIEA for DAERA, and the term is hazardous waste rather than special waste. A copy of the note must normally reach the Department not more than one month and not less than 72 hours before the waste moves, and the consignee sends a completed copy as soon as the waste arrives. DAERA charges £24 or £10 for a code, or nothing in certain cases.

Check the official guidance

This guide is based on these pages. Rules change, so check them for the latest position.

How Tippa helps

Tippa fills in SEPA's own consignment note from your records, and when a site in Scotland books in a hazardous load, Tippa emails SEPA a completed copy of the consignment note as the load is booked in, on SEPA's own Excel note, with any photos you add of the signed paper note. Rejected loads are included. Sites in England and Wales get the same for waste from Scotland, alongside their consignee return.

  • Each collection, load going out and receipt of special waste moved from Scotland gets SEPA's PDF consignment note filled in, to print, download or email: one note, its boxes left fillable for the next person, each party's tick once they've signed, and SEPA's additional sheet when the waste doesn't fit. Free.
  • Every copy sent is kept, so you can see what went to SEPA and when.
  • A code that can't be SEPA's, or a missing detail, is flagged with a way to fix it, and the copy is sent once it's put right.
  • A carrier's round in Scotland can go on one consignment note: the round's SEPA code reaches every hazardous stop and the driver, and Tippa fills in the round's note with the carrier's schedule after it, a sheet per premises with the producer's signature from Collect.
  • Tippa reminds you when to pre-notify SEPA for a round whose waste leaves Scotland, and keeps a record of when you did. It doesn't send the pre-notification itself.
  • At your own site, a carrier's round is one receipt, and its copy to SEPA comes with the schedule.
  • Each load received is reported to Defra's Digital Waste Tracking free, on any plan.

Consignee Returns add-on, £20 + VAT a month Round Planning add-on, £10 + VAT a month

This guide is general information about UK waste rules, not legal or regulatory advice. You remain responsible for meeting the duties that apply to your business; check the official guidance above and take professional advice where you need it.