A festival, a food market, a village show or a county fair produces a surprising amount of waste in a short time, much of it from people who are not employees: traders, caterers, contractors, volunteers and thousands of visitors. The waste law still applies, and it still needs someone to take responsibility for it. For event organisers and the waste firms who serve them, the practical question is usually the same: when a skip full of mixed event waste leaves the field, who is the producer, and who signs the transfer note?
The duty of care applies to events
Section 34 of the Environmental Protection Act 1990 places the duty of care on anyone who imports, produces, carries, keeps, treats or disposes of controlled waste. There is no exemption for temporary sites. An event on a farmer's field is subject to the same duty as a permanent factory. That includes keeping waste secure so it cannot escape, passing it only to an authorised person such as a registered waste carrier, and completing a written description of it at each transfer.
Our guide to the UK duty of care for waste covers the duty in general. This article looks at how it plays out when a crowd, a landowner, a promoter, dozens of traders and a waste contractor are all on the same site for a few days.
Who is the producer?
This is where events differ from a normal business. In a standard commercial set-up, the business that creates the waste is the producer and it deals with its own contractor. At an event, several parties create waste on the same ground.
- The organiser or promoter controls the site, the event layout and, usually, the shared bins and skips. Even where visitors and traders physically generate the waste, the organiser is typically the party that holds it on site and arranges for it to be removed.
- Traders and caterers produce their own waste: food packaging, cooking oil, trade packaging and, in some cases, food waste. Each trader is, in law, the producer of what their stall generates.
- Contractors such as staging, security, power and toilet suppliers produce their own wastes: pallets, cable offcuts, packaging.
- The landowner is not normally the producer, but the land is theirs and they will care what is left on it. Contracts should say who clears the site.
In practice, organisers handle this in one of two ways. Some require each trader to arrange their own collection, with proof of registration and notes. Others provide a managed waste service for the whole site, and the trading terms say traders must use it. The second route is simpler to administer, but it means the organiser takes on more responsibility for what goes into the shared skips. If you are not sure how to structure it, a short written arrangement that names who is responsible for which waste is far better than leaving it to assumption.
Who signs the transfer note?
A transfer note is signed by the person handing over the waste (the transferor) and the person receiving it (the transferee). At an event with a managed waste contractor, the usual picture is this:
- Organiser to waste contractor. The organiser, as holder of the event waste, signs as transferor and the contractor's representative signs as transferee. This covers the skips and bins collected from the event site.
- Waste contractor to treatment or disposal site. The contractor then becomes the transferor, and the receiving site is the transferee. This is separate paperwork and is the contractor's job.
- Traders to organiser or contractor, if they use shared bins. Where traders put waste in organiser-provided containers, a transfer has technically taken place. Many organisers cover this through the trading terms and one set of notes describing the waste as event waste including trader waste, but the safest approach is to make the arrangement explicit in writing.
- Traders with their own collections. A trader who arranges their own cooking oil collection or food waste pick-up is the transferor on those notes.
If waste is hazardous, consignment notes replace transfer notes for that waste. Examples that can turn up at events include waste oil, solvents from site vehicles and generators, certain batteries and fluorescent lamps. See our guide to the hazardous waste regulations if any of these will be on site.
Writing the arrangement down before the event
Waste problems at events usually start in the contract stage, not on the day. A good pre-event agreement covers:
- who provides bins and skips, how many, and where they are sited
- which waste streams are collected separately (general, dry recycling, glass, food, cooking oil, cardboard)
- how often collections happen during the event and at the end
- who arranges and pays for site clearance and litter picking afterwards
- what each trader must do about their own waste, including cooking oil
- who keeps the notes, and how they are shared with the organiser
Many local authorities require a waste plan as part of the event management plan for licensed events, and the local Safety Advisory Group may ask for it. The Purple Guide, the industry guidance on health, safety and welfare at music and similar events, also covers waste. Check what your own local authority expects before you plan.
Choosing and checking the waste contractor
An event is a bad time to discover your contractor is not registered. Before you sign:
- check their carrier registration on the public register and record it
- ask which sites will receive each waste stream and whether those sites hold environmental permits
- ask for evidence of experience with events, particularly at your scale
- agree reporting: tonnages, recycling rates if you need them, and copies of notes after the event
Our guide to checking a waste carrier before you hand over waste sets out the checks in full. Specialist suppliers such as portable toilet firms or cooking oil collectors should be asked the same questions, including where their waste ends up.
Typical waste streams at an event
General and mixed waste
Mixed bins from visitors are the bulk of it. A transfer note should describe what the collection is, for example mixed event waste, rather than just "rubbish". See our guide on writing a good waste description.
Dry recycling
Cardboard, plastic bottles, cans and paper. Contamination is the usual problem at events: if bins are overfilled with food and drink, recycling loads may be downgraded or rejected. Clear signage, staffed waste stations and bin positioning help.
Glass
Often kept separate for safety and quality. Many events restrict glass in public areas altogether, and have it collected behind bars and catering areas only.
Food waste
Food waste from caterers has to be kept secure and collected by an appropriate carrier. Rules on animal by-products affect what can be done with catering waste that contains meat or dairy. If you are unsure, ask your contractor how it is handled.
Cooking oil
Used cooking oil should never go down a drain. Traders should store it in sealed containers and arrange collection by a registered carrier, with a transfer note.
Camping waste
At camping festivals, abandoned tents, chairs and sleeping bags can become a large waste stream. Some events charge a deposit, run a take-it-home scheme or arrange donation of usable items. What cannot be reused is controlled waste and needs proper disposal.
Toilets and welfare
Portable toilet waste is handled by specialist suppliers. Ask for the supplier's registration where it applies and confirm where the waste goes.
Single-use plastics
In England, rules restrict the supply of certain single-use plastic items, such as plates, trays, bowls, cutlery and polystyrene food and drink containers. Wales and Scotland have their own restrictions. Check the current rules for your nation when setting your trader terms.
Using a season ticket for multi-day events
An event that runs for several days with several collections of the same waste, by the same carrier, going to the same destination can be a good fit for a season ticket, a single note covering a series of transfers. Recurring events such as weekly markets or monthly fairs can use one for the whole season. The conditions are the same as elsewhere: the waste must be the same, the parties must be the same, and the note must record each collection or be accompanied by a log of them. Our guide to season tickets for waste transfers explains the details.
After the event
Waste responsibility does not end when the gates close. Site clearance, litter picking and any final skip collections need to be on the schedule, and the contractor should provide final notes and tonnage data. Keep transfer notes for at least two years and consignment notes for at least three. If a local authority or the Environment Agency asks about waste at the event later, the notes are your evidence. Our guide to how long to keep waste transfer records covers retention.
If you need to create notes quickly on site, QWTN's free note creator runs in a web browser, so a note can be started wherever you have a signal. Whichever way you do it, the principle is the same: know who holds the waste, put the arrangement in writing, and keep the notes.
Rules and local authority requirements vary, so check current gov.uk guidance and your own licensing authority before the event.
Try it yourself
Create a one-off transfer note without an account.