If you hire out skips, run a man-and-van clearance service or do any kind of domestic rubbish removal, you have probably had this call: "Before I book you, can I have your waste carrier number?" A few years ago that was rare. Now it is a routine question, and a good sign. It means the customer has heard that they can be held responsible for where their rubbish ends up.
This article explains the householder's own duty of care, why it is changing how customers behave, and how a small waste business can turn a carrier-number question into a reason to be chosen. It is written for England and Wales in particular; the other UK nations have similar rules, but check your own regulator's guidance.
The householder's duty of care
The duty of care in section 34 of the Environmental Protection Act 1990 is best known as a duty on businesses. It is less widely known that it also applies, in a more limited form, to householders. A householder who hands waste produced at their home to someone else must take reasonable steps to make sure it is passed to an authorised person, such as a registered waste carrier or the local council. They do not have to complete a waste transfer note, and they are not expected to inspect the destination site. But they cannot hand it to anyone who turns up with a van and says they will "sort it".
In practice, taking reasonable steps means checking that the person collecting the waste is a registered waste carrier before the waste leaves the property, and keeping some record of who took it. If the waste then turns up dumped on a lay-by or a farm track and is traced back to the householder, "I didn't know" is not much of a defence if they never asked.
Why customers now ask for your carrier number
Several things have pushed householders to ask:
- Council and regulator campaigns. Local authorities, the Environment Agency, Natural Resources Wales and national anti-fly-tipping groups have run public campaigns telling people to check the carrier before handing waste over, and many council websites now carry a short checklist.
- Stories of householders being traced. Fly-tipped waste often contains letters, packaging and delivery labels. When a council investigates, a householder can be contacted even if they have no idea who took their waste.
- Online booking and price comparison. A customer who finds a skip or clearance firm through a website or a social media post cannot easily tell a registered business from a one-person operation with no registration. They have been told to ask, so they ask.
- Landlords, letting agents and trades. Anyone who arranges a clearance on someone else's behalf is likely to have a duty of care of their own. They will want the number for their records.
What it means for a waste business
For a registered carrier, the question is easy to answer and worth answering well. Unregistered operators cannot give a number that checks out, so a quick response from you is a competitive advantage.
If you carry waste in the course of your business, you need to be registered with the relevant regulator. In England that is the Environment Agency, in Wales Natural Resources Wales, in Scotland SEPA and in Northern Ireland the NIEA (and the councils for some categories). Whether you hold an upper tier or lower tier registration in England depends on what you carry and whether you carry other people's waste or your own; our guide to upper tier and lower tier registrations covers the difference. The government has also consulted on and announced reforms to the carrier regime, so it is worth checking gov.uk for how registration is changing.
Being registered is the start. The customer also needs to be able to verify it. Put your registration number and the regulator on your quotes, your website, your vehicle and your invoices, and tell customers how to check it themselves on the public register.
How a customer can check you
Customers do not need technical knowledge. A simple checklist works:
- Ask for the registration number. A registered carrier will have one and will give it without fuss.
- Search the public register. In England the Environment Agency's online public register shows whether a business or individual is registered and what tier they hold. Wales, Scotland and Northern Ireland have their own systems. See our walkthrough of the EA waste carrier register search.
- Check the details match. The name on the register should be the name on the quote and the van. If someone gives the number of a different business, walk away.
- Ask where the waste is going. A legitimate carrier can name the transfer station, recycling site or landfill. Vague answers should worry you.
- Get a receipt. It should show the carrier's name and registration number, and a description of the waste.
- Be wary of very low prices and cash-only offers, particularly through online adverts.
You can send this list to customers with the booking confirmation. It shows you take duty of care seriously, and it reduces the chance of them using the checklist to rule you out because you did not offer the number first.
What you should give the customer
The householder does not need to complete a transfer note, but you do have your own duty of care and your own record-keeping obligations. For a domestic job, that means you should be able to show, from your own records:
- a description of the waste and how it was collected (loose, in a skip, in bags)
- the quantity and the date and time of collection
- the customer's name and the collection address
- your registration details
- where the waste went and who accepted it
A short receipt or confirmation sent to the customer that includes your registration number and a plain description of the waste closes the loop for them. It is not a legal substitute for your own records, but it is a useful proof of the steps they took. If you are not sure what a good description looks like, our piece on writing a good waste description has examples. For the transfer from you to a transfer station or recycling site, you still need a proper waste transfer note covering your own transfer, and you can create one for free at qwtn.co.uk/notes/new.
Mixed loads and hazardous items from homes
Domestic jobs bring their own classification issues. House clearances and garage clear-outs produce a mix of furniture, electrical items, paint, gas bottles, batteries and sometimes asbestos from old outbuildings. If your customer hands you something that is hazardous, you cannot put it with the rest as if nothing had happened. We cover the classification problem in more detail in mixed construction waste in skips, and the same thinking applies to domestic clearance. Ask what is in the property before you quote, give a clear list of what you will and will not take, and agree in advance what happens if something unexpected appears.
What fly-tipping means for everyone in the chain
Fly-tipping is an offence under section 33 of the Environmental Protection Act 1990. Penalties include an unlimited fine on conviction and, for serious cases, imprisonment. Vehicles used for fly-tipping can be seized, and the Environment Agency and councils can also recover clean-up costs. Landowners often end up paying to remove waste dumped on their land.
If you are a registered carrier and your waste ends up where it should not, you are not protected by your registration. You are expected to have a record of where the waste went, to a site that was permitted or exempt to receive it. That is why the waste transfer note matters at the other end of the journey. If a transfer station or recycling site later says it never received your load, the note, signed by the receiving party, is your evidence.
If a customer has been caught out by an unregistered operator, you may be the first person they ring. Advise them to report the fly-tipping to their local council, to keep any messages, receipts or photographs of the vehicle and number plate, and to avoid confronting the person. Councils and, in serious cases, the regulator will take it from there.
Turning the question into trust
A customer asking for your carrier number is, in effect, asking if they can trust you. You can answer more than the question:
- give the number straight away and show how to check it
- say where the waste will go, naming the site
- send a clear receipt that includes your registration and a description of the waste
- keep a photo of the load at collection, which proves what was taken and when
- keep your own records for the required period, so you can answer a council query months later
None of it is complicated. It is a short routine that you can repeat for every domestic job, and it makes you easier to hire than the van that has no number.
Try it yourself
Create a one-off transfer note without an account.