What Digital Waste Tracking Actually Requires

DEFRA’s Digital Waste Tracking (DWT) is a structural shift in how the UK records and regulates waste movements. It becomes mandatory (for some) in October 2026. This article explains the core requirements for operators obligated at that point. In it we draw on Defra’s technical documents and on our own knowledge through years of industry engagement as well as the practical experience gained through integrating our software with the DWT service.

This is part of a series, so if you’re not sure what DWT is then start with the overview in Digital Waste Tracking: the What, Why, When and Who.

The fundamental requirement for DWT

Within DWT Phase 1 every movement of waste arriving at a receiving site must have a digital record in the Digital Waste Tracking service. In Phase 1 the responsibility to create the record sits with the permitted or licenced receiving site. This starts for sites in England, Wales and Northern Ireland from October 2026 and Scotland from January 2027. Sites operating under an exemption are not covered during this phase. Phase 2 extends responsibility to carriers, brokers and dealers to record waste movements in the DWT system.

What operators must record for each waste movement

Defra has laid out the data fields required to create a harmonised approached to waste data. These fields are broadly similar to a full hazardous waste consignment note. The main difference between the hazardous waste consignment note and the more widely used waste transfer note (sometimes called a duty of care note) is the addition of information on the receiving site.

When creating a record for the DWT system, receiving sites must provide data across three core areas:

What the waste is - This is general information about the waste:

• the correct EWC code
• a plain language description of the waste
• the physical form
• the container type
• the weight and unit of measure
• if it is hazardous
• if it contains POPs

What happened before this point - A record of who created the waste and who transported it to the receiving site:

• the activity that generated the waste
• the origin of the waste
• the carriers involved in the movement
• the dealers or brokers involved in the movement

Where is it now and what might happen next - Details about the receiving site and what happens next to the waste:

• the receiving site
• when the waste arrived here
• the intended treatment
• any changes when they occur

By standardising the required data the DWT system removes local variation and the ambiguity that can lead to inconsistent reporting. Much of this is already standard in hazardous waste consignment notes so if your waste management software can handle those compliantly, then it should be straightforward for your current system to handle the data requirements of the DWT system.

There are a few additional data requirements though. New fields include:

• the unique Digital Waste Tracking ID
• the API Code that identifies the receiving organisation.

Both of these fields connect the record directly to the central service and are mandatory for every submission.

• Whether the waste contains POPs and if so which one(s) and their concentration levels

We know that this one is a real headache from an operational point of view, but from a data perspective it’s straightforward.

Which waste streams must be recorded?

Digital waste tracking is intended to cover the movement of all ‘controlled waste’. This includes hazardous and non-hazardous wastes, commercial and industrial wastes, construction and demolition wastes and municipal wastes. The exceptions, at time of writing, are extractive wastes (e.g. from quarries or mines) which are not removed from site, animal by-products (because they are not covered by the definition of ‘controlled waste’ and under the Environment Act 2021 the regulators do not have the powers to mandate these movements for DWT) and radioactive materials (as they are covered under other regulations and are highly tracked already).

The intention is that the vast majority of waste movements become visible and traceable; with the intended aim to reduce waste crime.

Who is responsible for creating and updating a record?

In Phase 1 the receiving site is responsible for creating the waste tracking record and generating the code by logging the movement with the DWT system. Starting at the end of the chain may seem a little strange but Defra’s logic is that there are a known number of permitted and licenced sites (around 12,000) and it is possible to confirm which of these are actually operational and receiving waste because of quarterly returns. With these sites then reporting each movement of waste received on site, including information on the carriers, brokers and dealers involved, will then provide the regulators with a much better idea of the parties actively involved in waste movements around the UK.

The receiving site is also the first point where the waste is weighed and accepted so arguably the point where the most reliable data is available.

The receiving site must complete and update the record within two working days of receiving the waste, starting with the day after the waste arrived on site. For example, a waste movement arrives onsite at 1pm on a Tuesday, the movement must be recorded on the DWT system by 11:59pm on the Thursday. This is not real time reporting. The two-day window allows checks and corrections on misdescriptions, POPs classification issues and rejected loads to be dealt with.

Can records be updated and when can this happen?

Submitted records can be amended on the DWT system, and in fact records must be updated whenever information changes. This includes:

• corrections to waste description or weight
• changes in treatment route
• confirmation of acceptance
• recording of rejections

The service is designed for near real time accuracy rather than instant updates. This removes the lag of paper processes while still allowing operational checks and corrections.

How does digital waste tracking works in practice?

Defra plan to provide two submission methods (at the time of writing).

The Receipt of Waste API is the primary method.

It is a REST API with seven endpoints and uses JSON. It requires OAuth authentication and an API Code for each receiving organisation. It is designed for software-to-software workflows. And because of that, the last couple of sentences are not really aimed at you, assuming you’re a waste operator. If you’re a software developer, then we’re sure you followed us!

A manual option

There is very limited information available about this route at present. It is likely to be a spreadsheet upload to the DWT system. Defra have said this route will remain available until at least October 2027. It exists for operators without integrated software. Operators should treat this as a temporary measure. And while many of us might be familiar and comfortable with spreadsheets, we think that the nested structure of the required data is likely to make a traditional spreadsheet difficult to manage at scale.

As of the time of writing, there have not been any details released about the ‘manual’ method. So we’re not going to cover that here. If you don’t have software to integrate with the DWT system, either because you don’t have software and you’re not planning on implementing any, or because the software you use is not going to integrate with the DWT system, then you might still find useful information in the next sections about how you can prepare, because you’ll still need to gather the data required and get it together for your manual submissions.

What does not change

Digital waste tracking will not replace any of the existing reporting systems immediately after roll out. Requirements in terms of Waste Data Flow, hazardous waste consignee returns and duty of care documentation all remain in place.

Defra has been explicit that alignment with Waste Data Flow is not within the current business case of the DWT team and is being handled by another team focussed on WDF.

It is unclear how long the dual reporting will run for, Defra are aware of the additional burden this places on operators but during the transition to the full implementation of DWT it is seen as a necessary requirement. This creates a strong case for automation via integrated software which can fulfil both requirements simultaneously.

The practical challenges operators will face

Depending on the approach taken operators face a different range of challenges.

For operators looking to stick with their paper system or spreadsheets the biggest challenge will be around embedding processes across their business to deliver consistent, quality, timely data capture without large staffing costs through rekeying or duplication of effort. Businesses with chaotic processes or relying on last-minute admin are more likely to draw attention to themselves as their manual submissions to the DWT system risk quality issues, missing the deadlines and inconsistencies which may warrant a closer look by the regulators.

Operators who are implementing a new software system will likely face a much easier time once their software solution is implemented as it should integrate with the DWT system meaning streamlined processes and more efficient workflows. For those with no software in place or a legacy provider who isn’t integrating with the DWT system then they will need to identify the right platform for their needs and give themselves time to implement the software and train up their staff ahead of the October roll out.

Operators whose software is already integrated with the DWT system should see little requirements to change their processes or retrain staff. All that is required from these operators is to ensure they have received their API key from Defra (a unique code to identify their organisation and software connection in the DWT system) and shared it with their software providers.

There are also a few challenges that will affect a range of operators, regardless of their software situation:

POPs classification is currently inconsistent across industry. Operators will need clear processes for identifying and recording details of POPs and their concentrations. No mean feat.

Local authority data sharing remains uneven. Collection authorities do not always receive weighbridge data from disposal authorities and the digital service does not resolve this so processes will need to be agreed to ensure reporting between authorities can happen within the time constraints.

No lookup for tracking codes exists yet. Operators cannot retrieve any information against existing codes from the DWT service which makes some workflows harder. Whilst this issue mostly requires changes from Defra, operators would do well to think about how to ensure confirmation of reporting and handover of responsibility – or to ensure their software provider is abreast of this.

What happens if rules are not followed?

Regulators will have direct access to the data. They will see missing records, mismatched weights and repeated misdescriptions. Enforcement will vary across devolved nations because waste regulation remains devolved. However DWT removes ambiguity and will increase scrutiny where patterns suggest non-compliance.

Receiving sites may refuse loads if records are incomplete. Customers will expect consistent data for their own assurance. Operators with repeated gaps will face more questions and more checks.

The intent is to create a level playing field for those meeting their Duty of Care and disadvantage those trying to benefit from waste crime. Operators with reliable data should face fewer interventions over time with regulators able to focus their investigations and enforcement action where the data shows anomalies and inconsistencies.

How operators can prepare

Preparation falls into three areas:

• Review existing duty of care processes and identify where data is missing, inconsistent or challenging to get and implement procedures to fill these gaps
• Assess if your software meets the DWT requirements and if your software provider is integrating with the DWT system – if it doesn’t or they’re not consider finding a more suitable solution now
• Train internal teams so that all required fields are understood and collected at the right points to streamline workflows and reduce rekeying by aligning systems and processes

Digital waste tracking highlights the gaps that already exist in many operations’ workflows. The challenge is consistency across teams and sites and the right software can help overcome these challenges.

How Dsposal’s Paperwork helps operators meet these requirements

Dsposal's Paperwork is designed for SME waste operators and builds compliance into your daily workflows. It aligns weighbridge operations, site acceptance processes, carrier interactions and back-office work with the requirements of digital waste tracking while delivering a slick operating system for your waste management business. It has been built with waste companies like yours, so it works for waste companies like yours.

Paperwork helps operators:

• capture required data fields through guided inputs
• keep data consistent across drivers, yards, accounts teams and compliance roles
• reduce corrections which reduces regulatory attention
• maintain clear evidence of Duty of Care

Operators tell us the main value is the removal of gaps that arise on busy days. Paperwork gives teams a single source of truth and creates a smoother path into the national digital service.

It also saves your staff time, improves profitability and delights your customers.

A straightforward next step

If you want to see how other SME waste companies have prepared for digital waste tracking, we can show you how Paperwork fits into real operations, book a demo today.