Who is liable — the carrier or the site?
In this first phase, the receiving site is liable for reporting. From 1 October 2026 the permitted site must report every load it receives; the carrier is named on that receipt but has no reporting duty of its own until October 2027. The carrier's duty of care to describe the waste correctly continues as before.
What the site is responsible for
- Reporting every load received, within two working days, with the details the regulations require.
- Recording the carrier's registration number, or a reason if the carrier has none.
- Reporting hazardous loads with the consignment code, or a reason if there is none.
- Reporting what was actually received — codes, quantity, form — not what the paperwork said if the two differ.
- Keeping the record and correcting it within the window if it was wrong.
What the carrier is responsible for
Everything it was responsible for before: registration as a carrier, the duty of care, describing the waste accurately on the transfer note, hazardous consignment notes where they apply. The carrier does not send anything to Defra in 2026. From October 2027, in the next phase, carriers are expected to report their own movements.
Where the two meet — and where the site is exposed
The site's receipt names the carrier. If the carrier cannot give a registration number, the site can still report the load with a reason — but the site has now recorded, on a Defra system, that it took waste from an unregistered carrier. That is a duty-of-care question for the site as well as the carrier. The practical answer is at the gate: no number, no tip, unless the site has a reason it is prepared to put on the record.
The same logic applies to descriptions. If a load is described as inert and turns out to contain plasterboard, the site reports what it received. Declaring what you found protects the site; the duty to describe the waste correctly sat upstream with the carrier and the producer.
Officers and directors
The regulations allow the Environment Agency to sanction an officer of the business as well as the business where a contravention happened with their consent or connivance, or through their neglect. "The weighbridge operator didn't do it" is not a defence for the operator of the facility.
A site's simplest protection
- Carrier registration number checked before the vehicle goes over the bridge.
- The receipt filed from the ticket, checked before it is sent, with the waste tracking ID stored against the load.
- Undeclared items photographed, attached to the load they came from, and the receipt corrected inside the window with the reason kept.
Questions sites ask
Does the carrier have to report anything in 2026?
No. The reporting duty in the first phase is on the permitted receiving site. Carriers' own reporting is expected from October 2027.
If a carrier gives the site the wrong description, who is liable?
The site must report what it actually received. The carrier's duty of care to describe the waste correctly is unchanged, and a corrected receipt with the reason recorded protects the site.
Can a site refuse a load from a carrier with no registration number?
A site can set its own gate rules. A receipt without a carrier number needs a stated reason, and the site is recording that it took waste from an unregistered carrier.
Can the Environment Agency penalise an individual as well as the company?
Yes, where the contravention occurred with the consent, connivance or neglect of an officer of the business.