8 EWC Code Mistakes Waste Sites Make (and How to Fix Them)
For years the EWC code was a quick scribble on the transfer note. Nobody chased it. From 1 October 2026 that changes: if you receive waste in England or Wales you must file every movement digitally, and the waste classification code is one of the fields you submit (GOV.UK, 2026). Scotland follows in January 2027, and Northern Ireland joins England and Wales from October 2026 (Environment Agency, 2026). The code your weighbridge operator picks in a hurry is about to become a logged record - and the Environment Agency has proposed a £1,000 fixed monetary penalty aimed at "unintended or accidental administrative breaches" of the new regime (letsrecycle, 2026).
Behind all of it sits the duty of care, where getting the code wrong is not a small thing: "Failure to comply with the duty of care is an offence with no upper limit on the courts' power to fine" (GOV.UK, 2018). So it is worth knowing where sites actually trip up. Here are the eight most common EWC code mistakes, and the fix for each.
Key takeaways
- From 1 October 2026 the EWC/List of Waste code is a required field in Digital Waste Tracking for sites receiving waste in England and Wales (GOV.UK, 2026).
- You must classify waste before it moves, and the six-digit code has to go on the paperwork (GOV.UK, 2025).
- A mirror entry cannot be coded until you assess its hazardous properties - "a list of waste code cannot be assigned until steps 4 to 7 have been completed" (Environment Agency, WM3, 2021).
- Upholstered domestic seating must be treated as containing POPs unless proven otherwise, coded 20 03 07, and incinerated (Natural Resources Wales, 2023).
- The duty of care fine has no upper limit, and misdescription is exactly what the EA looks for (GOV.UK, 2018).
The 8 mistakes at a glance
| # | The mistake | The fix |
|---|---|---|
| 1 | "General waste" or a blank box instead of a code | Put the six-digit LoW/EWC code on every description |
| 2 | Guessing a mirror entry | Assess the hazardous properties before you code it |
| 3 | Copying the producer's code blind | Check the load matches the ticket before you sign |
| 4 | Defaulting to a "99" code | Work through the chapters; 99 is a last resort |
| 5 | Treating an asterisk as optional | An asterisk means hazardous - there is no cheaper option |
| 6 | Miscoding upholstered seating | Code sofas 20 03 07 as POPs, and incinerate |
| 7 | Paper note and digital record disagree | Agree the code once, at the weighbridge |
| 8 | No evidence behind the code | Record and keep your classification reasoning |
Mistake 1: Writing "general waste" instead of a six-digit code
The fix: put the actual List of Waste code on every description - never a vague word. GOV.UK is direct about it: when you describe your waste in the paperwork, this "must include: the waste classification code, also referred to as LoW (List of Waste) code or EWC (European Waste Catalogue) code" (GOV.UK, 2025). "General waste", "mixed", or a blank box is not a classification. It also fails the incoming test - you must classify waste "before it is collected, disposed of or recovered" (GOV.UK, 2025), so the code belongs on the ticket at the gate, not tidied up at month end.
The code itself is not complicated once you can read it. If you want the full walk-through, our guide to what an EWC code is breaks down the six digits and the asterisk. In short:
Mistake 2: Guessing a mirror entry instead of assessing it
The fix: assess the hazardous properties before you commit to a code - never eyeball it. Some wastes are listed as a pair: one code with an asterisk (hazardous), one without. WM3 is blunt about the duty this creates: "If the waste is classified under 'mirror hazardous' or 'mirror non-hazardous' entries you will need to continue with the assessment of hazardous properties in steps 4 to 7", and "a list of waste code cannot be assigned until steps 4 to 7 have been completed" (Environment Agency, WM3, 2021).
That means the "is this hazardous or not?" call at the gate is not a judgement your operator makes by looking. It needs a documented assessment. Where the composition genuinely cannot be worked out, the safe default is the hazardous entry, not the cheaper one. Guessing the non-hazardous side to save a gate fee is the classic mirror-entry error - and the one most likely to unravel at an inspection.
Mistake 3: Copying the producer's code without checking the load
The fix: check that what arrived matches the code on the paperwork - you are the holder now. A code that was right for the producer's process is not automatically right for the load on your weighbridge. Contamination, mixing in the skip, or a description that never matched the contents all break the chain. Once you accept the load, duty of care makes the description your responsibility: "A written description of the waste is agreed and signed by you and the next holder", and it must classify the waste "by using the appropriate codes" (GOV.UK, 2018). If the grab tells a different story from the ticket, the ticket is wrong - fix it before you sign, not after.
Mistake 4: Reaching for a "99" code when a specific one exists
The fix: work through the chapters first; a 99 code is a last resort, not a shortcut. Codes ending in 99 mean "wastes not otherwise specified", and WM3 tells you not to jump to them: "You must not use any six digit entry ending in '99' from the chapters considered at step 1 because more appropriate entries might be found in other chapters" (Environment Agency, WM3, 2021). Start from the process that produced the waste, narrow to the sub-chapter, match the printed description, and only fall back on a 99 code when nothing specific fits anywhere. A yard that codes everything awkward as 99 is a yard that will get questions on its next visit.
Mistake 5: Treating an asterisk entry as optional
The fix: if the code carries an asterisk, the waste is hazardous - there is no cheaper option. WM3 states it plainly: "The six-digit codes in the LoW that are hazardous wastes have an asterisk () next to them" (Environment Agency, WM3, 2021). An absolute-hazardous entry is hazardous whatever the chemistry - you do not get to drop the asterisk to duck the paperwork or the disposal cost. The money makes the temptation obvious and the risk worse: from 1 April 2026 the standard rate of Landfill Tax is *£130.75 a tonne** against £8.65 at the lower rate (GOV.UK, 2026). Misdescribing a load to sit on the wrong side of that gap is exactly the misdescription the EA treats as an enforcement trigger.
Mistake 6: Not coding upholstered seating as POPs
The fix: treat sofas and soft chairs as POPs waste unless proven otherwise - code 20 03 07, and incinerate. Upholstered domestic seating (sofas, armchairs, dining chairs, futons, bean bags) commonly contains persistent organic pollutants in the foam and covers. The guidance is specific: "describe the waste as 'domestic seating waste containing POPs'" and "classify it with the list of waste code 20 03 07" (Natural Resources Wales, 2023). You must "incinerate waste domestic seating containing POPs or mixed waste containing it" and "must not use any other waste treatment, recycling or disposal methods". Mix it into a general load and the whole load becomes POPs waste until you separate it out. Miscode a sofa as bulky general waste and you have both the wrong code and the wrong disposal route.
Mistake 7: Letting the transfer note and the digital record disagree
The fix: agree the code once, at the weighbridge, so the paper and the digital record match. Under Digital Waste Tracking the submission requires "waste classification codes ... also known as list of waste (LoW) codes and European Waste Catalogue (EWC) codes" (GOV.UK, 2026). That turns the code into a logged, validated field: a mismatch between the paper transfer note and the digital record is now visible in a way it never was. With a £1,000 penalty proposed for accidental administrative breaches (letsrecycle, 2026), the fix is to capture the agreed code once and carry it straight onto the receipt. Software built for the weighbridge can record the code as the load is weighed and file it under DWTS, so the same code flows through without being re-keyed - and our DWTS readiness checklist covers the wider workflow.
Mistake 8: Keeping no evidence to defend the code
The fix: record how you reached the code, and keep it - your reasoning is what defends the classification. A code with no assessment behind it is a code you cannot stand up. For mirror entries in particular, "waste holders have a duty to determine if a 'mirror entry' waste is hazardous or non-hazardous" (Environment Agency, WM3, 2021) - and a duty you cannot evidence is a duty you may as well not have discharged. Classification is one of the things checked when the EA visits, so keep the assessment, the supplier's description, and any test results with the record. Our guide on how to prepare for an EA inspection covers what else the officer asks to see.
Frequently asked questions
What is the most common EWC code mistake?
Writing a vague description instead of a six-digit code. The paperwork "must include: the waste classification code" (GOV.UK, 2025), so "general waste" or a blank box is not a valid classification.
Do I have to classify waste before I accept it?
Yes. You must classify waste "before it is collected, disposed of or recovered" (GOV.UK, 2025), which means the code needs to be right at the gate, not corrected later.
How do I know if a waste is a mirror entry?
It is listed as a pair of codes - one with an asterisk, one without. You cannot assign a code until you assess the hazardous properties: "a list of waste code cannot be assigned until steps 4 to 7 have been completed" (Environment Agency, WM3, 2021).
When can I use a code ending in 99?
Only as a last resort. You must not use a 99 code from the first chapters considered "because more appropriate entries might be found in other chapters" (Environment Agency, WM3, 2021).
What does the asterisk on an EWC code mean?
It marks the waste as hazardous. "The six-digit codes in the LoW that are hazardous wastes have an asterisk (*) next to them" (Environment Agency, WM3, 2021).
What code do sofas and upholstered chairs need?
Code 20 03 07, described as "domestic seating waste containing POPs", and they must be incinerated (Natural Resources Wales, 2023).
Does the EWC code have to match on the transfer note and the digital record?
Yes. Digital Waste Tracking requires the waste classification code on each movement (GOV.UK, 2026), so the paper and digital records should carry the same code.
When does Digital Waste Tracking start?
Sites receiving waste in England or Wales must use the service from 1 October 2026; Northern Ireland from October 2026 and Scotland from January 2027 (Environment Agency, 2026).
What is the fine for getting a code wrong?
There is no fixed figure. Breaching the duty of care "is an offence with no upper limit on the courts' power to fine" (GOV.UK, 2018). A £1,000 fixed monetary penalty has been proposed for accidental administrative DWT breaches (letsrecycle, 2026).
Who is responsible for getting the code right?
The waste holder. Once you accept a load and sign the description, the classification is yours to stand behind (GOV.UK, 2018).