Every tonne tracked. Every movement documented. By default.
RAW TG operates on our digital platform, so traceability isn't an add-on — it's how every trade runs. Digital duty of care capability, chain-of-custody and an auditable trail per consignment, built into the movement rather than bolted on after.
The record is built as the movement happens.
The animation shows each event being captured against the same consignment: source, movement, custody, inspection and settlement. That is the difference between a live audit trail and paperwork reconstructed after the fact.
What you get on every trade.
Traceability is the same on every movement — not a premium tier. Each of these is produced as part of running the trade, not assembled afterwards from scattered paperwork.
Digital duty of care
Duty-of-care capability captured digitally as material changes hands, rather than on loose paper.
Waste transfer documentation
Transfer documentation generated and held against each movement as part of the workflow.
Chain-of-custody
An unbroken record of custody from source to processor — who held the material, and when.
Timestamped movement records
Each step in a movement is timestamped, so the sequence of events is recorded as it happens.
Auditable trail per consignment
A single, retrievable record for each consignment — the answer to a provenance question in one place.
Cross-border documentation
Documentation to support UK, EU and international movements, held alongside the rest of the trail.
None of this is paperwork for its own sake. Battery materials are waste until a processor turns them back into product, and waste carries legal duties from the moment it changes hands. Capturing those duties digitally, as the trade runs, is what turns a movement into something a counterparty, a refiner's own customers, or a reviewer can actually rely on. See the platform underneath it.
The same record, read three ways.
A single system of record serves a different need for each party to a trade — without anyone reassembling paperwork after the fact.
For suppliers
Clean evidence of where your material went and who handled it — proof you can stand behind, not a paper trail you have to chase.
For refiners
Provenance and chain-of-custody for your own reporting and customers — feedstock you can account for, end to end.
For diligence & reviewers
An auditable system of record rather than scattered paperwork — answers that can be retrieved and interrogated, not reconstructed.
The framework every UK waste movement sits inside.
Documenting a trade well means understanding the duties that attach to waste — not improvising paperwork after the fact. RAW TG references this framework as context for how it works; it does not claim to hold any particular registration or approval on a counterparty's behalf.
In the UK, the duty of care broadly derives from section 34 of the Environmental Protection Act 1990 and the Waste (England and Wales) Regulations. In practice that means a movement is evidenced by a waste transfer note and — where the material is hazardous — a hazardous waste consignment note. Carriers, brokers and dealers are expected to be registered to handle waste, and the waste itself is described using EWC (List of Waste) codes; chapter 16 06 broadly covers batteries and accumulators.
Capturing these instruments digitally, against each consignment, is what makes a provenance question answerable later. Each party to a trade nevertheless remains responsible for its own classifications and legal obligations.
| Instrument | What it evidences |
|---|---|
| Waste transfer note | A non-hazardous waste handover between parties |
| Hazardous waste consignment note | Movement of hazardous waste, in fuller detail |
| EWC 16 06 | List of Waste classification for batteries and accumulators |
| Carrier / broker registration | Authorisation to transport or arrange waste movements |
Moving waste across a border is a regime of its own.
Transfrontier shipment (TFS) is governed broadly by the Basel Convention, the OECD Decision and, in the EU, the Waste Shipment Regulation. In Great Britain the regime is administered by the competent authority — broadly the Environment Agency. The level of control depends on what the material is.
| Route | Broad documentation | Consent |
|---|---|---|
| Green-listed waste | Moves with Annex VII information accompanying the load | No prior consent required |
| Notifiable ("amber") waste | Prior written notification, plus financial guarantees | Prior informed consent of dispatch, transit & destination authorities |
Notifiable movements require prior informed consent from the competent authorities of the countries of dispatch, transit and destination, and financial guarantees must usually be in place before material moves. Controls specific to battery materials and black mass have been tightening internationally, so the classification of a given load — and the route it can lawfully take — is confirmed case by case. RAW TG prepares and holds the documentation these movements require; it does not issue consents or guarantee an outcome. See how movements are routed and handled.
The same records discharge Extended Producer Responsibility.
Battery EPR — in the UK today and under the EU Battery Regulation since August 2025 — runs on evidence of collection, treatment and recovery. That evidence is generated exactly where RAW TG operates: at the material level, movement by movement.
- Treatment and export routes documented per consignment.
- Recovery data captured where it is created — at the processor.
- Evidence retrievable for producers, schemes and auditors.
Documentation is going digital, and traceability is going further.
Two shifts are reshaping what good provenance looks like — and the way RAW TG documents trades is built with both in view.
Digital waste tracking
The UK is moving from paper waste documentation toward mandatory digital waste tracking, phased in over the coming years. Our platform is designed around digital waste tracking workflows and helps prepare the records that direction implies. It is not the government system, and it does not guarantee a compliance outcome.
EU Battery Regulation & the Battery Passport
Regulation (EU) 2023/1542 introduces due-diligence and carbon-footprint rules, recycled-content and recovery targets for materials such as lithium, cobalt, nickel and copper, and a digital Battery Passport — broadly from 2027 for EV and industrial batteries. Lifecycle traceability is a clear direction of travel, and unbroken chain-of-custody is the foundation it rests on.
Built on our platform — and clear about it.
RAW TG didn't build a trading business and then look for a compliance tool. It operates on an established platform built for exactly this.
Our digital platform is built, owned and operated within the RAW TG group. Every trade is run and documented on it, so the trading engine and the system of record come from the same place — traceability is structural, not bought in.
What this is — and isn't.
- Digital duty of care capability, by default on every trade.
- Designed around digital waste tracking workflows.
- An auditable record that helps prepare for diligence and reporting.
Capability, never approval. We describe what the platform does, not a regulatory endorsement of it.
Accuracy & scope of these statements.
RAW TG describes its traceability and digital duty of care capability. It does not claim regulatory approval, certification, or guaranteed compliance outcomes. Counterparties remain responsible for their own classifications and legal obligations.
Compliance & traceability — answered.
What is the "duty of care"?
It is the legal responsibility that attaches to waste as it changes hands. In the UK it broadly derives from section 34 of the Environmental Protection Act 1990 and the Waste (England and Wales) Regulations, and in practice it is evidenced by waste transfer notes — or, for hazardous waste, hazardous waste consignment notes. RAW TG captures this evidence digitally as part of running the trade. We describe a capability; counterparties remain responsible for their own obligations.
Does this mean RAW TG guarantees regulatory compliance?
No. RAW TG describes a traceability and digital duty of care capability. It does not claim regulatory approval, certification or guaranteed compliance outcomes, and counterparties remain responsible for their own classifications and legal obligations.
What are EWC codes, and which apply to batteries?
EWC (European Waste Catalogue) or List of Waste codes are how a waste stream is classified and described on its documentation. Chapter 16 06 broadly covers batteries and accumulators. The correct code for a specific consignment depends on its composition and is confirmed case by case rather than assumed.
What is transfrontier shipment (TFS), and what is Annex VII?
TFS is the regime for moving waste across borders, governed broadly by the Basel Convention, the OECD Decision and, in the EU, the Waste Shipment Regulation. Green-listed wastes broadly move with Annex VII information accompanying the load. Notifiable ("amber") wastes require prior written notification and the prior informed consent of the competent authorities of dispatch, transit and destination, plus financial guarantees. Controls on battery materials and black mass have been tightening internationally.
Is your platform the government's digital waste tracking system?
No. The UK is moving toward mandatory digital waste tracking, phased in over the coming years. Our platform is a commercial system designed around those workflows that helps prepare the records that direction implies — it is not the government system, and using it does not guarantee a compliance outcome.
What is the Battery Passport, and does it affect me yet?
The Battery Passport is a digital lifecycle record introduced by the EU Battery Regulation (Regulation (EU) 2023/1542), broadly from 2027 for EV and industrial batteries, alongside due-diligence, carbon-footprint, recycled-content and recovery requirements. It signals where lifecycle traceability is heading. Unbroken, timestamped chain-of-custody — exactly what is captured on every trade today — is the foundation that kind of reporting rests on.
See how traceability works on a trade.
Tell us what you're moving, and we'll walk through the documentation you'd hold at each step.
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