Three checks before entering Switzerland

Before accepting an order, check these three points in sequence:

1. Start with the route: import, export or transit?

Regulation (EU) 2024/1157 applies on the EU side but does not apply directly in Switzerland. Switzerland primarily applies its Ordinance on Movements of Waste (VeVA/OMW), the Basel Convention and the OECD Decision. The new EU rules nevertheless affect shipments between the EU and Switzerland. Notifications acknowledged by the competent authority of destination before 21 May 2026 may remain subject to Regulation (EC) No 1013/2006 under Article 85; check the applicable consent and treatment deadlines. FOEN: implications of the new EU rules for Switzerland (July 2026).

2. Check the waste: Annex VII or consent?

First establish the waste list code, actual composition, any contamination, the relevant Basel/OECD entry and the planned recovery or disposal operation. A six-digit EWC/LoW code, or the absence of an asterisk, does not by itself authorise shipment under Annex VII. Also check Switzerland’s domestic rules for “special waste” and “other waste subject to control”: FOEN consent may be required even for a green-listed entry. FOEN: waste shipment guidance, Chapters 3–6.

For imports into Switzerland FOEN consent is generally required (Article 22 VeVA). An important exception covers certain waste imported from EU/OECD countries for recovery: it must be on the OECD Green List and not subject to control under Article 14(3) VeVA. For exports from Switzerland FOEN authorisation is generally required (Article 15 VeVA), with a corresponding exception for certain green-listed waste sent for recovery in EU/OECD countries. Where consent is required, Annex VII alone is insufficient.

If the route passes through Switzerland, Article 29 VeVA generally requires notification to FOEN. For a notified shipment, FOEN may prohibit transit within 5 days after the competent authority of destination acknowledges receipt of the notification. Transit consent is generally tacit. The Swiss notification exemption covers qualifying green-listed OECD/List B Basel waste transiting for recovery. The absence of a Swiss notification requirement does not automatically determine the procedure required by EU countries. FOEN: transit rules, Chapter 6; transit list updated on 1 October 2026.

3. What must the carrier prepare?

• Waste document: the new Annex VII form and the contract required by Article 18 for shipments genuinely eligible for the general information procedure, or a movement document and consents for notified shipments. FOEN provides the new Annex VII form and a model contract. Check the version accepted under the applicable 2026 transitional arrangements. FOEN forms and contract.
• Customs clearance: waste crossing the Swiss border must be declared correctly. For controlled waste, consent/notification details matter for customs documentation. Special waste in transit must be declared as such. FOEN: Chapters 6 and 9.
• EU requirements: check the carrier authorisations required in each EU country on the route. FOEN confirms that carriers physically operating in the EU must register in DIWASS. Select the appropriate EU authority to validate the registration; do not select FOEN, as it does not validate DIWASS accounts. FOEN: points 6–7.
• ADR/SDR: check separately whether the specific load is classified as dangerous goods for transport. Classification as controlled or hazardous waste does not automatically settle the ADR question. FOEN: Chapter 9.2.

In 2026, Swiss companies may continue to prepare and sign paper Annex VII documents and send them to their partners. On the EU side, transitional paper handling for Article 18 applies from 21 May to 31 December 2026. For shipments planned in 2027, check the EU electronic workflow and participants’ DIWASS access. The Swiss option to use paper does not provide a general exemption from EU obligations. FOEN: points 4 and 6; European Commission: DIWASS guidance.

In road transport, foreign carriers may not perform domestic cabotage between two locations within Switzerland; this restriction also applies to waste. Loading in Switzerland for an international shipment abroad is a different situation. FOEN: Chapter 9.3.

4. Two details that change the decision

B3011: the same waste, different directions

FOEN expressly states that, from 21 May 2026, exports of B3011 plastic waste from the EU to Switzerland are subject on the EU side to prior written notification and consent under Article 44(2)(c) of Regulation 2024/1157. FOEN also states that Switzerland may accept qualifying waste without its own import consent and does not process that notification on the Swiss side. For shipments CH → EU FOEN allows the Annex VII procedure for B3011, provided the shipment meets the other applicable conditions. Do not automatically write “B3011 = Annex VII” without identifying the direction and analysing the composition. FOEN: point 8.

Facility audits for exports from the EU from 2027

According to FOEN, from 21 May 2027 exports of waste from the EU to a Swiss recovery facility will require a facility audit confirming environmentally sound waste management. The EU exporter is responsible for ensuring the audit is carried out. In July 2026, FOEN stated that no EU–Switzerland agreement waived this requirement. Check the latest position before shipping after that date. FOEN: point 9.

Separate rules apply to mixed municipal waste sent from the EU to Switzerland for recovery: Regulation (EU) 2026/1703 introduced an exception for these exports, effective from 30 July 2026. This exception is not a general exemption from notification and consent. European Commission: amendment concerning Switzerland.

Checklist before accepting an order

• ☐ I know the loading and unloading countries and addresses, and all transit countries.
• ☐ I have the waste code, composition, Basel/OECD entry, contamination details and intended treatment operation.
• ☐ I have checked Swiss domestic controls and whether consent is needed in every relevant jurisdiction.
• ☐ For plastic waste, I have checked the direction-specific rules for B3011.
• ☐ I have the correct Annex VII and contract, or a valid notification, consents and movement document.
• ☐ I have prepared customs clearance and documents, and checked EU authorisations and DIWASS.
• ☐ I have checked ADR/SDR and ruled out prohibited cabotage in Switzerland.

FAQ – frequently asked questions

Do you have a specific route through Switzerland?

Send the waste code, description and composition, loading and unloading countries, transit countries and planned treatment at the facility. Permitra will help identify the correct procedure and documents before you accept your first order.

Official sources and further reading

1. FOEN, implications of Regulation (EU) 2024/1157 for Switzerland, July 2026 (French edition).
2. FOEN, Transboundary movement of waste, 2025 edition, revised 30 September 2026.
3. FOEN, Annex VII form and model Article 18 contract.
4. FOEN, no Swiss registration obligation for waste carriers.
5. European Commission, Regulation 2026/1703 concerning Switzerland.
6. FOEN, tacit transit consent, updated 1 October 2026.
7. European Commission, DIWASS and transitional Annex VII handling.