DIWASS and Annex VII for waste transport: carrier obligations in 2026 and 2027

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  • 2026-10-15
Permitra • DIWASS / Annex VII • 2026–2027

DIWASS and Annex VII for waste transport: carrier obligations in 2026 and 2027

Transporting waste between EU countries? Find out when paper Annex VII documents are still accepted, what is expected to change in 2027 and how to prepare drivers and dispatchers for inspections.

Regulation (EU) 2024/1157A guide for transport companies
The short answer

Paper Annex VII documents are still accepted, but new rules apply

Until 31 December 2026, Poland’s Chief Inspectorate for Environmental Protection (GIOŚ) accepts paper Annex VII documents outside DIWASS, provided that the new form is used and a contract complying with Article 18 is in place. From 1 January 2027, electronic handling of Article 18 documents through DIWASS or interconnected systems is expected to become mandatory under the announced timetable. This does not postpone the entire Regulation: DIWASS has been required for notifications since 21 May 2026, subject to the transitional provisions.

Before accepting a load

Three separate checks

  • Waste: Annex VII or notification?
  • Companies: DIWASS registration and national authorisations.
  • Route: documents, Poland’s SENT system, ADR and customs requirements, where applicable.

01

Three dates that affect shipment documentation

When planning shipments for late 2026, distinguish the notification procedure from the general information requirements under Article 18 (Annex VII). Their implementation timetables differ.

21.05.2026

New Regulation applies

DIWASS for notifications; a new Annex VII form and revised contract requirements.

15.11.2026

Planned module launch

Announced production launch of the electronic Annex VII module.

01.01.2027

Mandatory electronic Annex VII

Announced end of transitional paper handling under Article 18.

Dates follow the GIOŚ announcement cited below. Confirm the implementation status immediately before shipment; the November date is a planned launch, not an already completed event.

What is allowed during the transitional period? Until 31 December 2026, GIOŚ accepts preparation and transmission of paper Annex VII documents and the contract outside DIWASS. The new form, the required contract and all other conditions applicable to the shipment remain necessary. For an international route, also check the positions of the other competent authorities. This is a transitional administrative approach, not a postponement of the entire Regulation.

02

What is DIWASS, and is it a permit?

DIWASS (Digital Waste Shipment System) is the EU system for electronic exchange of information and documents concerning cross-border waste shipments. It handles notifications, movement documents and Annex VII documents, among other functions.

System

DIWASS

Electronic information exchange and identification of shipment participants.

Shipment procedure

Annex VII / PIC

Determines whether general information requirements suffice or prior consent is required.

National law

BDO / §53 / VIHB…

Authorisations or registrations for waste transport in individual countries.

A DIWASS account does not replace a national waste carrier permit or registration. Examples include BDO registration with the appropriate scope in Poland, notification under §53 or a permit under §54 KrWG in Germany, and VIHB registration in the Netherlands. Requirements and exemptions depend on the company’s role and the country; these are national examples, not EU-wide substitutes.

03

Decision flowchart: Annex VII or notification?

Do not start by asking whether the waste code has an asterisk. Before preparing documents, establish the waste’s composition, its Basel/OECD entry, the purpose of shipment, the countries along the route and the destination facility.

WASTE TRANSPORT ORDER
Do the waste, route and purpose meet the conditions for the Article 18 information procedure?

YES — after classification

ANNEX VII

The general information procedure for eligible shipments destined for recovery.

  • New Annex VII form
  • Contract required by Article 18
  • Confirmed details of all parties
  • Paper handling possible in 2026 under the stated conditions

NO / prior consent required

NOTIFICATION (PIC)

The prior written notification and consent procedure must be completed before shipment.

  • Notification documentation
  • Valid consents from the competent authorities
  • Movement document
  • DIWASS handling since 21 May 2026, subject to transitional provisions

Some shipments are prohibited rather than merely subject to notification. Do not choose a procedure solely on the basis of the EWC code.

A common mistake Codes 15 01 02 and 19 12 04 identify waste types in the European List of Waste. They do not, by themselves, establish that a shipment is green-listed and eligible for Annex VII. Actual composition, contamination, the applicable shipment entry, destination and recovery operation all matter.

Related reading: Green or amber list? Why the EWC code alone is not enough — find the article in the Permitra knowledge base (Polish).

04

Annex VII in 2026: new forms and the contract

Shipments covered by Article 18 require the new Annex VII form under Regulation (EU) 2024/1157. It identifies the participants, waste, operation, locations, route and carriers. A CMR consignment note alone does not replace Annex VII.

Who prepares the document, and when?

The person arranging the shipment is responsible for preparing the information. The relevant information must generally be provided at least two working days before the shipment starts; the actual quantity, carrier details and any container identification number may be added up to the start of shipment. During the transitional period, follow the applicable arrangements for paper documents. For electronic handling, ensure access to the shipment information in the vehicle even when an internet connection is unavailable, as required by Article 18(6).

Article 18 contract: must it be in the cab?

A contract between the person arranging the shipment and the consignee must be in place and meet the Regulation’s requirements. If the consignee does not operate the recovery facility, the facility operator must also sign. In the specific case of shipments between two establishments controlled by the same legal entity, that entity’s declaration may replace the contract.

The contract must be made available when requested by the authorities, but there is no universal requirement for every driver to carry a full paper copy. Operationally, arrange access in the cab or immediate access through the dispatcher.

05

How to prepare your company’s DIWASS registration

Unregistered operators cannot simply be typed into an electronic document. The carrier, consignee and facility must be selectable in DIWASS when it is used for the shipment.

1

Create an EU Login account

Set up the account for the user who will represent the company. If a national interconnected system is required, follow the access method specified by the competent authority.

2

Register the economic operator

Enter the correct company name, identifiers, address and activities. Identify the competent authority responsible for the company.

3

Obtain validation

Check the operator’s status and any authority requirements. Submitting a request does not by itself mean the registration is active.

4

Check roles and document access

Assign users responsible for documents, confirmations and data updates. Practise before 2027.

Non-EU participants may also need registration The European Commission explains that third-country operators and authorities involved in shipments from, to or through the EU must be available in DIWASS. Registration serves technical identification; it does not automatically mean that every participant must operate the system themselves.

Official guidance and access: European Commission — DIWASS and Poland’s GIOŚ — DIWASS information point.

06

What does the carrier check, and what does the organiser check?

Area Primarily the organiser / customer Carrier / dispatcher
Classification Confirming the waste, procedure and facility. Checking that the documents match the load and route; resolving discrepancies.
Annex VII / PIC Preparing the document and ensuring the appropriate consents and contract are in place. Carrier details, updates and confirmations required for the carrier’s role.
DIWASS Identifying participants and preparing information exchange. Active registration and user permissions to the extent required.
Route Countries, facility and shipment procedure. Waste transport authorisations along the route, CMR, national documents and ADR/SENT/customs formalities, where applicable.

This is an operational division of tasks, not an automatic transfer of legal liability. Specific obligations depend on the participants’ actual roles and the rules applicable to the shipment.

DIWASS ≠ BDO ≠ SENT DIWASS concerns shipment document exchange, BDO covers the relevant Polish carrier registration, and SENT is Poland’s monitoring system for specified transport operations. None replaces the others.

Read more: BDO for foreign waste carriers (Poland; Polish article) and SENT — guide and checklist (Poland; Polish article).

07

Two pre-loading checklists

Use separate office and driver checks. This helps identify discrepancies before departure instead of during a roadside inspection.

Freight forwarder / dispatcher
Established whether the material being transported is waste.
Checked the EWC/LoW code and Basel/OECD entry.
Confirmed the Annex VII or PIC procedure.
Checked the consignee, facility and recovery operation.
Checked DIWASS registration and national authorisations.
Arranged the contract and any required SENT, ADR and customs formalities.
Checked document consistency and contact details.
Driver
I have the correct Annex VII or the documents required for a notified shipment.
The correct carrier is listed in the documents.
The waste type and quantity match the load.
The route, consignee and facility are correct.
I have the CMR and required national documents.
During an inspection, I can obtain the contract and contact the dispatcher.
I know what to do if there is an error or no connection; shipment information remains accessible in the vehicle.

08

Routes outside the EU require additional checks

Switzerland and Ukraine illustrate why the same waste code does not always mean the same set of documents. Third-country requirements, possible customs formalities and specific import/export rules apply alongside EU law. This guide does not establish authorisation for any particular third-country route.

Do not assume DIWASS registration allows exports to any country. A specific shipment may require notification or be prohibited.

09

Frequently asked questions (FAQ)

Is paper Annex VII sufficient until 31 December 2026?

GIOŚ accepts paper handling under Article 18 outside DIWASS during this period, provided the new form is used, the required contract is in place and all other shipment obligations are met. For routes involving other countries, check their competent authorities’ approach as well.

What changes on 1 January 2027?

Under the announced timetable, Annex VII documents are to be handled electronically in DIWASS or interconnected systems. Before the first shipment, check current European Commission and competent authority announcements.

Does every carrier need a DIWASS account?

The Commission states that operators involved in shipments from, to or through the EU must be registered so that they can be selected in electronic documents. This includes carriers. Operator registration is distinct from a personal user account and does not replace national authorisations.

Can all non-hazardous waste travel with Annex VII?

No. You must assess the actual composition, Basel/OECD entry, destination, purpose and facility. The six-digit EWC code alone is insufficient.

Must the driver have a paper contract in the cab?

The relevant contract must be available on request by the authorities, but there is no universal requirement for every driver to carry a full paper copy. We recommend immediate access to it.

Does BDO registration or a CMR replace Annex VII?

No. BDO concerns national registration in Poland, CMR documents road carriage, and Annex VII is required for specified waste shipments. Each has a different function.

Permitra support

Have a waste transport order but are unsure which documents you need?

Send us the waste code and description, planned route, carrier’s country of establishment and facility details. We will help identify the procedure and formalities needed before departure.

Our mission is to help companies like yours enter new markets, achieve higher margins, and obtain the necessary waste transport permits across Europe without stress.

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