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Permitra • Transboundary waste shipments • 2026–2027
Green list vs amber list waste: Annex VII or notification?
Moving waste paper, scrap metal or plastics between EU countries? We explain how the two procedures differ, which documents go with each, what changes on 1 January 2027 and what the carrier is responsible for.
- Regulation (EU) 2024/1157
- Annex VII and DIWASS
The short answer
The list decides the procedure, not the carrier’s authorisations
Green-listed waste (Annexes III, IIIA and IIIB to Regulation 2024/1157), when shipped for recovery, is subject to the general information requirements of Article 18: an Annex VII document and a contract, with no authority consent for each shipment. Amber-listed waste – the term used in the heading of Annex IV and by the Irish and UK authorities for waste listed in that annex – is subject to notification, the procedure of prior written notification and consent, before the waste moves.
Notification can also be required for waste that is not on the amber list, and an EWC code without an asterisk does not by itself make waste green-listed.
Before accepting a load
Three separate questions
- Waste: which annex entry, and what is the actual composition?
- Shipment: Annex VII and a contract, or notification consents?
- Carrier: authorisations in every country on the route and access to DIWASS?
Green list and amber list: what do they actually mean?
“Green” and “amber” are the common names for the waste lists used in the rules on transboundary shipments of waste. Since 21 May 2026, the EU has applied Regulation (EU) 2024/1157, which replaced Regulation 1013/2006. It is this Regulation that determines which procedure applies to a given shipment.
Annexes III, IIIA, IIIB
Wastes and permitted mixtures which, when shipped for recovery in quantities above 20 kg, are subject to the general information requirements of Article 18 (Article 4(4)).
Annex IV
Wastes whose shipment for recovery is subject to prior written notification and consent (Article 4(2)(a)).
Other cases of notification
Waste without an appropriate entry, mixtures that are not permitted, waste classified as hazardous in the list of waste, contaminated waste and waste destined for disposal.
A code such as 19 12 01, 19 12 02 or 19 12 04 without an asterisk does not on its own mean the green list. The EWC code describes the type of waste; the procedure is determined by the annex entry, the composition of the load, contamination, the purpose of the shipment and its destination. We explain the difference between these code systems, with the examples of 15 01 02 and 19 12 04, in Green or amber list? Why the EWC code alone is not enough.
Green list: when does Annex VII apply?
Shipping green-listed waste for recovery does not require authority consent for each shipment, but it has its own mandatory elements (Article 18).
Annex VII
The Annex VII form is completed by all undertakings involved in the shipment, each in its own fields, including the carrier (Article 18(4)). A new form has applied since 21 May 2026.
Contract for recovery
It is concluded between the person who arranges the shipment and the consignee; if the consignee is not the operator of the facility, the facility operator also signs it. The contract must be effective from completion of the Annex VII document until the certificate of recovery (Article 18(10)).
Recovery under a permit
Waste may only go to a recovery facility that holds a permit or registration and presents it to the person who arranges the shipment before the shipment takes place (Article 18(3)).
Two working days
The person who arranges the shipment enters the available information no later than two working days before the shipment starts. The actual quantity, the carrier details and the container number may be provided just before departure (Article 18(5)).
What must be available during transport?
The Annex VII information must be available electronically, including during transport. If it cannot be made available online, the person who arranges the shipment and the carrier must make it available in the vehicle by other means, consistent with the electronic version (Article 18(6)).
A copy of the contract is provided to the inspection authorities at their request by the person who arranges the shipment or by the consignee (Article 18(11)). The Regulation therefore does not require the driver to carry the contract. In practice, however, it is worth having a copy in the cab: at a roadside check it shortens the explanations and the time the vehicle is held.
Article 18 covers shipments of green-listed waste above 20 kg (Article 4(4)). Waste explicitly destined for laboratory analysis or experimental treatment trials is also subject to Article 18, as a rule up to 250 kg (Article 4(5)). This is not a general exemption from the rules.
Amber list and other waste requiring notification
Notification (the procedure of prior written notification and consent, PIC) means that, before the shipment starts, the notifier must obtain the consent of the competent authorities of dispatch, destination and transit. Since 21 May 2026, new notifications have been handled electronically in DIWASS.
For waste destined for recovery, notification applies to (Article 4(2)):
- waste listed in Annex IV (the amber list);
- waste not classified under one single entry in Annex III, IIIB or IV;
- mixtures of waste not listed in Annex IIIA;
- waste classified as hazardous in the list of waste (codes with an asterisk);
- green-listed waste contaminated to an extent that increases the risks or prevents recovery in an environmentally sound manner;
- waste containing persistent organic pollutants (POPs) at or above the concentration limits.
Separate rules apply to mixed municipal waste and to refuse-derived fuel (RDF) processed from it: shipments for recovery require notification, and shipments for disposal are prohibited (Article 4(3)). Shipments of waste for disposal are prohibited in the EU as a rule; the exception is consent given under the notification procedure where the conditions of Article 11 are met (Article 4(1)).
Written or tacit
The authorities have 30 days to decide. If the authority of transit raises no objection within that period, tacit consent may be assumed (Article 9). Transport may only take place within the validity period of the consents and under their conditions.
Financial guarantee
Notified shipments require a financial guarantee or equivalent insurance. Among other things, it covers the cost of taking the waste back if the shipment cannot be completed as intended (Article 7).
Movement document
Once the consents have been obtained, the parties complete the movement document, whose information must also be available electronically during transport (Article 16).
A change of carrier, routing, dates or quantity compared with the notification is an essential change. The notifier must inform the authorities, and as a rule a new notification is needed unless all the competent authorities consider it unnecessary (Article 17). A carrier should not “swap in” a vehicle from another company or change the route on its own initiative.
Shipments notified under Regulation 1013/2006 and acknowledged by the competent authority of destination before 21 May 2026 remain subject to the old Regulation. Recovery or disposal under such consents must be completed by 21 May 2027 at the latest (Article 85(3) and (5)).
Green list vs amber list: comparison table
The comparison covers typical shipments for recovery between EU Member States.
| Element | Green list – Article 18 | Notification – PIC |
|---|---|---|
| Waste | Annexes III and IIIB, mixtures listed in Annex IIIA, for recovery | Annex IV, unlisted waste, non-permitted mixtures, hazardous waste, contaminated waste; any shipment for disposal |
| Consent before shipment | No | Yes, from the authorities of dispatch, destination and transit |
| Documents | Annex VII and contract for recovery | Notification document, consents, movement document, contract |
| Financial guarantee | Not required | Required |
| Advance notice | Information two working days before departure | Consents first; then the movement document two working days before each shipment |
| DIWASS | Mandatory from 1 January 2027 | Mandatory from 21 May 2026 |
| Carrier’s role | Completes its fields in Annex VII and confirms taking over the waste | Named in the notification; transports in line with the consents and the movement document |
| Change of carrier | Update of the Annex VII information | Essential change – the authorities must be informed; as a rule a new notification |
In the table, “amber list” is shorthand for the whole notification route. The precise meaning of both terms is explained in part 01.
Annex VII or notification? Decision chart
The chart shows the logic of the rules. It does not replace an assessment of the specific load of waste.
Article 18 – Annex VII
Annex VII, contract for recovery, a permitted facility, information two working days in advance.
Notification or prohibition
Prior written notification and consent, financial guarantee; in some cases the shipment is prohibited.
If the authorities of dispatch and destination cannot agree on the annex entry, the shipment is subject to notification (Article 29(4)).
2026–2027 deadlines: paper Annex VII and DIWASS
- 21.05.2026
New Regulation
Regulation 2024/1157 applies; new Annex VII form and new contract requirements; notifications only in DIWASS.
- 31.12.2026
End of the paper period
The Commission postponed the green-list module in DIWASS; until this date the Irish authority advises paper Annex VII documents.
- 01.01.2027
Annex VII electronic only
Green-list shipments are entered in DIWASS, at least two working days before the shipment starts.
Dates based on Regulation 2024/1157 and the briefing note of Dublin City Council (National TFS Office) of 9 April 2026, which refers to the European Commission’s decision.
From 21 May 2026 the Regulation requires Annex VII information to be made available electronically. The European Commission decided to postpone the green-list module in DIWASS until 1 January 2027. In Ireland, the competent authority for waste shipments is Dublin City Council, through the National TFS Office. It has advised that, until 31 December 2026, paper Annex VII documents should continue to accompany green-list shipments and carriers should physically sign the document when they collect the waste. From 1 January 2027, the person who arranges the shipment must enter the Annex VII information in DIWASS at least two working days before the shipment starts.
The United Kingdom is outside the EU. For EU law, a shipment between the EU and Great Britain is an export from or an import into the EU; on the British side, Great Britain’s own rules (the assimilated Regulation (EC) No 1013/2006) and its competent authorities apply, in England the Environment Agency. On routes through other countries, the practice of their authorities applies.
From 1 January 2027, Annex VII is handled in DIWASS or in a national system connected to it. The two-working-day deadline in Article 18(5) then applies in full. The carrier works in the system in its own role: it has access to the Annex VII documents in which it is named and confirms in them that it has taken over the waste (Implementing Regulation 2025/1290). This is why a transport company should be registered in DIWASS, with its authorised staff having access to the account. We cover the changes in more detail in DIWASS from 2027.
Checklist before accepting and carrying out a transport
Whether the shipment is lawful and whether the carrier is ready are two separate questions. It is best to check both before confirming the order.
- The waste code and the correct annex entry have been confirmed.
- The description of composition and contamination matches the actual load.
- The facility and the recovery (or disposal) operation are known.
- Annex VII and a contract, or notification consents and a movement document, are in place.
- The transport date falls within the validity period of the consents.
- The company holds registrations or permits in every country on the route.
- The carrier and vehicle details in the documents match the facts.
- The driver has access to the shipment information, including offline, and a copy of the contract.
- It has been agreed with the organiser who completes and confirms the carrier’s fields.
- Any additional obligations have been checked where relevant (e.g. SENT, ADR).
- The driver has the organiser’s contact details in case of an inspection.
Neither Annex VII nor a notification consent replaces a carrier’s national registration, and a carrier registration in one country is not a permit to transport waste in other countries on the route. We discuss the requirements along the route in our guide Waste transport across Europe in 2026/2027.
Frequently asked questions
Does a waste code without an asterisk mean the green list?
No. The EWC code and the annex entry under Regulation 2024/1157 are two different systems. The procedure depends on the entry, composition, contamination, purpose and destination. See Why the EWC code alone is not enough.
Is all hazardous waste on the amber list?
No, these are different concepts. However, waste classified as hazardous in the list of waste requires notification when shipped for recovery under Article 4(2)(d), regardless of the amber list.
Does the driver have to carry the contract in the cab?
The Regulation requires the person who arranges the shipment or the consignee to provide a copy of the contract to the inspection authorities at their request (Article 18(11)). It does not oblige the driver to carry it, but a copy in the cab makes inspections easier and is worth having.
Can a paper Annex VII be used until the end of 2026?
In Ireland, Dublin City Council’s National TFS Office has advised that paper Annex VII documents should continue to accompany green-list shipments until 31 December 2026, because the Commission postponed the green-list module in DIWASS. This is authority guidance, not an amendment to the Regulation; in other countries on the route, the practice of their authorities applies, and in Great Britain its own rules apply.
What changes for carriers on 1 January 2027?
Annex VII becomes electronic, and the carrier must be available in DIWASS so that it can be named in the document and confirm that it has taken over the waste. As a rule, the person who arranges the shipment enters the information two working days before departure.
Is the carrier responsible for classifying the waste?
Classification and the choice of procedure are primarily the responsibility of the person who arranges the shipment or the notifier. The carrier is responsible for its own information, confirmations and authorisations, and should not ignore an obvious discrepancy between the documents and the load.
Can an old notification consent still be used?
Shipments notified under Regulation 1013/2006 and acknowledged by the authority of destination before 21 May 2026 remain subject to the old Regulation. However, recovery or disposal must be completed by 21 May 2027 at the latest (Article 85).