Polski 
Deutsch 
Español 
Français 
Italiano 
Nederlands 
Čeština 
Română 
Lietuviškai 
Українська 
Permitra • Germany • 2026–2027
Waste Transport Permit in Germany – §53 and §54 KrWG for Carriers
Are you moving waste to Germany, from Germany or through Germany? We explain when a notification under §53 is enough, when a permit under §54 is needed, what the authorities check and where the rules leave room for interpretation.
- Kreislaufwirtschaftsgesetz (KrWG)
- Regulation (EU) 2024/1157
The short answer
Yes, a carrier from Poland is also subject to the German KrWG
Professional transport of waste in Germany requires a notification of the activity under §53 KrWG (non-hazardous waste) or a permit under §54 KrWG (hazardous waste). Being established in another country does not remove this obligation, and the German rules also cover activity in Germany as part of a cross-border shipment, including transit.
A Polish BDO entry does not replace the German notification.
Before accepting a job
Three separate questions
- Waste: hazardous or not? §53 or §54?
- Company: professional transport or an exception?
- Shipment: Annex VII or notification?
The national system: notification under §53 and permit under §54 KrWG
The basis is the Circular Economy Act (Kreislaufwirtschaftsgesetz, KrWG) and the Notification and Permit Ordinance issued under it (Anzeige- und Erlaubnisverordnung, AbfAEV). The law distinguishes two regimes, depending on the type of waste.
| Element | §53 KrWG – notification (Anzeige) | §54 KrWG – permit (Erlaubnis) |
|---|---|---|
| Waste | Non-hazardous | Hazardous |
| Nature | Notification before starting the activity; the authority confirms receipt | Decision of the authority before starting the activity |
| Requirements | Reliability of the owner and of the persons managing the business, and the expertise of the managers and staff | |
| Authority | The authority of the federal state (Land). For a company established abroad: the Land in which the activity is first carried out (§7(2) and §9(2) AbfAEV) | |
| Scope | Activity throughout Germany | The permit applies throughout Germany (§54(1)) |
A notification under §53 is not a permit in the Polish sense. The authority may, however, make the activity subject to conditions, limit it in time, demand documents and, where there are doubts about reliability or a lack of expertise, must prohibit it (§53(3)). The rules provide no expiry date for a notification. If material data change, the notification is submitted again (§7(7) AbfAEV).
As a rule, reliability is lacking if, in the five years before the notification, the owner or a person managing the business was fined more than €2,500, among other things for breaches of waste, transport or ADR law (§3(2) AbfAEV).
We have devoted a separate article to hazardous waste in Germany: Transport of hazardous waste in Germany – §54 KrWG and ADR. Here we concentrate on §53 and on what is common to both regimes.
Who is covered and what the exceptions are
The KrWG treats as a waste transporter anyone who transports waste professionally or in the course of another economic activity (§3(11)). A transport company providing a waste transport service for customers falls in the first group. The AbfAEV also covers activity carried out on German territory as part of the cross-border shipment of waste (§1(2)), so the mere absence of loading or unloading in Germany does not remove the obligation.
Entsorgungsfachbetrieb
A certified “specialised waste management company” (§56 KrWG) does not need a permit under §54, but only for the certified activity (§54(3)). It still submits a notification under §53 and attaches the certificate to it. A certificate is valid for 18 months at most.
Occasional transport
Transport in the course of another activity, carried out unusually and irregularly, is exempt from notification. Regularity is presumed above 20 t of non-hazardous waste or 2 t of hazardous waste a year (§7(9) AbfAEV). The exception does not cover haulage companies.
A separate permit under §54
Transporting hazardous waste requires a separate permit under §54 KrWG, issued after an assessment of reliability and qualifications. We describe the details in the article on hazardous waste.
Anyone holding a permit under §54 does not additionally need to notify the activity under §53 (§53(1)). Further exceptions to the permit requirement, for example for take-back systems or courier services, are listed in §12 AbfAEV.
On the road: “A” plates and documents in the vehicle
A person transporting waste in the course of their business marks the vehicle before the journey with two white, reflective “A” plates (A-Schilder, §55 KrWG). The dimensions are set by §10 of the Waste Shipment Act (AbfVerbrG): at least 40 × 30 cm, a black letter “A” 20 cm high, a plate at the front and at the rear and, for a combination with a trailer, at the rear of the trailer. Marking is not required for transport in the course of another activity. In particular cases the authority may grant an exemption from the plates (§13a AbfAEV). “A” plates do not replace ADR marking.
The vehicle should carry a document confirming the authorisation (§13 AbfAEV):
- for §53: a copy or printout of the notification confirmed by the authority; until the authority has confirmed it, a copy with a note to that effect;
- for §54: a copy or printout of the permit, also where the journey carries non-hazardous waste;
- for the Entsorgungsfachbetrieb exemption: a current certificate.
For a cross-border shipment, the documents for the consignment itself are added (Annex VII or notification documents).
Cross-border transport: Annex VII, notification and DIWASS
A notification under §53 or a permit under §54 concerns the carrier. The procedure for a particular consignment is laid down by Regulation (EU) 2024/1157, applicable from 21 May 2026: for eligible waste destined for recovery it is Annex VII (Art. 18), and in other cases prior written notification and consent (notification).
The Federal Ministry for the Environment (BMUKN) and the Länder announced on 28 April 2026 that, for shipments under Art. 18, no sanctions will be imposed until 31 December 2026 for handling Annex VII on paper, provided the documents are carried in the vehicle and drawn up on the new template. From 1 January 2027 at the latest, the electronic form applies. The transitional period does not apply to notifications: for these DIWASS has been mandatory since 21 May 2026.
Inspections and sanctions
Compliance with the KrWG is supervised by the authorities of the Länder. In inspecting waste shipments they work with the customs service and the Federal Office for Logistics and Mobility (BALM, §11(2) AbfVerbrG). For companies with neither a seat nor a branch in Germany, fines for road transport are imposed by BALM (§69(4) KrWG).
No notification under §53
Transporting non-hazardous waste without a notification or on an out-of-date notification.
Consequence: a fine of up to €10,000 (§69(2) no. 1 KrWG).
Hazardous waste without §54
The company has only a notification under §53, and the load carries a hazardous waste code.
Consequence: a fine of up to €100,000 (§69(1) no. 7 KrWG).
No “A” plates or document
A vehicle without marking, or a driver without a copy of the notification or permit.
Consequence: a fine of up to €10,000 for each of these breaches (§69(2) nos. 13 and 15 KrWG, §15 AbfAEV).
Illegal shipment
The wrong procedure for the consignment, for example Annex VII instead of a notification.
Consequence: a fine of up to €50,000 (hazardous waste) or €20,000 (§18 AbfVerbrG). In certain cases, a criminal offence under §326 StGB.
The amounts given are upper limits. The amount of a fine in a particular case is set by the authority. The indirect consequence can be more serious than the fine itself: a fine above €2,500 may undermine the company’s reliability in a later notification or permit application.
Disputed points and questions to settle for a particular company
- Which Land is competent for transit alone? The provision refers to the place where the activity is carried out “for the first time”. For a journey through several Länder, this has to be settled case by case.
- Driving between submission and confirmation of the notification. The AbfAEV provides for a situation in which the authority has not yet confirmed the notification. The authority may nevertheless impose conditions or prohibit the activity, so the risk depends on the completeness of the documents.
- Mixed loads and uncertain classification. The choice between §53 and §54 depends on the classification of the waste under the German list (AVV). A code with an asterisk, as a rule, means hazardous waste (§3 AVV), and therefore §54, even if the rest of the load is non-hazardous waste. In exceptional cases the authority may assess the waste differently.
We describe the requirements in other countries on the route in the overview Waste transport across Europe in 2026/2027.
Frequently asked questions
Is a Polish BDO entry enough to transport waste in Germany?
No. BDO is a Polish registration. Professional transport of waste in Germany requires a notification under §53 or a permit under §54 KrWG, unless the company falls within a statutory exception. For hazardous waste a separate permit under §54 is needed – details in a separate article.
Is a notification needed if I am only passing through Germany?
As a rule, yes. The AbfAEV covers activity carried out on German territory as part of the cross-border shipment of waste, and the Act does not exempt transit.
Can I transport hazardous waste with a notification under §53?
No. Hazardous waste requires a permit under §54 or a basis for exemption, for example an Entsorgungsfachbetrieb certificate for the relevant scope. We describe the details in the article on §54 KrWG.
How long is a notification under §53 valid?
The rules provide no expiry date. The authority may, however, limit the activity in time, and if material data change (for example the company or the persons managing it), the notification is submitted again.
Is a German notification enough in other EU countries?
A notification or permit under the KrWG is a German authorisation. The requirements for a carrier in other countries on the route follow from their national law and must be checked separately.
What penalties apply for the lack of a notification?
The KrWG provides for a fine of up to €10,000 for the lack of a notification under §53 and up to €100,000 for transporting hazardous waste without a permit under §54. For foreign companies, proceedings are conducted by BALM.