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Permitra • DIWASS / Annex VII • 2026–2027
DIWASS and Annex VII in waste transport – carrier obligations in 2026 and 2027
Do you have a job to carry waste between EU countries? Find out when a paper Annex VII is still enough, what changes on 1 January 2027, who must be registered in DIWASS and where registrations most often get stuck.
- Regulation (EU) 2024/1157
- Implementing Regulation (EU) 2025/1290
- A guide for transport companies
The short answer
A paper Annex VII is still acceptable, but only until the end of 2026
Until 31 December 2026 the Polish competent authority GIOŚ accepts a paper Annex VII and a contract handled outside DIWASS, provided that the new form is used and the contract meets the requirements of Article 18. From 1 January 2027 Annex VII documents are to be handled electronically: in DIWASS or in a system interconnected with it.
Before that, every company that appears in the document, including the carrier, must be registered in DIWASS. A company that is not in the system cannot be selected in the document.
Before accepting a load
Three separate questions
- Waste: Annex VII or notification?
- Companies: DIWASS registration and national authorisations.
- Route: documents, SENT, ADR, customs – where applicable.
Three dates that change transport documentation
When planning journeys around the turn of 2026 and 2027, you need to distinguish the notification procedure from the general information requirements (Article 18, Annex VII). Each has a different timetable.
- 21 May 2026
New Regulation
Regulation 2024/1157 applies in full. Notifications go through DIWASS. The new Annex VII form and the new contract requirements apply.
- 15 Nov 2026
Announced module launch
The Commission announced that from this date DIWASS should allow Annex VII to be handled in production. Until then the module was available as a test version.
- 1 Jan 2027
DIWASS mandatory
End of the transitional paper workflow. Annex VII and the contract electronic only.
Dates according to notices issued by GIOŚ (the Polish competent authority) after the meetings of the Commission expert group of 27 March and 14 September 2026. As at 10 November 2026, the production Annex VII module has not yet been launched.
Until 31 December 2026 GIOŚ allows Annex VII and the contract to be drawn up and passed on in paper form, outside DIWASS. There are two conditions: the new form template under Regulation 2024/1157 and a contract that complies with Article 18. During this period GIOŚ will not treat a shipment as illegal merely because the documents were not entered into DIWASS, as long as paper documents accompany the transport. This is the position of the Polish authority. Where the route passes through other countries, the approach of their authorities also matters.
What is DIWASS and is it a permit?
DIWASS (Digital Waste Shipment System) is the EU system for the electronic exchange of documents and information on cross-border shipments of waste, run by the European Commission (Article 27 of Regulation 2024/1157). It handles, among other things, notifications, movement documents and Annex VII.
DIWASS
Electronic exchange of information and identification of the parties involved in a shipment.
Annex VII / PIC
Determines whether the information procedure is enough or prior consent is needed.
BDO / §53 / VIHB
Authorisations to carry out waste transport on the territory of specific countries.
Registration in DIWASS does not replace a national permit or carrier registration. In Poland this is, as a rule, an entry in the Polish BDO register within the relevant scope; in Germany, a notification under §53 or a permit under §54 KrWG; in the Netherlands, a VIHB listing. Obligations depend on the company’s role and on the country.
Decision flow: Annex VII or notification?
Don’t start by asking whether the waste code “has an asterisk”. Annex VII (Article 18) applies to shipments for recovery of green-listed waste (Annexes III and IIIB) and of certain mixtures (Annex IIIA) where the load exceeds 20 kg. It also covers small quantities for laboratory analysis (Article 4(4) and (5)). Before the document is created, you need to know the composition of the waste, the correct Basel/OECD entry, the purpose of the shipment, the countries on the route and the destination facility.
Annex VII
Information procedure for qualifying shipments destined for recovery.
- New Annex VII form
- Contract required by Article 18
- All parties registered in DIWASS
- Paper workflow possible until 31 Dec 2026
Notification (PIC)
Prior written notification and consent are needed before transport.
- Notification documents
- Valid consents of the competent authorities
- Movement document
- Handled in DIWASS from 21 May 2026, subject to transitional provisions
In some cases transport is prohibited, not merely subject to notification. The EWC code alone does not determine the procedure.
Code 15 01 02 or 19 12 04 tells you the type of waste according to the European list. It does not yet prove that the consignment is green-listed and can travel under Annex VII. What matters is the actual composition, contamination, the shipment entry, the destination and the recovery process.
Related article: Green or amber list? Why the EWC code alone is not enough.
Annex VII in 2026: the new form and the contract
For shipments covered by Article 18, the new Annex VII form under Regulation (EU) 2024/1157 is used. The form identifies the parties, the waste, the recovery operation, the locations, the countries and all carriers. A CMR consignment note alone does not replace Annex VII.
Who prepares the document and when?
The form is completed by all undertakings involved in the shipment, each in its own part, with the main burden falling on the person who arranges the shipment. That person completes the information no later than two working days before the start of the shipment. The actual quantity, the carrier details and the container number may be provided at the latest before the start (Article 18(4) and (5)). The carrier confirms taking over the waste in its part of the document.
The Article 18 contract: does it have to be in the cab?
The contract between the person who arranges the shipment and the consignee must be concluded at the latest by the time Annex VII is completed and remain effective until recovery is certified. If the consignee does not operate the facility, the operator of the facility also signs the contract. It must contain, among other things, details of the parties, a description and codes of the waste, quantities, the recovery operation, the period of validity and an obligation to take the waste back if the shipment cannot be completed (Article 18(10)).
The person who arranges the shipment or the consignee provides a copy of the contract to the authorities involved in inspections at their request (Article 18(11)). The rules do not impose a general obligation on every driver to carry a full paper copy. This is one of the issues that are sometimes interpreted differently during inspections. The Annex VII information must, however, be available in the vehicle: electronically or, where online access is not possible, by other means consistent with the data in the system (Article 18(4) and (6)).
More about the document itself: Annex VII 2026/2027: how to complete the new form and contract.
DIWASS registration: who it applies to and how it works
In DIWASS a company cannot be entered manually. Each party is selected from a list, and only registered operators appear on that list. The European Commission states this explicitly: all parties to a shipment must be registered where an EU Member State is the country of dispatch, transit or destination. This covers the person who arranges the shipment, the waste producer, the carrier, the consignee and the facility. From 2027, if any one of them is not registered, the whole document is blocked.
Every carrier named in the shipment documents must be in the system, regardless of the country where it is established and even if it drives only one leg.
Parties from third countries involved in shipments from, to or through the EU must also be in DIWASS. The Commission treats this as a technical requirement.
Without them the document cannot be created, even if the carrier is ready.
Two levels: the person and the company
Implementing Regulation 2025/1290 separates two things. A personal user account is created by every person who will work in the system (Article 6). Registration of the company (the operator) is approved by the competent authority of the Member State where the company has its registered office – in Poland, GIOŚ (Article 7). The authority only checks whether the company exists and whether the person is entitled to represent it. It has 5 working days to do so and, if it asks for additional information, a further 3 working days from receiving it. It may also refuse.
| Element | What the rules say | Why it matters |
|---|---|---|
| Master user | Each company must have at least one master user. Only a master user can add and remove further users (Article 6(3)–(5)). | The first person approved by the authority becomes the master user. If that person leaves the company, nobody can add new people. |
| Roles | A company acts in the system in specific roles: carrier, person who arranges the shipment, consignee, facility receiving waste, waste producer, notifier (Article 10). | The same company may act in several roles, e.g. as carrier and as person who arranges the shipment. |
| Identification number | A company registered for customs purposes provides its EORI number. Others provide the number designated by their country (Article 9). | The number determines whether a business partner can find the company on the list. |
| Sites | A company may register sites, and the authority checks their link to the company (Article 7(7), Article 9(6)). | The correct site must be indicated for each operation. |
| Carrier access | A company acting only as a carrier uses DIWASS via the system’s web interface or via an eFTI platform interconnected with the system (Article 5(2)). | The carrier does not have to buy software, but someone in the company must know how to use the system. |
Submitting an application does not by itself mean an active registration. If approval drags on beyond 31 December 2026, the carrier cannot be named in the document.
Where DIWASS registrations most often get stuck
We help carriers register in DIWASS. Below are the problems we see most often and their consequences for transport.
Company not visible on the list
The business partner cannot select the carrier in the document. Usually the application has not been submitted or is still awaiting the authority’s approval.
Consequence: from 2027 the document cannot be issued and the journey has to wait.
A personal account, but no company
An employee has a personal account but is not linked to the company or has no role assigned. Such an account gives no access to the shipment documents.
Consequence: the company believes it “is in DIWASS”, but it is not.
Only one master user
Registration is set up by a single person who later leaves the company or cannot be reached.
Consequence: nobody can add a dispatcher or change permissions, and restoring access takes time.
Incorrect identification details
A different identification number, name or address than in the registers, or a duplicate registration of the same company.
Consequence: a request for additional information or a refusal, and the business partner cannot find the right operator.
Non-EU carrier
A company from Ukraine, Turkey or the Balkans must be in DIWASS, but there is no authority in the EU that registers it in the same way as an EU company. How it is registered depends on its role and on the shipment.
Consequence: unless the route to registration is clarified in advance, the document gets stuck at the stage of selecting the carrier.
Applications piling up at year-end
The authority has statutory deadlines, but every request for additional information pushes registration back. The largest number of applications will come before 1 January 2027.
Consequence: a registration approved only in January means downtime on the first journeys.
Nobody can handle the document
The registration is in place, but the dispatcher does not know how to confirm taking over the waste, check the shipment data or add a driver.
Consequence: errors in the document and waiting at loading.
DIWASS registration mistaken for a permit
The company has an active account and assumes it may carry waste in any country.
Consequence: penalties for lacking BDO, §53/§54 KrWG, VIHB or another authorisation in a country on the route.
What does the carrier check, and what does the person who arranges the shipment check?
| Area | Mainly the person who arranges the shipment / client | Carrier / dispatcher |
|---|---|---|
| Classification | Confirming the waste, the procedure and the facility. | Whether the documents match the load and the route; clarifying discrepancies. |
| Annex VII / PIC | Creating the document, the relevant consents and the contract. | Carrier details, confirmation of taking over the waste and updates within its role. |
| DIWASS | Selecting the parties and preparing the information exchange. | Active company registration, a master user and dispatcher permissions. |
| Route | Countries, facility and shipment procedure. | Waste transport authorisations in the countries on the route, CMR, national documents, ADR/SENT/customs – where applicable. |
This is an operational split, not an automatic transfer of legal responsibility. The specific obligations depend on the parties’ actual roles and on the rules applicable to the shipment in question.
DIWASS concerns the exchange of shipment documents, the Polish BDO register confirms the scope of a carrier’s registration in Poland, and SENT is Poland’s national monitoring system for certain transports. None of them replaces the others.
More: BDO for foreign waste carriers (in Polish) and SENT in road transport.
Risks during inspections
Most hold-ups at inspections are not caused by bad faith, but by a single element that does not match.
Procedure chosen by EWC code
The waste travels under Annex VII, although its composition or destination required notification.
Consequence: the transport may be treated as an illegal shipment of waste.
Old Annex VII template
From 21 May 2026 the new form applies, including in the paper workflow.
Consequence: a non-compliant document despite complete data.
Article 18 contract not available on request
The contract exists, but nobody can make it available during the inspection.
Consequence: waiting until the matter is clarified and a risk of proceedings.
Documents do not match the load
A different weight, type of waste, carrier or facility than in the document.
Consequence: the load is held until the matter is clarified.
Each of these points has to be resolved for the specific shipment and the specific route. That is what we do every day.
Routes and non-EU companies
Switzerland and Ukraine show why the same waste code does not always mean the same set of documents. On top of EU rules come the requirements of the third country, customs obligations and specific import and export rules.
The Commission states that companies from third countries must be in DIWASS, but using the system is voluntary for them. They can work in it themselves or simply be identifiable in the documents. For a carrier from Ukraine, this means it must be established who will enter it into the system, and on what basis, before the first document goes into DIWASS.
Registration in DIWASS does not mean that export to any country is permitted. In specific cases a shipment may require notification or be prohibited.
Frequently asked questions
Is a paper Annex VII enough until 31 December 2026?
During this period the Polish competent authority GIOŚ accepts a paper Annex VII and a contract handled outside DIWASS, provided that the new template is used, a contract compliant with Article 18 is concluded and the other obligations are met. Where the route passes through other countries, their approach also matters.
What changes on 1 January 2027?
Annex VII documents and contracts are to be handled exclusively electronically, in DIWASS or in systems interconnected with it. Every party to the shipment, including the carrier, must by then be actively registered.
Does every carrier have to be registered in DIWASS?
Yes. The Commission states that all parties to a shipment from, to or through the EU, including carriers, must be registered, because only then can they be selected in the document. Registration does not, however, replace national permits.
Who approves a company’s registration in DIWASS?
The competent authority of the Member State where the company has its registered office. In Poland this is the Chief Inspector of Environmental Protection (GIOŚ). A company based in Germany or Czechia registers with the authority of its own country, not in the countries on the route.
How long does company registration take?
Implementing Regulation 2025/1290 gives the authority 5 working days to decide and, after a request for additional information, a further 3 working days. Any gaps in the application extend this time, so registration should not be left until December.
Does a carrier from Ukraine have to be in DIWASS?
It must be in the system if it carries waste from, to or through the EU. The Commission stresses, however, that for companies from third countries this is a technical requirement and using DIWASS themselves is voluntary. How such a company is entered into the system must be established before the first journey.
Does the driver need access to DIWASS?
The rules require the carrier to complete its part of the document and the Annex VII information to be available during transport. Who in the company does this in the system, the driver or the dispatcher, is a matter of work organisation. What matters is that these people have permissions granted by the master user.
Can any non-hazardous waste travel under Annex VII?
No. What decides is the actual composition of the waste, the Basel/OECD entry, the destination, the purpose and the facility. The six-digit EWC code alone is not enough.
Does the driver need a paper contract in the cab?
The person who arranges the shipment or the consignee provides a copy of the contract to the authorities involved in inspections at their request. The rules do not impose a general obligation on every driver to carry a full paper copy.
Does a BDO entry or a CMR replace Annex VII?
No. The Polish BDO register concerns national registration of an activity, a CMR documents carriage by road, and Annex VII is a document required for certain shipments of waste. Each has a different function.