DIWASS after 21 May 2026 — what does a waste carrier need to know?

From 21 May 2026, DIWASS changes the way documentation is handled for international waste shipments in the European Union. Check what a carrier must have, when Annex VII is sufficient, and which documents should be prepared for roadside inspections.

This article concerns transboundary shipments of waste covered by Regulation (EU) 2024/1157, in particular shipments involving EU Member States. It does not describe local national procedures for domestic waste transport within a single country.

In theory, DIWASS is intended to provide electronic handling of documents, notifications and annexes. In practice — according to our current understanding — the system is not yet fully ready for normal operation in all cases, especially for shipments under Annex VII. For this reason, the most important point at present is that the companies involved in the shipment should have an active DIWASS account with the status “VALID”.

TL;DR

DIWASS from 21 May 2026 — what has changed for carriers?

The most important change is that, for international waste shipments, having only a paper document in the vehicle cab is no longer sufficient as a general rule.

From 21 May 2026, participants in waste shipments should be registered in DIWASS. The European Commission indicates that DIWASS does not allow operator data to be entered manually when creating a document — the company must be registered in advance, otherwise it will not appear in the system’s selection list. Source

This applies in particular to entities such as:

• the person who arranges the shipment,
• the waste producer,
• the carrier,
• the consignee / importer,
• the facility, meaning the recovery or disposal facility.

Registration in DIWASS is a technical condition that allows a company to be selected in documents relating to a waste shipment. However, registration itself does not mean that the company automatically holds the required permits for waste transport or waste treatment. Source

Transitional period until 31 December 2026

For shipments under Annex VII, mainly green-listed waste intended for recovery, there is a transitional period from 21 May to 31 December 2026.

During this period, Annex VII may still be handled mainly in paper form. The European Commission indicates that, due to technical problems with the full operation of the system, Annex VII documents are to be handled during this period as before, primarily on paper.

Very important: the German Federal Ministry for the Environment, BMUKN, has indicated that during the transitional period sanctions should not be imposed if Annex VII documents and other required documents are prepared in paper form and accompany the transport, where it is not possible to prepare them electronically. At the same time, the ministry stressed that all participants in waste shipments must still register in DIWASS without delay. Source

This means in practice:

until 31 December 2026, paper Annex VII may still be used, but the companies involved in the shipment should have a valid DIWASS account.

New Annex VII form 2026 — what must the document contain?

From 21 May 2026, the new Annex VII form resulting from Regulation (EU) 2024/1157 should be used. BMUKN confirms that even when documentation is prepared on paper, the new Annex VII form from Regulation 2024/1157 must be used.

The new form includes, among other things:

• details of the person who arranges the shipment,
• details of the importer / consignee,
• the actual quantity of waste,
• the actual date of shipment,
• carrier details,
• details of the waste producer,
• the place where the shipment starts,
• details of the recovery facility or laboratory,
• the waste code,
• countries of dispatch, transit and destination,
• signatures and confirmations of receipt and recovery of the waste.

Practical tip: the driver should not depart with the waste if Annex VII is old, incomplete, does not contain the carrier’s details, does not include the waste code, or does not clearly identify the consignee and the facility.

Should the driver carry the contract?

Yes — as a practical recommendation, the driver should carry a copy of the contract between the parties, especially for shipments under Annex VII.

The rules and document templates indicate that, for shipments under Annex VII, a written contract must exist. The new Annex VII contains a declaration that a valid written contract has been concluded with the consignee and — where applicable — with the operator of the facility.

The attached Annex VII contract template also refers to the obligation to provide a copy of the contract at the request of the competent authorities. This applies both to the person who arranges the shipment and to the consignee.

Our recommendation is therefore simple:

the driver should have a copy of the contract in the vehicle, or at least be able to present it immediately during an inspection.

Ideally, the driver should receive a complete set of documents:

• the new Annex VII,
• CMR,
• a copy of the Annex VII contract,
• commercial documents, if required,
• confirmation that the carrier holds the required national waste transport permits,
• contact instructions in case of inspection.

What should the carrier check before loading?

Before accepting a waste shipment, the carrier should check several points.

1. Do all companies have a DIWASS account?

During the transitional period, the most important point is that the participants in the shipment have an active DIWASS account with the status “VALID”.

This applies in particular to:

• the loader / person arranging the shipment,
• the consignee,
• the facility,
• the carrier.

If a business partner does not have a DIWASS account, the shipment may become problematic, because that company will not be available for selection in the system when the documentation is prepared electronically. The European Commission indicates that lack of operator registration prevents the operator from being selected in DIWASS documents.

2. Is the new Annex VII being used?

From 21 May 2026, the new Annex VII form should be used — PDF available for download.

An old “Annex VII” that a client has had saved for years is not sufficient. It is worth checking the layout of the form and the legal basis.

3. Is there an Annex VII contract?

For shipments under Annex VII, a written contract must exist between the relevant parties. Most often, this will be a contract between the person who arranges the shipment and the consignee, and in practice also with the facility if it is a separate entity.

Annex VII Contract ENG — template available for download.

4. Are the data in the documents consistent?

The most common problems during inspections do not result from the absence of a document, but from discrepancies.

Check whether the following match:

• waste code,
• waste description,
• weight,
• place of loading,
• place of unloading,
• consignee details,
• facility details,
• carrier details,
• countries of transit,
• vehicle registration numbers, if entered,
• CMR and Annex VII.

If Annex VII says one thing and the CMR says another, the transport is risky.

What if the business partner does not have a DIWASS account?

First, you need to determine whether the shipment is carried out under:

• Annex VII, meaning green-listed waste,
• or the notification procedure, meaning prior notification and consent from the authorities.

If it is an Annex VII shipment, during the transitional period until 31 December 2026 the paper document may still be used, but the business partner should register in DIWASS as soon as possible.

If the shipment requires notification, the situation is more serious. For the notification procedure, the obligation to use DIWASS applies from 21 May 2026, and the transitional period for paper Annex VII does not apply to such shipments.

In practice, it is worth sending the client a short message:

Please confirm whether your company has an active DIWASS account with the status “VALID”. Please also send us the new Annex VII, a copy of the Annex VII contract and confirmation that all data in the documents are consistent with the actual shipment.

Waste transport inspection — when can the carrier have a problem?

The carrier may have a problem if:

• the new Annex VII is not available in the vehicle,
• Annex VII is prepared on the old form,
• the contract is missing or cannot be presented quickly,
• the carrier is not indicated in the documents,
• the data in the CMR and Annex VII differ,
• the waste code is incorrect,
• the consignee or facility does not match the documents,
• the companies involved in the shipment do not have a valid DIWASS account,
• the shipment requires notification but there is no approval in DIWASS,
• the carrier does not hold the required national waste transport permits.

DIWASS does not replace national permits. If a given country requires the waste carrier to be registered or authorised, a DIWASS account alone is not sufficient.

The most important rules for the carrier

For now, the safest approach is to apply a simple procedure:

• Check whether the goods are waste.
• Determine whether the shipment is under Annex VII or requires notification.
• Check whether all parties have a valid DIWASS account.
• Use the new Annex VII form from 21 May 2026.
• Give the driver a copy of Annex VII, CMR and the contract.
• Check data consistency before loading.
• Do not treat a DIWASS account as a substitute for national permits.

Summary

DIWASS was intended to introduce full digitalisation of waste shipments in the EU from 21 May 2026. In practice, the system is still being implemented, and for Annex VII shipments there is a transitional period until 31 December 2026.

This does not mean that the new obligations can be ignored.

At present, the most important points for the carrier are:

a valid DIWASS account, the new Annex VII form, a copy of the contract, consistent data and a complete set of documents in the vehicle cab.

If any of these elements is missing, the shipment may be challenged during an inspection. In waste transport, it is better to stop the issue before loading than to explain it later on the road.

Legal and jurisdictional disclaimer: This article concerns transboundary waste shipments covered by EU rules. It does not replace a case-by-case legal analysis. National registration, permit and control requirements may still apply in the countries of dispatch, transit and destination.