Polski 
Deutsch 
Español 
Français 
Italiano 
Nederlands 
Čeština 
Română 
Lietuviškai 
Українська 
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.
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.
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.
New Regulation applies
DIWASS for notifications; a new Annex VII form and revised contract requirements.
Planned module launch
Announced production launch of the electronic Annex VII module.
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.
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.
DIWASS
Electronic information exchange and identification of shipment participants.
Annex VII / PIC
Determines whether general information requirements suffice or prior consent is required.
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.
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.
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.
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.
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.
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.
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.