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Waste transport across Europe in 2026/2027 – which permits, registrations and documents are required on your route?
You have an order to transport waste from Poland to Germany, from the Czech Republic to the Netherlands or from Belgium to Italy, and one basic question arises: which permits, registrations and documents does a carrier need to carry out such a transport legally?
Since 21 May 2026 key provisions of the new Regulation (EU) 2024/1157 on shipments of waste have applied in the European Union. At the same time, the DIWASSsystem became operational, and from 2027 the handling of shipments under Annex VII will also change.
The main difficulty is that there is no single European waste transport permit. In addition to the procedure governing the shipment itself, the requirements of every country on the route must be checked.
There is no single “European waste transport permit”
This is a basic rule every carrier should understand before starting international waste transport.
EU rules primarily govern the transboundary shipment of specific consignments of waste. At the same time, individual countries have their own systems for companies engaged in waste transport.
In practice, a compliant transport should be analysed on three levels:
1
what exactly are you transporting, and is the shipment subject to Annex VII or to prior written notification and consent (PIC/notification)?
2
does the company hold the required registrations or permits in the country of loading, transit and unloading?
3
are the documents, DIWASS data, route, facility and actual shipment details consistent with the applicable procedure?
Two trucks may carry the same type of waste under the same transboundary procedure, yet only one of the carriers may hold the full set of required national registrations.
Step 1. First determine what waste will actually be transported
Before checking BDO, §53, VIHB or other permits, the waste must first be classified correctly.
One common mistake is to assume:
“The customer provided EWC code 15 01 02, so we already know the waste is on the green list.”
Not necessarily.
The EWC/LoW code and the classification used for transboundary waste shipments are related, but not identical classification systems.
Depending on the case, a proper assessment may require:
- ✓ EWC / LoW code
- ✓ Basel / OECD code
- ✓ precise description of the waste
- ✓ material composition
- ✓ level and type of contamination
- ✓ hazardous properties
- ✓ destination and method of treatment
- ✓ recovery or disposal operation
That is why the question “can waste code 15 01 02 be shipped under Annex VII?” may require additional information about the specific material.
Step 2. Annex VII or notification?
Once the waste has been classified correctly, the procedure applicable to its transboundary shipment must be determined.
| Procedure | Typical situation | Documentation |
|---|---|---|
| Art. 18 / Annex VII | Certain wastes destined for recovery, including waste listed in Annexes III, IIIA and IIIB | Annex VII + required contract + electronic data in accordance with DIWASS rules |
| PIC / notification | Including certain hazardous wastes, waste listed in Annex IV and other shipments requiring consent | Notification document, movement document, consents, contract, financial guarantee and supporting documentation |
When is Annex VII used?
Under Article 4(4) of Regulation (EU) 2024/1157, the general information requirements in Article 18 apply to certain shipments of waste destined for recovery where the quantity exceeds 20 kg.
This applies in particular to waste listed in Annexes III and IIIB and to certain mixtures listed in Annex IIIA.
When is notification required?
The prior written notification and consent procedure is much more extensive. It may apply, among other things, to certain:
- hazardous wastes,
- waste listed in Annex IV,
- waste that cannot be properly classified under a single entry,
- mixtures of waste,
- waste requiring particular control because of its composition or contamination,
- shipments subject to specific rules on recovery or disposal.
In such cases, Annex VII does not replace notification.
DIWASS – why must 2026 and 2027 be treated differently?
DIWASS – Digital Waste Shipment System – is a central element of the digitalisation of transboundary waste shipments in the European Union.
Since 21 May 2026 DIWASS is used for prior written notification and consent procedures.
21.05–31.12.2026
A transitional period applies to Annex VII. The document may be prepared outside DIWASS and accompany the transport in paper form, but the new Annex VII form and a contract compliant with Article 18 of Regulation 2024/1157 must already be used.
From 01.01.2027
Shipments covered by Article 18 are to be handled electronically through DIWASS or systems connected to DIWASS. Organising transports will require information to be exchanged between the parties in advance.
What does this mean for the carrier?
Companies carrying out regular waste transports should not treat DIWASS as just another form.
The system requires the participants in the shipment to be identified correctly, so the following data will become even more important:
- data of the person arranging the shipment,
- data of the waste producer,
- carrier details,
- consignee details,
- recovery facility details,
- waste classification,
- route and planned shipment date.
Step 3. Check every country on the route – not only loading and unloading
One of the most common mistakes is to analyse only the country of loading and the country of destination.
If the transport route is:
German carrier requirements must also be checked.
Importantly, there is no single European rule for transit. Merely passing through a country may trigger a registration requirement in one state, while the rules may be different in another.
Poland – BDO
Professional transport of waste within Poland generally requires the appropriate entry in the BDO Register.
Of particular importance to foreign carriers, the official BDO position states that the obligation also applies to companies carrying out waste transit through Poland, even if both the starting point and destination of the transport are outside Poland.
For a foreign company without a branch in Poland, the registration procedure differs from the standard procedure for a Polish company.
Germany – §53 and §54 KrWG
In Germany, the type of waste transported and the nature of the activity are decisive.
For the collection and transport of waste, a notification of activity may be required under §53 Kreislaufwirtschaftsgesetz (KrWG).
For hazardous waste, however, it is necessary to check whether a permit is required under §54 KrWG.
These are two different procedures. A document suitable for standard waste should not automatically be treated as authorisation to transport hazardous waste.
Netherlands – VIHB
Companies professionally transporting waste within the Netherlands should check whether they must be entered in the VIHB register maintained by NIWO.
The obligation is not limited to Dutch companies. NIWO also sets out requirements for foreign companies carrying out professional waste transport in the Netherlands.
Italy – ALBO, category 6
Companies carrying out transboundary waste transport in Italy are subject to the Italian Albo Nazionale Gestori Ambientali.
For companies carrying out exclusively transboundary waste transport, the key category is category 6.
Belgium – one country, several systems
Belgium is a good example of why naming the country alone is not always enough.
- Flanders – OVAM,
- Wallonia – SPW,
- Brussels-Capital Region – Bruxelles Environnement.
Therefore, the statement “I have a permit for Belgium” should always lead to a follow-up question: which region and which scope of activity does the document cover?
Which documents should be available during transport?
There is no single universal “driver’s document folder” suitable for every waste transport in Europe.
The required documentation depends on the waste, the applicable procedure and the countries on the route.
For an Annex VII shipment, check in particular:
- ✓ correctly completed Annex VII
- ✓ consistency of the data with the actual waste
- ✓ details of all participants
- ✓ carrier details
- ✓ evidence of required registrations
- ✓ documents required locally
Until the end of 2026, remember that using a paper Annex VII during the transitional period does not mean that the old form may still be used.
How should a specific route be checked correctly?
At Permitra, we begin the analysis by collecting information that can actually change the scope of the obligations.
For an initial review, it is useful to prepare:
1
2
3
4
5
6
7
Examples – why is the country name alone not enough?
Example 1: Poland → Germany → Netherlands
A carrier receives a regular order to transport waste from Poland to a recovery facility in the Netherlands.
The question “is BDO enough?” is too narrow.
- waste classification,
- Annex VII or notification,
- Polish BDO registration,
- German requirements,
- VIHB in the Netherlands,
- DIWASS,
- documents required during transport.
Example 2: Lithuania → Poland → Germany
In this case, Poland is only a transit country.
“We do not load or unload in Poland, so BDO does not apply to us.”
This assumption is incorrect. According to the official BDO position, a foreign carrier transporting waste through Poland is subject to the registration obligation even when both the point of origin and the destination are outside Poland.
The most common mistakes in waste transport across Europe
“I have BDO, so I can transport waste throughout the EU.”
No. BDO is a Polish registration system. Other countries may impose their own requirements on waste carriers.
“I have Annex VII, so I do not need any other permits.”
Not always. Annex VII concerns a specific transboundary shipment procedure and does not automatically replace national carrier registrations.
“The waste code has no asterisk, so it must be on the green list.”
No. Classification for transboundary shipment must be determined under the relevant rules and lists. The EWC code alone is not always sufficient.
“I am only passing through the country, so registration is not required.”
This rule cannot be applied across Europe. Transit obligations must be checked separately for each country.
“In 2027 I will simply print Annex VII as before.”
From 2027, shipments covered by Article 18 are to be handled electronically through DIWASS or systems connected to it.
How does Permitra help carriers with waste transport across Europe?
A carrier does not need to maintain an in-house compliance department that continuously analyses waste-management rules in a dozen or more countries.
Permitra specialises in transboundary waste transport and European registration requirements for carriers.
We can analyse the planned route, check the requirements of the individual countries and – where needed – assist with the appropriate registration procedures.
Do you have a new waste route? Check the requirements before the truck goes to its first loading.
Send us the waste code and the route, including the country of loading, unloading and all transit countries. We will identify which areas need to be verified and which registrations or permits the carrier may require.
You do not always need every possible permit. You need the ones that actually result from your route, the waste and the way the transport is carried out.
FAQ – waste transport across Europe
Does Polish BDO allow waste to be transported throughout the European Union?
No. BDO is a Polish register. In other countries, local requirements for waste carriers must be checked separately.
Does a foreign carrier need BDO if it only transits Poland?
As a rule, yes. The official BDO position states that the registration obligation also applies to foreign carriers transporting waste through Poland.
Is Annex VII a waste transport permit?
No. Annex VII is a document used under the general information requirements procedure set out in Article 18 of Regulation 2024/1157. It does not replace national carrier authorisations.
Can every non-hazardous waste be transported under Annex VII?
No. The waste classification must be checked against the relevant annexes to Regulation 2024/1157 and the other conditions of the procedure.
Will Annex VII be handled through DIWASS from 2027?
Yes. The transitional period for paper handling of Annex VII lasts until 31 December 2026. From 1 January 2027, shipments covered by Article 18 are to be handled using DIWASS.
Official sources and further reading
- Regulation (EU) 2024/1157 on shipments of waste – EUR-Lex
- GIOŚ – Annex VII and the DIWASS transitional period
- GIOŚ – shipments of “green-listed” waste
- GIOŚ – DIWASS information point
- BDO – registration obligation for carriers transporting waste through Poland
- BDO – registration of foreign businesses
- Germany – §53 Kreislaufwirtschaftsgesetz
- Germany – §54 Kreislaufwirtschaftsgesetz
- NIWO – VIHB registration for foreign waste carriers
- Albo Nazionale Gestori Ambientali – Category 6