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Permitra • The Netherlands • VIHB / NIWO • 2026–2027
Waste Transport Permit in the Netherlands – the VIHB List, NIWO and ILT Inspections
Are you moving waste to the Netherlands, from the Netherlands or across Dutch territory? We explain what the Dutch VIHB list is, who it covers, whether it applies to carriers from Poland and other EU countries, and how it fits together with Annex VII and DIWASS.
- Wet milieubeheer, Art. 10.55
- Regulation (EU) 2024/1157
- Legal position as of 10 November 2026
The short answer
Yes – a foreign waste carrier needs to be entered on the Dutch VIHB list
The Dutch Environmental Management Act (Wet milieubeheer) prohibits the commercial transport of waste other than household waste, including hazardous waste, unless the carrier is entered on the list of carriers, collectors, dealers and brokers, the VIHB list. The list is kept by NIWO.
The inspectorate ILT states expressly that the obligation also applies to a foreign carrier and to every transport on Dutch territory. A Polish BDO entry or a DIWASS account does not replace this entry.
Before accepting a job
Three separate questions
- Company: does it have an active VIHB entry with the letter V?
- Waste: Annex VII or notification?
- Systems: DIWASS, and from 2027 for Annex VII as well.
What the VIHB list is and who keeps it
VIHB stands for four Dutch words: vervoerders, inzamelaars, handelaars, bemiddelaars. The list therefore covers carriers, collectors, dealers and brokers in waste. A company is entered for one or several of these activities, which is visible in the entry number: six digits and four letters, where “X” means the activity is not covered (for example 512345 VXXX is transport only).
Wet milieubeheer
Art. 10.55: transport, trading and brokering are prohibited without an entry. Art. 10.45: collection is prohibited without an entry.
BIA and RIA
The Waste Collection Decree (BIA) and the ministerial regulation (RIA) lay down the criteria for entry and the obligations to be met in the vehicle.
NIWO
Nationale en Internationale Wegvervoer Organisatie, designated by the Minister of Infrastructure and Water Management.
An entry on the VIHB list is the Dutch counterpart of a national waste carrier registration, such as the BDO entry in Poland in the relevant scope, or the notification or permit under §53/§54 KrWG in Germany. Each of these authorisations operates on the territory of its own state.
Who needs to be entered
The prohibition in Art. 10.55 of the Wet milieubeheer covers transport “for others, for remuneration” of the waste that Dutch law calls bedrijfsafvalstoffen (waste other than household waste and other than hazardous waste) and gevaarlijke afvalstoffen (hazardous waste). In practice this concerns almost every job a transport company receives.
| Situation | Is a VIHB entry needed? | Basis |
|---|---|---|
| Non-hazardous waste, commercial transport | Yes (letter V) | Wm Art. 10.55(1)(a) |
| Hazardous waste, commercial transport | Yes – the VIHB list also covers hazardous waste | Wm Art. 10.55(1)(a) |
| Carrier from another EU country | Yes, in the same way as a Dutch company | NIWO; ILT – inspection guidance |
| Transit through the Netherlands | According to ILT, yes – the obligation applies to transport on Dutch territory; the Act provides no exception for transit | Wm Art. 10.55; ILT |
| Freight forwarding that merely commissions another carrier | According to NIWO, not as a broker (B); the entry is needed by the carrier performing the transport | NIWO – explanatory notes |
| Trading and brokering in waste | Yes (letters H, B) | Wm Art. 10.55(1)(b) and (c) |
| Collection of waste from producers in the Netherlands | Yes (letter I); an I entry also covers transport | Wm Art. 10.45 and 10.55(2) |
Collecting waste oils, ship waste and small quantities of hazardous waste (up to 200 kg or 200 l per hand-over) additionally requires a permit from the minister (inzamelvergunning). A VIHB entry does not replace it (Wm Art. 10.45(1)(b), BIA Art. 9).
What follows from a VIHB entry
The entry is not a one-off formality. It brings obligations that are checked during a vehicle inspection and at the company’s premises.
Indefinite, with a review
The entry has no end date. At least once every 5 years NIWO checks whether the company still meets the criteria (RIA Art. 5(5)).
Reliability, sometimes competence
A carrier must demonstrate the reliability of the persons managing it.
A copy of the NIWO certificate
The driver must carry an authenticated copy of the certificate. NIWO issues copies marked “KOPIE” for vehicles; self-made copies are not accepted (BIA Art. 6 in conjunction with RIA Art. 2).
Transport data for 5 years
The carrier records from whom it collected the waste and to whom it handed it over, its name and quantity, and keeps the data for at least 5 years (Wm Art. 10.55(5)–(6)).
The paper certificate is valid only if the company appears on the public, electronic VIHB list. An entry lapses, among other things, at the company’s request, in the case of false data and after the final withdrawal of the Community licence on the basis of which it was made (RIA Art. 6).
Cross-border shipments: Annex VII, notification and DIWASS
The VIHB entry determines whether a company may transport waste in the Netherlands. Which document must accompany a particular shipment follows from Regulation (EU) 2024/1157, applicable from 21 May 2026. In the Netherlands it is known as EVOA, and ILT is responsible for supervision.
- 21 May 2026
New regulation
Notifications in DIWASS; a new Annex VII form and new contract requirements.
- until 31 Dec 2026
Paper Annex VII
ILT allows a paper Annex VII, but only on the new template.
- 1 Jan 2027
Annex VII in DIWASS
Submission 2 working days before the transport; the carrier must have a DIWASS account.
Dates according to ILT (the postponement of the Annex VII obligation in DIWASS to 1 January 2027 was agreed on 27 March 2026).
The green list for recovery is, as a rule, subject to the information procedure under Art. 18 and the Annex VII document. Hazardous waste, mixtures and waste for disposal require notification and the consent of the competent authorities. Where the Netherlands is only a country of transit in a notification, ILT gives tacit consent 30 days after the authority of destination has acknowledged the notification.
From 1 January 2027 the organiser of the shipment selects the carrier from DIWASS in the Annex VII notification. A company without an active account will not be named in the document, even if it holds a valid VIHB entry. The reverse also applies: a DIWASS account does not replace a VIHB entry.
Inspections, typical problems and sanctions
ILT inspects waste transport on roads, waterways and railways, as well as at companies, selecting them on the basis of risk. It works with the police, the customs service, NVWA, the Koninklijke Marechaussee and the regional environmental services. Inspectors may stop a vehicle and direct it to a designated place, examine the load, take samples and demand documents. The person inspected has a duty to cooperate.
No VIHB entry
The company has BDO and a Community licence but is not on the VIHB list.
Consequence: transport in breach of Art. 10.55 Wm, which is an economic offence.
The wrong copy of the certificate
The cab contains a scan, a photocopy or a laminated document instead of the “KOPIE” copy issued by NIWO.
Consequence: a required document is missing in the vehicle.
The entry lapsed unnoticed
A change of company, a withdrawn Community licence or outdated data after a NIWO review.
Consequence: the certificate in the cab does not confirm the authorisation, because the electronic list is decisive.
The document does not match the load
An old Annex VII template, no carrier signature or a load that differs from the waste description.
Consequence: detention until the matter is clarified; the remedy may be to return the waste.
Sanctions under Dutch law
A breach of Art. 10.55 of the Wet milieubeheer is an economic offence within the meaning of the Economic Offences Act (WED, Art. 1a). An intentional act is punishable by up to 2 years’ imprisonment, community service or a fourth-category fine, which from 1 January 2026 is up to €27,500. A non-intentional act is a minor offence: detention of up to 6 months, community service or the same fine. In the case of a company, the court may impose a fine of a higher category (up to €110,000), as well as additional penalties, for example the partial or complete suspension of the business for up to a year.
Independently of this, ILT applies administrative measures: a warning, an order subject to enforcement by substitute performance (last onder bestuursdwang) or subject to a penalty payment (last onder dwangsom). Illegal shipment of waste, irrespective of the lack of an entry, is subject to more severe penalties (WED Art. 1a(1)°).
Disputed points and questions to settle for a particular company
- Transporting one’s own waste in one’s own vehicles. The Act covers transport “for others, for remuneration”. A producer carrying its own waste does not fall within the literal wording of the provision, but ILT guidance refers generally to a “carrier”. It is worth settling this before the first journey.
- Transit without loading or unloading. The Act contains no exception, and ILT points to the obligation for every transport on Dutch territory. We have not found case law that would call this into question.
- Cabotage and domestic transport in the Netherlands. Where an entity in the Netherlands hands waste to a recipient in the Netherlands, the carrier receives a Dutch waste consignment note (begeleidingsbrief, Wm Art. 10.39). The documents under Regulation 2024/1157 concern shipments between states.
- The scope of the letters in the entry. A company that, besides transport, buys and sells waste or organises its collection from producers needs an entry covering those activities (H, B, I), not only V.
- The transition to the new regulation in Dutch law. The Wet milieubeheer in the version of 22 October 2026 still refers to Regulation 1013/2006. The references are read as references to 2024/1157 (Art. 85(8)), and the adaptation of the Act is going through the legislative process.
More on how national authorisations fit together on a route through several states: Waste transport across Europe in 2026–2027.
Frequently asked questions
Is a Polish BDO entry enough to transport waste in the Netherlands?
No. BDO relates to activity in Poland. The Dutch Act requires an entry on the VIHB list, and ILT states that this also applies to foreign carriers. A Polish BDO entry does not replace a VIHB entry.
Does a VIHB entry cover hazardous waste?
Yes. The VIHB list concerns both hazardous and non-hazardous waste (other than household waste). The transport of hazardous waste must in addition meet separate rules, including the notification procedure for shipments between states.
Is an entry also needed for transit through the Netherlands?
According to ILT, yes: a carrier moving waste across Dutch territory must be on the VIHB list and show a copy of the certificate. The Act contains no exception for transit.
How long is a VIHB entry valid?
Indefinitely, as long as the company meets the criteria. NIWO checks this at least once every 5 years, and an entry lapses, among other things, after the withdrawal of the Community licence on the basis of which it was made.
Does a DIWASS account replace a VIHB entry?
No. DIWASS is used to exchange shipment documents (notifications and, from 1 January 2027, Annex VII as well). A VIHB entry is the national authorisation to transport waste in the Netherlands. Both are needed.
What penalties apply to transport without an entry?
It is an economic offence: for an intentional act, up to 2 years’ imprisonment or a fourth-category fine (up to €27,500 from 2026), with a higher category possible for a company. ILT may also apply administrative measures, including orders subject to a penalty payment.