Annex VII in DIWASS – digital completion obligation postponed to January 2027

Annex VII in DIWASS – why will we stick with the paper version for now?

The source of information regarding the „postponement” of the obligation for digital completion of Annex VII is primarily the findings from the Expert Group on Waste Shipments meeting on 27 March 2026. Its The summary was later published by industry organisations. and entities participating in consultations regarding the implementation of DIWASS. The European Commission had indicated several reasons for the necessity of introducing a transitional period. Among them were, inter alia:

Does the change relate only to Annex VII matters?

It was emphasised that the shift relates solely to digital conduct Annex VII. The same notification procedures will still need to be carried out from 21 May 2026 via the DIWASS system. The obligation for digital handling of notifications stems directly from Regulation (EU) 2024/1157 and the implementing provisions regarding the functioning of the DIWASS system.

In practice, this means that entrepreneurs can expect a transitional period during which:

• notifications will be processed digitally within DIWASS.,
• whereas Annex VII documents will continue to be able to function in paper form

Not all countries will accept paper Annex VII

However, simply shifting the responsibility does not mean that all countries will approach the matter in the same way. Companies and waste recipients from Germany and the Netherlands are already signalling that they will continue to require additional completion or registration of documents within the DIWASS system as well. Many large entities are already implementing their own integrations with the new digital system. They want to maintain a uniform document flow regardless of the transition period.

It's also worth remembering that the DIWASS registration process itself can prove more complex than many entrepreneurs initially assume. This also applies to subsequent system support. Problems with EU Login configuration, assigning appropriate roles, or verifying company data are already causing numerous delays. Difficulties also arise when integrating identification numbers and communicating with the relevant authorities in individual EU countries.

This is why more and more companies are deciding Entrust DIWASS registration to experienced operators or entities specialising in the cross-border movement of waste. This not only saves time but also reduces the risk of errors, rejected applications, or stressful situations related to the timely execution of international transport. This will be particularly important in the first few months of the system's operation. It is then that the administrations of Member States and businesses will be developing practical procedures for operating in the new digital environment.

Consequences of not registering with DIWASS

It is worth noting that despite the postponement of the digital obligation for maintaining Annex VII, many freight forwarders, foreign contractors, and waste producers may still require company registration in the DIWASS system as a condition for further cooperation. This is primarily due to internal compliance procedures and the need to minimise legal and organisational risks in the international supply chain. For many entities, the mere presence of a company in DIWASS will confirm that the entrepreneur is preparing for new EU obligations and will be able to carry out transports in accordance with future digital requirements. In practice, a lack of registration may lead to the suspension of new orders, the termination of existing cooperation, or the inability to continue carrying out transports until active registration in the DIWASS system is obtained.