From 1 January 2027, shipments for which Annex VII will be issued in DIWASS will generally require notification in the system two working days before the commencement of transport. However, some representatives of the transport and recycling industries believe that this deadline is not in line with market realities, where many orders are created ad hoc. Where do these objections come from and can the European Commission still change its approach?

What has already changed by 21 May 2026?

Although the most talk today is about mandatory reporting of transport via Annex VII in DIWASS from 2027, the first significant changes came into effect on 21 May 2026.

From that day, a person organising transport of waste subject to general information obligations must ensure that the waste is delivered to a recovery facility holding the required permit or registration in accordance with waste management regulations. This means that responsibility for the correct organisation of transport begins even before the preparation of transport documents.

Simultaneously, a transitional period has begun concerning the digitalisation of Annex VII. Until the end of 2026, the document can still be used primarily in paper form, as some Member States and operators are still preparing for full DIWASS system support (however, other countries, such as Germany or The Netherlands, require registration in this system).

However, this means that businesses should not leave preparations until the last minute. Registration with DIWASS and the adaptation of internal procedures are becoming increasingly important.

From 1 January 2027, Annex VII to DIWASS will need to be reported earlier.

From 1 January 2027, it ends transitional period for Annex VII. From that point onwards, information concerning transports carried out under Article 18 of the regulation will, as a general rule, be transmitted electronically via the DIWASS system.

The biggest change will be the obligation to enter data at the latest two working days before the start of transportation.

Not all information needs to be known at this stage. The regulations allow for later supplementation of, among other things:

This solution is intended to provide authorities with earlier access to information about planned transports and to facilitate inspections.

Why does the two-day rule generate so much discussion?

The obligation to digitise does not cause major controversy. On the contrary, most organisations representing the waste management sector support the development of DIWASS as a tool for increasing transparency and the effectiveness of [permit/licence] control.

Much more emotion, however, is evoked by the fact that Annex VII in DIWASS will need to be reported two working days before the commencement of transport..

In the opinion of industry representatives, such a deadline does not always correspond to the realities of organising transport.

Waste transport is very often planned on a day-to-day basis. It happens that an order only appears after a return load has been found or after the recipient has confirmed their readiness to accept the waste. In such cases, planning the entire transport with two days' notice may simply be impossible.

Another argument is the specificity of the transport itself. The route, the carrier, or even the mode of transport can change shortly before departure. This particularly applies to transport carried out near state borders and transports organised to avoid empty runs.

The industry also notes that some data – primarily the actual waste mass – is only known after loading or after weighing the waste at the facility. Although regulations allow certain information to be supplemented later, businesses point out that the very necessity of prior reporting can make transport organisation difficult.

What does the industry propose and can regulations still change?

Industry bodies stress that the problem lies solely with the requirement to report transport two working days before it commences, not with DIWASS itself.

In an open letter, the organisation EUROFER, an association representing metal processing companies, addressed to the European Union institutions, proposed, among other things:

Industry representatives also argue that the mere use of DIWASS will significantly increase the amount of information available to control bodies. In their opinion, earlier notification of transport will not bring significant control benefits, but may increase administrative burdens and hinder the smooth functioning of the market.

As of the publication date of this article, the regulations have not been changed. However, it is worth keeping an eye on subsequent European Commission communications, as the topic is the subject of active discussion between EU institutions and organisations representing businesses.