Germany tightens its approach to DIWASS. Paper Appendix VII does not exempt from registration

Many carriers considered the postponement of the digital Annex VII to mean more time for the implementation of DIWASS. Germany is now showing that such an approach can be very risky. According to the latest guidelines, a paper Annex VII does not exempt transport participants from the obligation to register in the DIWASS system.

From 21 May 2026, the DIWASS system has become the central tool for controlling the transboundary movement of waste within the European Union. Although the European Commission has allowed a transitional period for paper Annex VIIs, the German authorities have made it clear that this does not exempt them from the obligation of registration in the system.

This is important information for carriers, brokers, exporters, and recipients of waste from Poland. Particularly for companies carrying out Green List transports to Germany or through German territory. There is growing evidence that DIWASS is intended to serve not only an administrative function but also the role of a digital control system for the waste market in the EU.

Paper Annex VII yes, but registration in DIWASS still required

The most resolute stance was published by the German Federal Ministry for the Environment (BMUKN). In an official statement concerning the transitional period, the ministry indicated that the absence of sanctions until the end of 2026 solely concerns the technical impossibility of transmitting Annex VII forms via DIWASS. At the same time, the authority emphasised that all entities involved in the transboundary shipment of waste they still have an obligation to register in the system „without undue delay.” In practice, this means that the transition period does not cover the requirement to have an active DIWASS account itself.

This could be of crucial importance during traffic checks in Germany. The BALM authorities (formerly BAG) have received a clear signal that the paper Annex VII alone does not yet conclusively determine the legality of the transport. If the carrier or another participant in the transport is not listed in DIWASS as an active operator, the inspection authority may consider that the entity does not meet the requirements of Regulation (EU) 2024/1157.

Crucially, the EU regulation itself does not provide for a transitional period for the obligation to register entities. The deferral concerns only the method of submitting Annex VII documents.

DIWASS as a tool for sealing the waste market

In recent months, the European Commission has increasingly emphasised that DIWASS is not intended to be a mere administrative platform. The system is to provide Member State authorities with real-time access to data on waste movements across the EU. According to figures cited during the work on implementing the new regulations, approximately 26 million tonnes of waste are moved annually under the PIC notification procedure. In turn, the Green List procedure involves the trade of up to around 50 million tonnes of waste per year.

The European Commission is currently placing particular emphasis on plastic waste. New regulations aim to limit the illegal export of plastic outside OECD countries. Therefore, DIWASS has been designed as a system to enable rapid information exchange between environmental authorities, border services, and inspection bodies of the Member States.

The European Commission and industry organisations openly indicate that digitalisation will increase market transparency and enable immediate verification of transport data. In practice, this means an end to operating solely based on paper documentation and emails.

The industry has been given a few more months' grace. However, inspections are already changing.

The European Commission she agreed to keep the paper Annex VII until the end of 2026. This is primarily because many Member States and industry organisations have flagged technical problems and the risk of a waste market paralysis after 21 May 2026. However, this does not mean that supervisory authorities will ignore DIWASS. On the contrary, all indications are that the system is already becoming a fundamental tool for assessing the legality of market participants.

Therefore, companies carrying out waste transportations under Annex VII procedure should not defer registration until the last moment. This applies not only to consignors and consignees of waste, but also to carriers appearing on transport documents. In practice, 2026 will be a transitional period solely for the circulation of documents. However, the obligation to be present in the DIWASS digital ecosystem is already becoming a real element of controlling transboundary waste movements in the EU.