Digital Annex VII. Download the current document template
Many entrepreneurs mistakenly assume that postponing the mandatory use of the DIWASS system means no changes to transport documentation, or no registration on the platform at all. However, registration is required regardless. Furthermore, the Annex VII template applicable from 21 May 2026 differs from the document used under previous regulations. Companies can still use paper documentation, but must use current forms and comply with the requirements of Regulation (EU) 2024/1157. The absence of the correct documents during inspections can lead to problems, despite the current transitional period.
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Justyna Blazewicz-Seredyn
Ewelina Nadolna
The paper Annex VII is still admissible
The Chief Inspectorate of Environmental Protection (GIOŚ) reminds businesses that they can voluntarily submit information on Green List waste shipments via the DIWASS system until 31 December 2026. This means they can continue to carry out transport based on paper documentation.
Inspection services cannot deem transport illegal solely because an entrepreneur has not entered data into the DIWASS system. However, it is worth remembering that regulations are not the only factor influencing business cooperation. An increasing number of market participants view registration in DIWASS as an element of building transparency and credibility in the supply chain.
For some waste producers, brokers, and recipients, the presence of a counterparty in the system may represent additional confirmation of their commitment to complying with the new EU requirements.
The lack of registration does not constitute a breach of law today, however, in practice, it may raise additional questions from potential clients or business partners. This particularly applies to Enterprises that have already implemented DIWASS they expect a similar approach from their carriers and subcontractors.
The new template for Appendix VII is mandatory.
However, the ability to use paper documents does not mean that existing forms can be used. From 21 May 2026, businesses must use the new Annex VII template, which refers to Regulation (EU) 2024/1157.
During a road inspection, the inspector will not only check for the presence of the document but also its compliance with current regulations. In practice, this means that possessing an old form may prove insufficient, even if the transport has not been reported in DIWASS.
The document itself is not enough
GIOŚ draws attention to another mandatory element of documentation. If the entrepreneur does not use DIWASS, they should have an agreement that meets the requirements of Article 18 of Regulation (EU) 2024/1157.
The driver should have both the current Annex VII and a correctly drawn-up contract in their possession. Only the combination of these two elements allows for the use of the protection provided for the transitional period.
The biggest mistake of hauliers
The biggest mistake today is the belief that deferring DIWASS allows the use of old documents. This is not the case. The transition period defers the obligation to use the DIWASS system, but it does not defer the obligation to use documentation compliant with Regulation (EU) 2024/1157.
Entrepreneurs can continue to use paper documentation, however, they must use the current template of Appendix VII and an agreement compliant with the new regulations. Therefore, it is worth verifying the documents used during the transport of waste from the Green List now.
Download the current template for Annex VII
To facilitate entrepreneurs' adaptation to the new requirements, an updated template of Annex VII, effective after 21 May 2026, has been prepared. The document takes into account the requirements arising from the latest regulations and can be used during transports carried out during the transitional period.