Ensuring a smooth implementation of new EU waste shipment rules
Dear Commissioner Roswall,
The new Waste Shipment Regulation entered into force on 20 May 2024, with most of its provisions—including critical operational requirements—set to apply from 21 May 2026. Among these are the mandatory electronic submission and exchange of information and documents, as well as the obligation to complete the Annex VII form at least two working days before the start of the shipment.
After the entry into force of the new waste shipment rules, the Clean Industrial Deal has materialised the EU’s ambition to be the global leader in the circular economy by 2030, while the Commission has set a course to simplify rules to make the EU’s economy more competitive and prosperous. We thus remind that waste shipments are a cornerstone of the EU’s circular economy but also a significant source of administrative burden.
As the imminent application of these new rules approaches, certain aspects—particularly those related to electronic procedures and Annex VII documentation—remain a persistent source of concern for European value chains. To mitigate potential disruptions, we, the undersigned European industry stakeholders, representatives of key European value chains, respectfully urge the Commission to ensure a smooth and efficient implementation of the Regulation, especially for intra-EU waste shipments.
In particular, we have two key requests to facilitate this transition:
- A transition/adaptation period for the implementation of the Digital Waste Shipment System (DIWASS)
European industry strongly supports the digitalisation of procedures as a means to enhance efficiency and traceability. However, the introduction of the Digital Waste Shipment System (DIWASS) presents significant operational and technical challenges, as demonstrated by the experiences of Member States in implementing similar digital systems.
While fully supporting the importance of the timely implementation of DIWASS as a key tool for harmonisation and transparency, we respectfully urge the European Commission to lead the establishment a transition/adaptation period of at least one year for the EU-wide implementation of DIWASS. This period would allow authorities and businesses to adapt to the new system without facing penalties for non-compliance during that initial phase.
Enforcing digital submission requirements from 21 May 2026 —particularly for Annex VII forms—could disproportionately impact businesses and authorities still adapting to the new system. This is especially true for smaller operators with limited resources and those operating across multiple jurisdictions, where compliance complexity is heightened by varying national approaches.
EU countries have already granted similar transition periods for their own digital systems to ensure smooth adoption and minimise disruptions. This approach aligns with the Commission’s goal of fostering a seamless digital transition while upholding environmental and administrative objectives.
While the Commission’s influence over Member States’ enforcement decisions is limited, we encourage the Commission to lead and coordinate a harmonised approach among Member States. The Waste Shipment Regulation already provides a possible legal basis for such a transition in Article 16(4), which allows for alternative means of document availability when digital systems are inaccessible. The Commission should encourage a common understanding among EU Member States that the year after the mandatory implementation of DIWASS entails a situation in line with Article 16(4), extending the same possibility to Annex VII shipments.
When Regulation (EU) 2024/1157 was adopted, a 24-month implementation period was foreseen to allow authorities and operators to adapt to the new digital system. In practice, however, preparation has been delayed: the DIWASS implementing rules were only adopted in July 2025, key technical documentation for system integration was only published at the end of January 2026, the user interface is not yet operational, and pre-registration of the thousands of affected operators has not begun. As a result, operators are left with only a few months to adapt to a complex new system, making a transitional period essential. In addition, automated interconnections between company IT systems and DIWASS (or equivalent national tools) are needed to reduce transition costs, avoid duplicate data entry, and ensure that digitalisation delivers real operational added value.
Specifically, we propose that during a transition period of one year, operators unable to fully comply with DIWASS (e.g., due to technical limitations or where relevant operators in the shipment chain are not yet registered in the system) should be permitted to submit and make available required documents in the transport vehicle via alternative means (e.g., having a physical Annex VII document available in the transport vehicle or submitting it via post, fax, or email, with or without digital signatures in line with Article 72), without facing penalties. In such cases, the notifier or person who arranges the shipment should ensure that the information and documents are submitted via DIWASS, but full coverage cannot be expected as the system may not be available to all operators. Ensuring a common understanding and harmonised application of such transition period is essential to maintain a level playing field across the EU.
Finally, as the new Annex VII (from 21 May 2026) requires more signatures and is clearly designed for digital purposes, using it in paper format would be impractical. We therefore suggest continuing using the current Annex VII for paper procedures and reserve the new form for DIWASS.
- The repeal of the requirement to submit Annex VII two days in advance
The new Waste Shipment Regulation (WSR) aims to strengthen enforcement and prevent illegal waste shipments, a goal the industry fully supports. However, the requirement to submit the Annex VII form two working days before shipment (Article 18 WSR) imposes a disproportionate logistical constraints and administrative burden on operators, conflicting with the EU’s broader objectives of efficient intra-EU shipments and circular economy development.
This requirement is unrealistic and impractical, particularly for green-listed intra-EU waste shipments, where logistics are often planned hours in advance to meet customer demands or optimize transport efficiency. In other cases, planning in advance may simply not be always possible, as is the case for shipments via barges. The issue is especially acute in border regions, where spontaneous shipments are common to avoid empty return trips. Moreover, this provision impedes immediate take-back when shipments are refused by a receiving facility because Article 23(3) WSR refers to the procedure in Article 18.
Contrary to the Commission’s objectives, this measure undermines the competitiveness of circular products compared to virgin materials, which are not subject to similar administrative burdens. It also disrupts basic waste management services to businesses. As an example, printing companies generate trim waste that is collected on demand—often within hours—when onsite containers reach capacity. Planning such collections two days in advance is operationally unfeasible and would force printing businesses to either increase onsite waste storage capacity at significant cost, or anticipate orders and the waste generation linked to those, neither of which is practical nor efficient while hampering the European economy and value chains.
Under such conditions, two likely outcomes emerge—both of which fail to deliver any environmental benefit. On the one hand, businesses may be compelled to switch to national waste management providers, even if cross-border partners offer better value in terms of cost, quality, recycling efficiency or proximity. This undermines the principles of the EU single market and the economies of scale that are essential for a thriving circular economy. On the other hand, operators could resort to a systematic prefill of Annex VII forms based on estimates, which then may or may not be used. This is possible as the quantity of the waste, the carrier and the container identification number can still be submitted before the start of the shipment. However, this not only represents unnecessary administrative burden but brings no added value to controls as those prefilled forms will not always reflect real shipments.
As a matter of fact, registering data online in DIWASS will already exponentially increase the information available for control authorities. Digital tracking via DIWASS provides authorities with real-time data on shipments, enabling better-targeted controls based on patterns and actual movements. We therefore call on EU legislators to repeal the requirement to submit Annex VII two days in advance for intra-EU shipments. Furthermore, Article 18(5) WSR must be amended to reflect operational realities by allowing estimated quantities in Annex VII forms before departure. Actual quantities can only be confirmed upon arrival at the weighbridge of the receiving facility. These changes would reduce unnecessary burdens, support the circular economy, enhance legal certainty and maintain the competitiveness of EU businesses—all while still ensuring effective enforcement against illegal shipments. Finally, overly rigid procedures could create economic risks for recycling markets, potentially discouraging investment and undermining collection and sorting activities essential to the circular economy.
On behalf of the undersigning associations, we thank you for your time and consideration of our requests. We sincerely appreciate your attention to these matters and would be grateful for any updates or feedback at your earliest convenience.
Please do not hesitate to contact us if further information is required. We look forward to your positive response.
Yours sincerely,
| Paolo Campanella Secretary General of FEAD | René Schroeder Secretary General of Ferver | Bertrand Cazes Secretary General of Glass for Europe | |
| Cédric Janssens Secretary General of Glass Fibre Europe | Anna-Maria Karjalainen Head of EU Regulatory Affairs and Deputy Director-General of ICA EU | Virginia Janssens Managing Director Plastics Europe | |
| Julia Ettinger Secretary General of Recycling Europe | Charlotte Röber Managing Director of VinylPlus | ||
