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19.10.2026 · Regulations

DIWASS: from 1 January 2027 waste shipment documents in the electronic system only

From 1 January 2027, the Annex VII form under Regulation (EU) 2024/1157 – used, among others, for shipments of green-listed metal scrap – is prepared and exchanged exclusively in the EU DIWASS system. The module will be available from 15 November 2026.

In a letter of 29 September 2026, Poland’s Chief Inspector of Environmental Protection (GIOŚ) informed industry organisations, including the Chamber, that from 1 January 2027 the documents required under Art. 18 of Regulation (EU) 2024/1157 may be prepared and exchanged only in the DIWASS system. This concerns cross-border shipments of green-listed waste destined for recovery – including metal scrap – above 20 kg. Until the end of 2026 a transitional period applies, during which GIOŚ accepts paper documents.

Mandatory from 1 January 2027Regulation (EU) 2024/1157, Art. 18DIWASS module from 15.11.2026

2working days before the shipment starts – the latest point at which the person arranging the shipment completes the Annex VII form, as far as possible (Art. 18(5))

DIWASS only from

in 71 days

What changes

Until 31.12.2026

Since 21 May 2026, GIOŚ has allowed the documents required under Art. 18 to be prepared and exchanged on paper, outside DIWASS – using the new Annex VII form and a contract meeting the new requirements. Annex VII forms are not sent to GIOŚ; from 15 November 2026 the DIWASS module may be used voluntarily.

From 01.01.2027

Documents required under Art. 18 are prepared and exchanged exclusively in DIWASS. All undertakings involved in the shipment complete the Annex VII form in the system, and the information must be available electronically during transport as well – to the other parties, the competent authorities and the inspection authorities.

Diagram 1. Does a shipment require the Annex VII form?

Diagram 1. Does a shipment require the Annex VII form?Decision tree: waste for disposal – consent under the notification procedure; waste for recovery that is not green-listed or is contaminated – notification procedure in DIWASS; green-listed waste up to 20 kg – no Art. 18 requirements; above 20 kg – contract and Annex VII form, in DIWASS only from 1.01.2027; laboratory samples up to 250 kg – also Art. 18.
Purpose of the shipment: recovery?Art. 4(1)–(2)
No
Disposalshipment prohibited unless consent is obtained under the prior written notification procedureArt. 4(1), Art. 11
Yes
Green-listed waste?Annex III or IIIB, or a mixture listed in Annex IIIA – not classified as hazardous and without contamination that increases the riskArt. 4(2) and (4)
No
Prior written notification and consente.g. Annex IV, unlisted or hazardous waste – in DIWASS since 21.05.2026Art. 4(2)
Yes
More than 20 kg in the consignment?Art. 4(4)
No
Art. 18 requirements do not applythreshold in Art. 4(4) not exceeded
Yes
General information requirements – Art. 18contract with the consignee + Annex VII form · confirmation of receipt · certificate of recoveryDIWASS only from 1.01.2027
Samples for laboratory analysisup to 250 kg, or more if agreed by the authorities – also Art. 18Art. 4(5)
SENT (Poland): from 28.10.2026, transport of waste under 19 metal codes – including 17 04 01 copper, bronze, brass – no longer requires a SENT notification on account of the waste shipment rules (Dz.U. 2026, item 1325).
Simplified diagram for shipments between EU Member States; exports from and imports into the EU are subject to additional provisions of Regulation (EU) 2024/1157.

A shipment step by step

  1. Contract with the consigneeconcluded at the latest when the form is completed; valid until the certificate of recovery is issuedArt. 18(10)
  2. Annex VII format least 2 working days before the start; actual quantity, carrier and container number – before the start at the latestArt. 18(5)
  3. Transportthe carrier confirms taking over the waste in the system; data available online or, if not possible, by other means in the vehicle, consistent with the systemArt. 18(6); Reg. 2025/1290 Art. 14
  4. Confirmation of receiptrecovery facility or laboratory – within 2 working days of receiving the wasteArt. 18(8)
  5. Certificate of recoveryno later than 30 days after recovery is completed and no later than one year after receiptArt. 18(9)

Diagram 2. Document flow of a single shipment in DIWASS

Diagram 2. Document flow of a single shipment in DIWASSSwimlane diagram: the person arranging the shipment concludes a contract with the consignee and completes the Annex VII form in DIWASS at least 2 working days before the shipment; the system shares the data with the parties and authorities; quantity, carrier and container number are added before the start; during transport the data is available online or in the vehicle; the facility sends a confirmation of receipt within 2 working days and a certificate of recovery within 30 days of recovery and no later than one year after receipt.
Person arranging the shipment
DIWASS (European Commission)
Carrier
Consignee / recovery facility
Competent and inspection authorities
before shipmentD − 2 working daysD – starttransportreceipt + 2 working daysrecovery + 30 days
ContractArt. 18(10)
ContractArt. 18(10)
Annex VII formArt. 18(5)
SharedArt. 27
Quantity, carrier, containerbefore start
Transportcarrier confirms take-over; data online or in the vehicleArt. 18(6)
Roadside checkaccess to data
Confirmation of receiptArt. 18(8)
Certificate of recovery≤ 1 year after receipt
Forwardedto parties and authorities
Receivesconfirmation and certificate
Accessinspection, enforcement, planning, statisticsArt. 18(12)
If the facility has no access to the system, it sends the confirmation and certificate via the person arranging the shipment (Art. 18(8)–(9)). Intervals on the time axis are indicative.

Contract with the consignee – minimum content (Art. 18(10))

  • details of the person arranging the shipment, the consignee and the facility, and of the persons representing each party
  • description of the waste and its identification codes
  • quantity of waste covered by the contract
  • recovery operation and period of validity of the contract
  • an obligation on the person arranging the shipment – or, where that person cannot ensure it, on the consignee – to take the waste back or ensure its recovery in an alternative way and, if necessary, its storage, if the shipment or recovery cannot be completed as planned or the shipment proves illegal

The contract must be consistent with the Annex VII form. If the consignee is not the facility operator, the operator also signs the contract. The person arranging the shipment or the consignee provides a copy to the inspection authorities at their request (Art. 18(11)). For shipments between two facilities controlled by the same legal person, a declaration by that legal person may replace the contract (Art. 18(14)).

Diagram 3. DIWASS architecture – who exchanges data, how and with whom

Diagram 3. DIWASS architecture – who exchanges data, how and with whomEconomic operators connect to the central DIWASS system via the web interface with EU Login or via commercial software (API); the system holds the operator register, Art. 18 documents and notifications and decisions; GIOŚ, other States’ authorities and inspection services have access.Economic operatorsAccess channels (PL)Central systemPublic authorities
Waste producer
Person arranging the shipment
Carrier
Consignee
Recovery facility / laboratory
Web interfaceEU Login sign-in
Commercial softwareAPI – interoperability under Reg. (EU) 2025/1290
DIWASSCommission central system · real-time repositoryArt. 27, Reg. (EU) 2024/1157
Operator register: EORI / NIP, REGON, BDO
Art. 18: Annex VII forms, contracts, confirmations, certificates
Notifications, decisions, movement documents
GIOŚcompetent authority in Poland · approves operator registration
Other States’ authoritiesdispatch, transit and destination
Inspection servicesWIOŚ, ITD, Border Guard, KAS, Police
Parties in the forms can only be selected from the list of operators registered in DIWASS – which is why all parties to a shipment must be registered. Sources: GIOŚ, Art. 27 of Regulation (EU) 2024/1157, Implementing Regulation (EU) 2025/1290.

Timeline

  1. Regulation (EU) 2024/1157 applies; notifications in DIWASS
  2. GIOŚ letter to industry organisations
  3. Annex VII module live in DIWASS (voluntary)
  4. Annex VII in DIWASS only

Diagram 4. Transition period and deadlines 2026–2027

Diagram 4. Transition period and deadlines 2026–2027Gantt chart: notifications mandatory in DIWASS from 21.05.2026; paper Annex VII allowed by GIOŚ from 21.05 to 31.12.2026; test module available at least from 29.09.2026; production module voluntary from 15.11.2026; Annex VII in DIWASS only from 1.01.2027; SENT no longer covers 19 metal waste codes from 28.10.2026.05.202606.202607.202608.202609.202610.202611.202612.202601.202702.202703.2027
Notifications – mandatory in DIWASS
21.05
Annex VII – paper form allowed by GIOŚ
21.0531.12
Annex VII test module (Commission) – available per GIOŚ letter of 29.09
29.0931.12
Annex VII production module – voluntary
15.1131.12
Annex VII in DIWASS only
01.01
SENT: 19 metal codes without notification (PL)
28.10today
The Annex VII transitional period is based on the GIOŚ position of 17.04.2026, following the conclusions of the Commission’s Expert Group on Waste. The “today” line moves automatically.

Registration in DIWASS

All parties involved in a shipment must register – including the producer, the person arranging the shipment, the consignee, the facility and the carrier. In the form, parties can only be selected from the list of registered operators. Registration and an EU Login account are free of charge; the main identifier is the EORI number or, if there is none, the Polish tax number (NIP). GIOŚ approves the registration of Polish operators within 5 working days of the request (Art. 7 of Reg. 2025/1290); foreign parties register with the authorities of their own countries.

Test environment

An Annex VII test module is available on the European Commission’s platform. Registrations made in the test version are not migrated to the production version – operators must register again there.

GIOŚ recommendation

GIOŚ recommends registering in DIWASS and starting to work in the system before 1 January 2027, so that it can be implemented and any problems identified early. Questions about DIWASS can be sent to diwass@gios.gov.pl.

Permits of the parties

A person arranging the shipment who is a new producer, a collector, or a dealer or broker must hold a permit or registration under Chapter IV of Directive 2008/98/EC (Art. 18(2)). Waste may only be shipped to a recovery facility with a permit or registration, which the facility presents before the shipment (Art. 18(3)). Where the arranger is not the original producer, they ensure – where possible – that the original producer also signs the form (Art. 18(4)).

Consequences of non-compliance

A shipment that does not comply with Art. 18(2), (4), (6) or (10) or with the information in the Annex VII form – except for minor clerical errors – is an illegal shipment (Art. 3(26)(g)). The tolerance for paper documents until 31.12.2026 stems from the GIOŚ position, not from a provision of the Regulation, and covers only the failure to enter documents into DIWASS.

During and after the shipment

From the start of the shipment until receipt, the waste must not be mixed with other waste or substances (Art. 19). If the shipment or recovery cannot be completed as planned, the arranger immediately informs the competent authority of dispatch (Art. 23). The arranger, the consignee and the facility keep the Art. 18 information in the EU for at least 5 years from the certificate of recovery (Art. 20(2)).

Notifications

The prior written notification and consent procedure has been handled in DIWASS on a mandatory basis since 21 May 2026 – the transitional period applied only to the documents under Art. 18.

Related changeSENT: no notifications for 19 metal waste codes from 28 OctoberFrom 28 October 2026, transport of metal waste under 19 codes no longer requires a SENT notification – the Annex VII form still applies.

Key facts

Legal basis
Art. 4(4)–(5), Art. 18 and Art. 27 of Regulation (EU) 2024/1157 of 11 April 2024 on shipments of waste; Commission Implementing Regulation (EU) 2025/1290
Scope
shipments of waste listed in Annex III or IIIB and mixtures listed in Annex IIIA destined for recovery, above 20 kg (Art. 4(4)), and of waste destined for laboratory analysis (Art. 4(5)); exports from the EU are subject to additional requirements (Art. 40(4), Art. 44(4))
System
DIWASS (Digital Waste Shipment System) – the European Commission’s central system; accessed via a web interface or interoperable commercial software (API)
Authority in Poland
Chief Inspector of Environmental Protection (GIOŚ) – approves operator registrations; diwass@gios.gov.pl
GIOŚ communications
notice of 17.04.2026 on the transitional period; letter DTPO-ZTP.415.8.2026.3.GP of 29.09.2026 to industry organisations
Deadline
1.01.2027 – Art. 18 documents in DIWASS only

Sources

Informal summary. The authentic text is Regulation (EU) 2024/1157 as published in the Official Journal of the EU; GIOŚ communications are available in Polish.

This information is provided for guidance and does not constitute legal advice.

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