The regulation introduces new operational requirements, including mandatory electronic submission and exchange of information, as well as stricter rules for completing Annex VII documentation prior to shipment.
Waste shipments play a central role in the functioning of the European circular economy, enabling the efficient use of secondary raw materials across borders. At the same time, they are associated with a significant administrative workload for authorities and operators. With the application date approaching, several implementation aspects remain unresolved, particularly those related to digital procedures and advance documentation requirements for intra-EU shipments.
A key concern relates to the introduction of the Digital Waste Shipment System (DIWASS). While the sector broadly supports digitalisation as a means to improve traceability and enforcement, the practical rollout of DIWASS raises operational and technical challenges. Experience from national systems shows that businesses and authorities require sufficient time to adapt internal processes, train staff and integrate IT systems. Although the regulation foresees a 24-month preparation period, implementing rules for DIWASS were only adopted in mid-2025, technical specifications were published at the end of January 2026, and the system is not yet fully operational. Registration of the large number of affected operators has also not started.
Against this background, industry associations are requesting a coordinated transition period of at least one year following the mandatory start date. During this period, operators that are technically unable to fully comply with DIWASS requirements would be allowed to make required documents available through alternative means without facing penalties. Such an approach would rely on existing legal provisions that allow for alternative documentation when digital systems are not accessible and would help maintain a level playing field across Member States. The associations also note that the revised Annex VII form is designed for digital use and is not suited for paper-based procedures. They therefore propose continuing to use the current Annex VII for non-digital processes during the transition phase.
A second major issue concerns the requirement to submit Annex VII documentation at least two working days before the start of a shipment. According to the sector, this obligation creates disproportionate logistical and administrative constraints, particularly for green-listed intra-EU waste shipments that are often organised at short notice. In practice, shipment planning frequently depends on real-time operational factors, such as container fill levels, transport availability or weather conditions in the case of inland waterways. The advance submission requirement also complicates immediate take-back procedures when shipments are refused by receiving facilities.
The associations argue that the two-day advance rule risks undermining the competitiveness of recycled materials compared with primary raw materials, which are not subject to comparable administrative requirements. It may also disrupt routine waste management services for industrial and commercial customers, where waste collection is often triggered on demand. In response, operators may either switch to less efficient national solutions or submit Annex VII forms based on estimates that do not necessarily reflect actual shipments, increasing administrative workload without improving enforcement outcomes.
From an enforcement perspective, the sector points out that digital registration through DIWASS will already significantly expand the volume and quality of data available to control authorities. Real-time digital tracking is expected to enable more targeted inspections based on actual shipment patterns rather than formal advance notifications. On this basis, the associations are calling for the repeal of the two-day advance submission requirement for Annex VII and for greater flexibility regarding estimated quantities prior to departure, with final quantities to be confirmed upon receipt.
According to the signatories, these adjustments would reduce unnecessary administrative burdens, improve legal certainty and support the functioning of the internal market for secondary raw materials, while maintaining effective controls against illegal waste shipments.
