Is Annex VII already electronic in 2026?

The Waste Shipment Regulation requires electronic availability under Articles 18 and 27, but the European Commission applies a transitional approach from 21 May through 31 December 2026 under which Annex VII documents should continue to be handled as before, primarily on paper.

When must Annex VII information be completed?

Article 18 requires the person arranging the shipment to complete the relevant Annex VII information to the extent possible no later than two working days before shipment starts. Actual quantity, carrier information and container identification may be supplied by the start of shipment.

DIWASS · Annex VII

DIWASS Annex VII: What Changes on 1 January 2027?

Q: What changes on 1 January 2027?

Under the Commission guidance currently in force, the Annex VII transition ends after 31 December 2026. Operators should therefore be operationally ready for electronic Annex VII exchange from 1 January 2027 unless the Commission issues new guidance.

Annex VII is the part of the DIWASS transition most likely to create confusion in late 2026. The law requires electronic exchange, but the Commission is currently allowing Annex VII documents to continue being handled largely as before through 31 December 2026. This guide explains what operators should prepare before that transition ends.

Last verified: 22 September 2026 · Based on current Commission guidance and Regulation (EU) 2024/1157

The practical answer

From 21 May to 31 December 2026, the European Commission says Annex VII documents should continue to be handled in the same way as before, primarily in paper format, because of implementation challenges around system interconnections. Under the current guidance, operators should therefore be ready to use the electronic framework from 1 January 2027. If the Commission changes or extends this guidance, the operational date could change, so businesses should monitor official updates.

Why is Annex VII different from other DIWASS workflows?

DIWASS became mandatory on 21 May 2026 for the submission and handling of notification documents involving an EU Member State as dispatch, destination or transit, and for generating movement documents under fully consented notifications.

Annex VII is different because the Commission identified practical difficulties in ensuring that the central DIWASS system, Member State systems and interconnected software were all ready to exchange Annex VII documents reliably. The Expert Group on Waste discussed those challenges in March 2026, leading to the current transitional approach.

That means there is a difference between the legal electronic framework in Regulation (EU) 2024/1157 and the temporary operational approach being applied during the remainder of 2026.

Do not interpret the transition as a cancellation of digitalisation. Article 18 requires Annex VII information to be made electronically available in accordance with Article 27. The 2026 arrangement is a temporary operational transition, not a return to a permanently paper-based regime.

What Article 18 requires

Article 18 applies to the waste shipments covered by Article 4(4) and (5), which are subject to the Regulation's general information requirements rather than prior written notification and consent.

The article assigns responsibilities across the shipment rather than treating Annex VII as a document completed once by a single party.

Before the shipment

The person arranging the shipment must be appropriately authorised or registered under the Waste Framework Directive where Article 18 requires it.
The waste may only be shipped to a recovery facility that has the required authorisation or registration.
All undertakings involved must complete the relevant Annex VII fields assigned to them.
The person arranging the shipment must complete the relevant information to the extent possible no later than two working days before the shipment starts.
The actual quantity, carrier or carriers, and container identification number where applicable may be supplied by the start of the shipment.

During transport

The Regulation requires the information to be electronically available, including during transport. It also recognises that electronic availability can fail: if the information cannot be accessed online during transport, the person arranging the shipment and carrier must ensure it is available in another form in the vehicle, consistent with the electronically submitted information. Changes or additions must then be submitted through the Article 27 system.

At destination

The recovery facility or laboratory must confirm receipt to the person arranging the shipment within two working days by completing the relevant Annex VII information.

The recovery facility must also provide a recovery certificate as soon as possible and no later than 30 days after completion of the recovery operation, and in any event no later than one year after receiving the waste.

The Annex VII contract still matters

For the Article 18 shipments covered by the Regulation, there must be a contract between the person arranging the shipment and the consignee for the recovery of the waste. If the consignee is not the facility operator, the operator must also sign the contract.

The contract must be in place by the time Annex VII is completed and remain effective until the recovery certificate is issued. It must contain specified information including the parties, waste description and codes, quantity, recovery operation and validity period, together with obligations for take-back or alternative recovery where the shipment or recovery cannot be completed as intended or is illegal.

What should change operationally from 1 January 2027?

Under the Commission guidance currently published, the special Annex VII transition stops after 31 December 2026. That does not mean every company will necessarily use exactly the same screen on 1 January. The access route depends on the competent authority responsible for the operator.

Operators can be required to use:

the Commission DIWASS GUI;
a Member State or regional system interconnected with DIWASS; or
corporate or commercial software connected through the applicable API route.

The Commission specifically notes that a competent authority can choose different access methods for the notification procedure and Annex VII. A company may therefore use one system for PIC notifications and another route for Annex VII.

Current 2026 situation	Readiness needed for 2027
Annex VII mainly handled on paper under the transition	Confirm the authority-defined electronic access route and test it before year-end.
Counterparty details are often retyped manually	Ensure required economic operators are registered and selectable in DIWASS.
Paper accompanies the vehicle	Define how transport staff will access required information electronically and what fallback copy is available if systems are offline.
Receipt/recovery confirmations may sit in separate workflows	Assign who completes the receiving and recovery stages and within which deadlines.
Changes may be communicated informally	Define how changes/additions are submitted through the relevant Article 27 system.

Registration can become a shipment blocker

DIWASS does not allow operator details simply to be typed into Annex VII at submission time. The Commission explains that operators are selected from registered entities. If a required operator is missing from the system, it will not appear in the drop-down list and the document may not be completable or submittable.

For Annex VII-heavy businesses, the highest-value preparation may therefore be less glamorous than buying software: create a list of the waste producers, persons arranging shipment, carriers, consignees and receiving facilities that recur in your flows, and identify which ones are not yet ready or registered.

Who needs to contribute to the digital Annex VII workflow?

The Commission's DIWASS access model gives different parties access once the Annex VII document is submitted. In practice, the workflow can involve the person arranging the shipment, waste producer(s), carrier(s), consignee, waste treatment facility and relevant competent authorities.

The operational challenge is therefore not just “who fills out Annex VII?” but how each contribution reaches the same electronic record without delaying the shipment.

A six-step Annex VII readiness plan for Q4 2026

1 · Inventory your Annex VII flows
List routes, waste codes, recurring counterparties, shipment volumes and exceptions.

2 · Confirm your access route
Check the competent authority's declared method specifically for Annex VII, not just for notification/PIC workflows.

3 · Audit registrations
Check your own entities, sites and recurring counterparties before a live document depends on them.

4 · Map ownership of each field
Identify who provides quantity, carrier, container, consignee, facility, receipt and recovery-certificate information.

5 · Test a representative shipment
Use a common route first, then test carrier changes, several carriers and other real exceptions.

6 · Define a fallback
Document what happens if the GUI, local system, commercial software or mobile connectivity is unavailable during transport.

Do Annex VII operators need commercial DIWASS software?

Not automatically. A low-volume operator may be able to work effectively through the Commission GUI or the relevant national/local system. Commercial software becomes more compelling as shipment volume, repeated counterparties, user count, number of countries and ERP/TMS integration needs increase.

For a buying decision, compare software cost with actual process cost: minutes per document, duplicated data entry, corrections, manual handoffs, delayed departures, document retrieval and audit effort.

FAQ

Will paper Annex VII definitely stop on 1 January 2027?

The Commission's current published transition runs through 31 December 2026. Therefore businesses should prepare for the electronic framework from 1 January 2027. Because implementation guidance can change, EU Reg Brief recommends checking the Commission and the relevant competent authority again before year-end rather than treating the date as immune to future guidance.

Does the driver need an internet connection at all times?

The Regulation anticipates periods when information cannot be made available online during transport. In that situation, the information must be available by other means in the vehicle and remain consistent with the electronic information. Changes or additions must subsequently be submitted through the relevant Article 27 system.

Can an unregistered carrier just be typed into Annex VII?

The Commission says operator details cannot simply be entered manually at the submission stage. Required operators need to exist in the system so they can be selected.

Is DIWASS registration proof that a recovery facility is legally authorised?

No. DIWASS registration is a technical identification step. Regulatory authorisation or registration of the facility remains a separate legal requirement.

Check whether your Annex VII process is ready

Use the free DIWASS 2026/2027 Practical Checklist to review access, registration, counterparties and shipment controls before the transition ends.

Get the practical checklist

Official sources

Scope: EU Reg Brief is an independent information resource and does not provide legal advice. Requirements depend on the waste, route, parties and competent authorities involved.