Joint Call: Ensuring a smooth implementation of new EU waste shipment rules

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:

1. 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.

2. 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. 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.

Cepi is the European association representing the paper industry. We offer a wide range of renewable and recyclable wood-based fibre solutions to EU citizens: from packaging to textile, hygiene and tissue products, printing and graphic papers as well as speciality papers, but also biochemicals for food and pharmaceuticals, bio-composites and bioenergy. We are a responsible industry: 85% of our raw materials are sourced from within the European Union, 92% of the water we use is returned in good condition to the environment. We are the world champion in recycling at the rate of 70.5% At the forefront of the decarbonisation and industrial transformation of our economy, we embrace digitalisation and bring 25 billion value addition to the European economy and €5 billion investments annually. Through its 19 national associations, Cepi gathers 490 companies operating 870 mills across Europe and directly employing more than 180,000 people.

The European Precious Metals Federation (EPMF) is an international trade association representing the interests of the precious metals industry in Europe. The main purpose of the EPMF is to promote and support the European precious metals industry, including refining, recycling, trading, and fabrication of precious metals such as gold, silver, platinum, and palladium. The EPMF represents the interests of its members in discussions with regulators, policy makers, and other stakeholders, mainly in sustainability and chemicals management fields. The organization also seeks to provide information and resources to its members in critical areas like EU regulations and new science.

EPRO is an association focussing on plastics circularity.  EPRO is represented in 12 EU Member States and two non-EU countries in the European Free Trade Association (EFTA) where EU laws apply.  Members consist of collection systems for plastics packaging and agricultural plastics, extended producer responsibility (EPR) organisations, and national plastics circularity associations.  EPRO provides a platform for sharing of technical expertise and best practice helping to facilitate the move towards a more circular economy for plastics.

ERFO is the European Recovered Fuel Organisation joining forces to recover energy from waste and produce high quality alternative and renewable fuels for energy-intensive industries like cement kilns, lime factories, biomass facilities or power plants.

EUROFER AISBL is located in Brussels and was founded in 1976. It represents the entirety of steel production in the European Union. EUROFER full members are steel companies and national steel federations throughout the EU. The major steel companies and national steel federations in Turkey, Ukraine and the United Kingdom are members. The European Steel Association is recorded in the EU transparency register: 93038071152-83.

European Metals is an umbrella association representing the interests of the combined non-ferrous metals industry towards EU policy makers. We bring together the companies and associations shaping Europe’s non-ferrous metals ecosystem: from upstream mining and refining to downstream use and high-quality recycling. By connecting technical expertise with policy action, we ensure that the importance of the metals sector is recognised, valued, and that our sector’s future is secured.

EXPRA (Extended Producer Responsibility Alliance) is the alliance of 38 non-profit packaging and packaging waste recovery and recycling organisations, (including 21 EU Member States and two non-EU countries in the European Free Trade Association (EFTA) where EU laws apply) founded and run by or on behalf of obliged industry. Acting as the authoritative voice and common policy platform for its members, EXPRA represents industry-led Extended Producer Responsibility (EPR) systems at European and international level.  For more than 30 years, EXPRA members have co-organised the collection, sorting, and recycling of used packaging, enabling obliged industry to fulfil its legal take-back and recycling obligations efficiently and effectively. EXPRA promotes and defends EPR as a proven, industry-driven approach to sustainable packaging waste management and serves as a key contact point for EU and international institutions.

FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year.

As the European federation of glass recycling companies, FERVER brings together industry leaders from 20 countries and its members are, amongst others, responsible for recycling around 70% of Europe’s packaging glass waste into high-quality cullet – a key raw material used to produce new glass products. FERVER members recycle both container glass and flat glass. FERVER therefore plays a vital role in closing the loop for glass and advancing circularity across Europe.

Glass for Europe is the trade association for Europe’s flat glass sector. Flat glass is the material that goes into a variety of end products, primarily in windows and facades for buildings, windscreens and windows for automotive and transport as well as solar energy equipment, furniture and appliances. Glass for Europe brings together multinational firms and thousands of SMEs across Europe, to represent the entire building glass value-chain. It is composed of flat glass manufacturers, AGC Glass Europe, Guardian, NSG-Group, Saint-Gobain Glass Industry and Şişecam, and works in association with national partners gathering thousands of building glass processors and transformers all over Europe.

Glass Fibre Europe, founded in 1987, is the voice of the European continuous filament glass fibre industry. It is composed of 7 companies: 3B the fibreglass company, Envalior, FYSOL SAS, Johns Manville, Owens Corning, Valmiera Glass, and Saint-Gobain Vetrotex. Glass Fibre Europe represents all the major producers of continuous filament glass fibre in Europe. The continuous filament glass fibre industry is the cornerstone of the glass-based composite materials and technical textiles value-chains. Glass fibre’s unique properties enable the production of wind energy, electric and electronic devices, and the development of sustainable solutions in a wide range of applications, such as transport and construction.

The International Copper Association Europe is the leading advocate for the copper industry in Europe and the European arm of the International Copper Association (ICA). Our members mine, smelt, refine and recycle copper for use across the economy, in the electricity system, buildings, transport and industry.

Plastics Europe is the pan-European association of plastics manufacturers with offices across Europe. For over 100 years, science and innovation have been the DNA that cuts across our industry. With members producing over 90% of all polymers across EU27+3 (Norway, Switzerland, UK) we are the catalyst for the industry with a responsibility to openly engage with stakeholders and deliver solutions which are safe, circular and sustainable. We are committed to implementing long-lasting positive change.

Recycling Europe (formerly EuRIC) is the voice of Europe’s recycling industry, including 80 national federations and companies across 24 EU & EFTA countries. From metals and paper to plastics, textiles, tyres, ships, construction & demolition waste and WEEE, our members transform waste into resources—powering Europe’s circular economy, ensuring resource autonomy, and boosting competitiveness and sustainable industrialisation across the continent.

VinylPlus is the European voluntary commitment to sustainable development of the European Polyvinyl Chloride (PVC) industry. We represent a unique value chain built over more than 25 years of continuous investment, bringing together companies from across all stages of PVC production, use, and recycling, with a complete production and recycling footprint established in Europe. VinylPlus empowers a future-proof PVC value chain by supporting and challenging its partners companies in achieving their sustainability goals, and by being backed by trusted, science-based data.