DIWASS implementation issues: waste industry concerns

The DIWASS system has not yet come into force and is already provoking clear reactions among companies and industry organisations. Questions are being raised as to whether the new tool will actually tidy up the market for cross-border waste shipments or whether it will rather change the way reporting and controls are carried out. This is why the problems with the implementation of DIWASS are becoming one of the more frequently discussed topics in the waste and logistics community today. This is not an objection to regulation per se. Rather, it is an attempt to realistically assess what companies will face in practice after May 2026.

Why the industry doubts even before the DIWASS launch

The first source of uncertainty is the scale of the changes brought about by the new system. DIWASS is not concerned with one stage of a shipment, but with the whole chain of cross-border waste shipments. It covers different roles, different procedures and different levels of responsibility.

The second factor is the pace of implementation. Companies know that the system is due to go live by a certain date, but the technical details and practical operating scenarios are still taking shape. Under such conditions, it is natural to ask whether the market will have time to prepare in an orderly rather than reactive manner.

Doubts therefore do not stem from a lack of desire to comply with the law. They stem from the experience of previous reforms, which often burdened businesses with additional obligations before bringing real operational improvements.

The voice of the industry - what concerns arise most often

In the industry debate around the implementation of DIWASS, there are specific and well-documented concerns that are worth knowing today. Representatives of European organisations active in the recycling, glass, metals and plastics sectors point out that the short timeframe for implementation, the limited time for technical preparation and the new documentation requirements may generate operational difficulties.

One of the industry demands is the introduction of a transition period of at least one year after DIWASS comes into force. This is to allow companies to complete the adaptation of systems and procedures without the risk of sanctions. The signatories of the letters to the European Commission also point out that the requirement to send documents such as Annex VII two days in advance does not always correspond to the realities of day-to-day logistics operations, which often depend on changing conditions.

Other industry voices emphasise that the DIWASS implementation schedule is quite tight. The implementation of the system must be completed by 21 May 2026, and the clarification of the technical specifications and the availability of test environments came relatively late. Recyclers' organisations indicate that earlier availability of information on the system architecture would have been helpful for planning IT integration and adjusting internal procedures.

Can one system solve all waste transport problems?

This question comes up a lot and it is worth answering it directly. DIWASS will not solve all the problems of the waste industry. And that is not its purpose. The system will not eliminate misclassification of waste. It will not replace the knowledge of transport participants. It will not take over responsibility for operational decisions. It will, however, organise information and make irregularities visible more quickly. From this perspective, it will act as a control and transparency tool, not as a corrective mechanism for the whole market. The expectation that it will „cure” waste transport leads to disappointment.

There is a recurring concern in many industry voices about excessive expectations of the system. It is supposed to improve supervision, but it will not replace well-functioning internal company procedures. Some industry representatives point out the risk of shifting the burden of responsibility from substantive decisions to the correctness of data in the system. This means that even minor inaccuracies can lead to serious operational consequences. However, DIWASS does not so much simplify responsibilities as enforce greater information discipline at every stage of carriage.

The most important conclusion is simple. Industry doubts are not a signal to wait, but to prepare in advance. Companies that treat DIWASS as just another IT system could face real operational problems. A much better approach is to analyse your own role in carriage, get your documentation in order and understand what information will be subject to verification. It is at this stage that the risks that the market is talking about today can be mitigated.

A game-changing solution

The problems with the implementation of DIWASS show one thing: the market is not questioning the need for change, but is concerned about the practical implications. This is natural with such a wide-ranging reform.

The system will not be a miracle cure for all waste transport problems. However, it will make unpreparedness, data inconsistencies and procedural errors visible more quickly. For companies, this means taking a conscious approach rather than passively waiting for the system to take off.

The sooner this topic is tamed, the less relevant the concerns that are resounding in the industry today will be.