The paper version of Annex VII is still in force. Why might many hauliers encounter problems during inspections?

Paper Annex VII It remains an acceptable method of documenting the transport of Green List waste. However, many businesses mistakenly assume that the postponement of the mandatory use of DIWASS means there are no changes to transport documentation. Meanwhile, new regulations and a new document template have been in force since 21 May 2026. Using the old forms may lead to problems during inspections, even if the shipment is carried out in accordance with the rules of the transitional period.

The paper version of Annex VII remains valid

Until 31 December 2026, businesses may make use of the transitional period provided for under EU legislation. In practice, this means they can carry out shipments of Green List waste without entering the data into the DIWASS system.

The absence of a record in the system does not automatically make the transport illegal. Enforcement authorities should not impose penalties solely on the grounds that the platform has not been used. However, they may make entry into a particular country more difficult (see below for further details).

Where does the problem lie?

Many transport operators focus solely on the DIWASS system and overlook the fact that, from 21 May 2026, new regulations regarding the documentation accompanying waste shipments will also come into force.

This means that a driver may hold a paper copy of Annex VII, but at the same time use a form that does not comply with the current requirements of Regulation (EU) 2024/1157.

During the inspection, the inspector will not only check that the document is present. They may also verify whether its content complies with current regulations.

Annex VII alone is not enough

Another document that is often overlooked is the contract between the waste consignor and the final waste treatment operator, as required by Article 18 of Regulation (EU) 2024/1157.

Businesses usually focus on the transport document. However, the regulations also require that there be a suitable contract between the parties involved in the movement of waste.

If a company is making use of the transitional period under DIWASS, it should ensure that both Annex VII and the contractual documentation are in order. Furthermore, it is incorrect to assume that registration in DIWASS is also deferred in the same way as the electronic Annex VII. Germany has taken a clear stance on this matter and has indicated that without a listing on the platform, the carrier may not be permitted entry within the country.

More and more companies are taking notice of DIWASS

Although the regulations still permit the use of paper-based documentation, many waste producers, brokers and recipients now expect their partners to be registered with DIWASS.

This is because of a desire to ensure greater transparency and make it easier to track shipments. Therefore, failure to register may lead to further queries from business partners, even if the business is operating in accordance with the regulations.

The most important rule for 2026

The transition period does not mean a return to the old documents. It simply means that businesses can still choose between paper documentation and the DIWASS system.

If a company decides to use a paper version of Annex VII, it should ensure that it is using the current template and that its contract complies with the requirements of Regulation (EU) 2024/1157. It is these elements that will be of the greatest importance during an inspection.