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★Mark us as a preferred sourceGerman recycling associations (bvse, BDSV, and VDM) have issued an official joint letter warning the German Federal Ministry for the Environment and the European Commission. According to the industry organizations, the mandatory digital waste shipment system is causing immediate problems, and without appropriate countermeasures, it could lead to a complete standstill of cross-border waste shipments and disrupt established recycling routes.
The amended EU Waste Shipment Regulation (EU) 2024/1157 has brought significant changes to the sector. Starting May 21, 2026, the European Union mandated the electronic exchange of documents via the digital waste shipment system (DIWASS). Similar to the digital tracking systems required in other industries, this move aimed for transparency and speed. However, practical implementation currently faces severe technical and administrative hurdles. If transitional periods are not extended, companies could face massive economic damage.
Technical failures of the digital waste shipment system and current status
The associations pointed out that major disruptions have only been avoided so far due to existing transitional rules. For shipments subject to general information requirements (Annex VII), purely paper-based documents can still be used until the end of 2026. Furthermore, for shipments requiring notification, companies frequently rely on permits that were submitted in paper form prior to the new rules coming into effect.
Problems become critical where the use of the platform is already mandatory. The associations highlight plastic waste with the waste code B3011 shipped to third countries, which has required notification for the first time since May 21, 2026. A recent survey among bvse members revealed a devastating result: not a single notification could be completely processed via the platform. Regardless of the digitalization level of the responsible waste shipment authorities, not a single shipment has taken place since May 21 where the use of the system was mandatory.
What is causing the administrative standstill in the European network?
The organizations provided a detailed breakdown of the software and administrative flaws:
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Registration difficulties: Authorities are partially unable to process the multitude of applications in a timely manner. Some responsible bodies are struggling to establish the technical prerequisites for the software themselves. This is particularly impactful because a notification is only technically possible once all participating partners in the disposal chain are registered.
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Interface failures: Defective or unreliable interfaces between national IT systems and the EU central hub frequently cause form uploads to fail.
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Invisible actors: Already registered actors, such as transport companies, are sometimes untraceable in the database, making it impossible to generate complete notification documents.
The outlook for next year and the 4-point proposal
bvse, BDSV, and VDM are viewing the upcoming year with particular concern. At the turn of the year, the transition phase for using Annex VII in paper form will end, and existing notification approvals will progressively expire. The associations state that using the network for the Annex VII procedure is currently not possible, meaning no practical test phase could take place yet. Should these problems remain unsolved, established recovery routes could be impaired. This is especially problematic where insufficient domestic recovery capacities are available.
To enable a smoother transition, the three recycling associations proposed four concrete measures:
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Extend paper tolerance: The current tolerance of paper forms for Annex VII shipments should be extended to new procedures requiring notification.
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Extend the transitional period: The transitional period for paper forms must be extended until at least June 30, 2027.
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Mandatory test phase: An exclusively digital processing should only become mandatory after a successful test phase of at least two months has been conducted.
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Extend existing approvals: To reduce pressure, official approvals for existing notifications expiring in 2026 should be extended by a flat rate of one year.
Frequently Asked Questions (FAQ)
What is the digital waste shipment system (DIWASS)?
The digital waste shipment system is an electronic document exchange platform for cross-border waste shipments, introduced on May 21, 2026, under the amended EU Waste Shipment Regulation.
Why have recycling organizations sounded the alarm?
According to surveys and experiences from bvse, BDSV, and VDM, the system is currently dysfunctional. Since the mandatory implementation date, not a single mandatory notification has been successfully processed due to technical errors.
What specific technical problems are hindering the system?
There are faulty interfaces between national systems and the central hub, form uploads often fail, authorities are backlogged with registrations, and some already registered actors (like transport companies) cannot be found in the database.
What do the professional associations propose to solve the situation?
They request extending the acceptance of paper-based documentation to new procedures, prolonging the paper transitional period until at least June 30, 2027, introducing a two-month test phase, and automatically extending permits expiring in 2026 by one year.
