The DIWASS rollout has brought renewed attention to the commercial risks that arise when a recyclable shipment, already sold, priced and booked for transport, fails to move when expected. For the businesses involved, that can meanextra storage and haulage costs, delayed payment, disrupted production schedules and strained customer relationships.
These are the commercial risks behind the growing concerns surrounding theEU's Digital Waste Shipment System (DIWASS). In a letter dated 21 October 2026, industry association Recycling Europe warned the European Commission that technical failures are delaying or blocking shipments requiring prior notification.
Digitalisation should make legitimate waste shipments easier to manage and monitor. When the infrastructure required to comply cannot be relied upon, however, businesses face uncertainty that no amount of preparation on their part can necessarily remove.
DIWASS Rollout: Key Information
- DIWASS went live on 21 May 2026. Its mandatory use began for notification procedures involving waste shipments where an EU Member State is the country of dispatch, destination or transit.
- Recycling Europe reports technical failures. Its letter says notified shipments have been delayed or blocked by malfunctions in the EU platform.
- Annex VII has a transitional period. European Commission guidance says these documents should continue to be handled as before, primarily on paper, between 21 May and 31 December 2026.
- The next key date is 1 January 2027. Electronic handling of Annex VII information is due to become mandatory under the existing timetable.
- An extension has been requested, not approved. Recycling Europe wants the transitional period extended until at least 1 July 2027, with paper procedures retained in the meantime.
Why a Technical Failure Becomes a Commercial Problem
The consequences of a shipment delay rarely stop with the company submitting the paperwork.
An exporter may have material occupying valuable warehouse space and a collection arranged for a specific day. If the shipment cannot proceed, storage arrangements and transport bookings may need to change. The buyer, meanwhile, may be relying on that delivery to maintain feedstock levels and keep processing equipment supplied.
For the receiving recycler, an interrupted delivery schedule can mean lower utilisation, production rescheduling or the need tosource alternative material. A haulier may have to rearrange its vehicle and driver schedule, potentially affecting other jobs.
Each of these outcomes depends on the circumstances of the shipment, its contractual terms and the length of the delay. They are not inevitable consequences of every DIWASS issue. They illustrate how a technical problem at one stage can create costs across an entire commercial transaction.
Cash flow matters just as much. Where payment depends on delivery, acceptance or completion of a contractual milestone, an interrupted shipment can postpone the point at which a business receives its money. Meanwhile, overheads and other commitments continue.
For companies operating on tight margins, a transaction that appeared commercially sound when agreed can become less attractive once additional costs accumulate.
Recycling Europe has not quantified the total financial impact across the sector in its published letter. Its warning is nevertheless clear: recycling businesses should not have to absorb the financial consequences of technical failures beyond their control while remaining responsible for meeting their legal obligations.
Why 1 January 2027 Matters
The current problems are particularly concerning because the next implementation stage is approaching.
The revised Waste Shipment Regulation (EU) 2024/1157 introduced a new framework for documenting and monitoring waste movements. DIWASS provides the central digital system through which relevant information and documents are submitted and exchanged.
The Commission's transitional approach for Annex VII documents reflects acknowledged challenges involving connections between the central system, national systems and commercial software. From 21 May to 31 December 2026, these documents are to continue being handled primarily in paper format.
That transitional period is due to end on 31 December. Unless the timetable changes formally, businesses handling qualifying shipments under the general information requirements of Article 18 must prepare for electronic documentation from 1 January 2027.
Article 18 also requires the person arranging a relevant shipment to complete the Annex VII form as far as possible no later than two working days before dispatch. Information about the actual quantity, carrier or carriers and, where applicable, container identification can be supplied later, up to the start of the shipment.
Recycling Europe argues that this advance submission requirement fails to reflect the practical realities of recycling operations and risks creating further disruption. Its letter asks the Commission to reconsider the rule as well as extend the transitional period.
The distinction matters: the advance submission requirement comes from the Regulation, while the technical failures described by the association concern the operation of the digital system. They are related operational pressures, but they are not the same problem.
Businesses should not assume that the requested extension will be granted. They need to prepare for the existing timetable while monitoring official guidance and any formally announced changes.
A European Problem With International Consequences
The commercial stakes extend beyond individual EU borders.
Eurostat recorded 49.7 million tonnes of recyclable raw material imports into the EU in 2025, alongside exports of 36.2 million tonnes to non-EU countries. These figures cover a wider category of recyclable raw materials, including by-products, rather than DIWASS-regulated waste alone. They nevertheless demonstrate how important international material flows are to European industry.
Global trade is also changing. The OECD's October 2026 monitoring report, based on 2024 trade data, found that global plastic waste and scrap trade volumes continued to decline, recording their largest year-on-year fall since 2020. Intra-regional trade was becoming increasingly important.
In this environment, dependable execution matters to both buyers and sellers. Businesses need to know not only whether material is commercially available, but whether it can move through the intended route, arrive on schedule and meet the receiving facility's requirements.
The implications also reach operators based outside the EU. The Commission states that third-country authorities and operators involved in waste shipments from, to or transiting through the EUneed to be registered in DIWASS. UK and other international businesses involved in relevant movements therefore need to understand the requirements that apply to their particular routes.
DIWASS is not a universal global waste tracking system, and not every recyclable material movement falls within its scope. But its operation matters to international supply chains whenever a shipment is subject to the EU's waste shipment procedures.
Digitalisation Must Work in Practice
WasteTradesupports the wider direction of travel towardsmore transparent, traceable and reliable digital trading. Better information exchange can improve oversight, reduce avoidable administrative errors and help businesses establish clearer responsibilities.
The question is whether the infrastructure delivers those benefits consistently.
The Commission's own guidance recognises that DIWASS can involve different access methods depending on the procedure, including local authority systems, the central website and interconnected commercial software. That flexibility creates opportunities for integration, but also places importance on dependable connections and clear operating procedures.
For businesses, digitisation is not simply a matter of replacing a paper form with an electronic one. Data has to remain accurate across the parties involved, information must reach the right system and operators need clarity about what to do when a technical issue prevents the intended process from being completed.
This is where integrated trading and logistics workflows can help.WasteTradeconnects material buyers and sellers withاللوجستياتوcomplianceprocesses, giving businesses a more coordinated way to manage the commercial side of recyclable material movements. Better-aligned information and clearly assigned responsibilities can reduce preventable errors and make it easier to manage the parts of a transaction within a company's control.
Such tools cannot repair DIWASS itself, guarantee regulatory approval or remove statutory obligations. Reliable trading platforms and reliable regulatory infrastructure need to work alongside each other.
What Needs to Happen Next?
The European Commission and relevant authorities need to prioritise documented technical faults, communicate clearly about their resolution and provide businesses with practical guidance when normal procedures cannot be completed.
Recycling Europe's proposed extension until at least 1 July 2027 deserves consideration alongside evidence of system reliability and the operational experience of businesses handling real shipments. Any extension or alternative procedure must be formally confirmed before companies can rely on it.
Operators should meanwhile review their registration, documentation, data-sharing arrangements and responsibility for submission. Exporters, brokers, carriers and receiving facilities need a shared understanding of who supplies each piece of information and how problems will be escalated.
The objective should not be to abandon digitalisation. It should be to make it work as intended, with safeguards and implementation arrangements that reflect the realities of moving recyclable materials commercially.
For the recycling industry, a digital shipment record is only useful if the system can reliably accept it, share it and make it available to the people who need it.
WasteTrade welcomes feedback fromشركات إعادة التدوير, traders, exporters, importers and logistics partners about their experience of DIWASS and the practical challenges of cross-border recyclable material trading. Those operational experiences matter as the industry prepares for the next implementation stage.
