The notification procedure for orange and red list waste

Not all waste can cross an EU border with a one-page Annex VII. Waste that is hazardous, mixed, or otherwise on the orange or red list needs prior written notification and consent: the authorities of every country involved must approve the shipment before the first truck moves. Here is how the procedure works and what the digital switch changed.

When notification applies

• Waste listed on the orange list (Basel Annex VIII and related entries), for example many contaminated or hazardous streams.
• Waste not listed on any annex (unlisted waste defaults to the strictest procedure).
• Green-listed waste that is contaminated enough to change its risk profile.
• Mixtures that do not fit a single green-list entry.
• All shipments destined for disposal (where allowed at all): always notifiable, whatever the waste.

The two documents

Annex IA: the notification document

The formal request for consent. One notification covers a series of planned shipments (up to a year, with quantity ceilings) between the same parties over the same route. It carries the notifier, consignee, facility, waste identity, process, packaging, route and insurance details.

Annex IB: the movement document

The document that travels with each individual shipment executed under that consent. It references the notification number and records the actual quantity, date and carriers of that particular movement, plus confirmation of receipt and of completed recovery or disposal at the end.

The procedure, step by step

1. Prepare the notification. Annex IA + supporting documents: the contract with the consignee, a financial guarantee or equivalent insurance covering transport, recovery and possible take-back, and the technical description of the process.
2. Submit to the competent authority of dispatch. Since 21 May 2026 this happens digitally via DIWASS rather than by post or PDF email.
3. Authorities check and consent. Dispatch, destination and any transit countries each review. Consent can come with conditions, and destination and transit authorities have their own clocks.
4. Ship under the consent. Each movement gets its Annex IB, announced to the authorities before departure. Quantities count down against the consented total.
5. Close the loop. The facility confirms receipt and then confirms completed recovery or disposal within the set deadlines. Only then is that movement done.

What the digital switch changed

The mechanics used to be brutally analog: courier envelopes, stamps from three ministries, faxed movement documents. Under Regulation 2024/1157, the notification and consent workflow runs through DIWASS. In practice that means:

• Notifications, consents and movement documents are structured data, not scans. Validation errors surface at submission, not three weeks later in a rejection letter.
• Every authority sees the same live status, so "the fax never arrived" disputes disappear.
• Quantity ceilings are tracked by the system across all movements under one consent.
• Your own records need to match the system exactly: an internal spreadsheet that drifts from DIWASS is now visibly wrong.

Timelines to plan around

Consent takes time even digitally: authorities have review periods and can raise objections, so a new notification is a matter of weeks to months, not days. Build that lead time into contracts, and renew well before an existing consent's period or tonnage runs out. Nothing stops a plant faster than a consented route expiring mid-quarter.