Archives: Topics

• • Definition varies across EU Member States and third countries.
  • Operators must confirm how each transit country interprets “transit”, including where shipments only pass through territorial waters.
  • Reference document by the Commission (based on MS feedback) is available for guidance.

• • By signing Block 17 of the notification, the notifier declares that insurance against third party liability is in place.
  • Insurance must cover the entire notification period until certificates under Articles 15(4), 16(5) or 15(5) WSR are issued.
  • Competent authorities may request a copy of this insurance.
  • This insurance is separate from the financial guarantee required under Article 7 WSR.

• • Notifier must immediately notify authorities and consignee of any essential change, including;
    • Quantity
    • Route or routing
    • Carriers
    • Date of shipment
    • Duration of shipment.
  • If changes involve the notifier or authorities, a new notification is required.
  • Modification requests must include all details, documentation and justification.
  • Authorities should reply within 5 working days.
  • ERA is not responsible for delays due to invalid, late, or incomplete modification requests.
  • Requests must be submitted via DIWASS, and for non‑EU authorities also sent by post, fax, or digitally signed email.
  • Discussions on changes must occur via email, as DIWASS only records final approvals or disagreements.

A notification expires if:

• • • The validity date in Block 20 has elapsed; OR
    • All shipments allowed are completed before expiry; OR
    • The maximum permitted quantity is reached early.

Waste must arrive at the facility before expiry of tacit or written consent.

Consent must be withdrawn if:

• • Waste composition differs from the notification;
  • Conditions of shipment are not respected;
  • Waste is not recovered or disposed of as per the facility permit;
  • Waste management contradicts the notification or documents
  • The financial guarantee or contract is terminated;
  • Withdrawal is requested by the notifier.

Consent may also be withdrawn if:

• • A delegated act prohibiting export enters into force;
  • Removal of a country or waste stream from the Article 41 list enters into force.

When consent is withdrawn:

• • Shipment or treatment must stop and Articles 22 or 25 WSR apply.

• • Release can be requested once required certificates under Articles 15(4), 15(5), and 16(6) are received.
  • For interim operations, dispatch and destination authorities may agree to release earlier.
  • Guarantees covering multiple notifications may be partially released for completed or withdrawn notifications.
  • Incorrect certificates causing improper release may trigger liabilities or application of Articles 25(8) and 26(2).
  • ERA will issue an official letter to the bank or insurer to authorise release.
  • Amendments reducing coverage require ERA’s written confirmation; increases or additions do not, but the original amendment must still be submitted.
  • Requests for release must be sent to [email protected].

• • Notification processing fees are non‑refundable and non‑transferable.
  • Requests for refund of unused movement form fees must be submitted to [email protected] within 1 month of dismissal, expiry, or withdrawal.
  • ERA may reject requests received after the deadline.

• • Exports outside the EU are allowed only to audited facilities.
  • The audit must show that the facility manages waste in an environmentally sound manner.
  • The notifier may:
    • Commission an audit: OR
    • Obtain an audit commissioned by another notifier or the facility.
  • The audit must be less than 2 years old at the start of export.
  • Ad-hoc audits are required if compliance concerns arise.
  • Non‑compliance requires immediate cessation of exports and informing authorities.
  • Evidence of all required audits must be included in the notification.
  • An annual public summary of compliance is required from the notifier.
  • Commission’s audit register is available but listing alone does not confirm compliance.

• • The Commission monitors exports to OECD Decision countries.
  • If increased exports or issues arise, the Commission may:
    • Request information from the destination country;
    • Prohibit exports if concerns remain unresolved.
  • When an export ban enters into force, all affected consents must be withdrawn.
  • Prohibitions may later be lifted if evidence supports it.

• • DIWASS is the primary system for all notification and movement document exchanges.
  • Technical support is available via SANTE [email protected].
  • Manuals and video demonstrations are available by the Commission’s through this link.
  • Use of DIWASS is mandatory unless the notifier is outside the EU with no system access.
  • Non‑EU authorities or facilities without DIWASS access must receive documents by post, fax, or digitally signed email.
  • All external exchanges must be mirrored in DIWASS.
  • Acknowledgements of receipt for imports or transits must be shared with authorities lacking system access by post, fax, or digitally signed email.

• • All operators involved in waste shipments (producer, notifier, consignee, facility, carrier) must register.
  • Operators are identified by a mandatory identification number.
  • Where required, the EORI number is the main identification number.
  • Main address must be used during first registration.
  • Operators not required to have EORI must provide their VAT registration number, Voluntary Organisation Number (VO) or e-ID number (as applicable).
  • All additional sites or locations with a different name or address must also be registered.
  • Sites with different identification numbers must be registered as separate operators.
  • First approved user becomes the master user and may add or remove users.
  • Operators must immediately inform authorities of any changes to registered data.
  • Third‑country operators can register via the competent authority of the dispatch/destination in the Member State which in the context of a notification is acting as a competent authority of dispatch/destination.
  • Registration instructions and video demonstrations are available by the Commission through this link.

• • Interpretations of the terms “almost free from contamination and other types of wastes” and “almost exclusively consisting of” laid down in Correspondents Guidelines No.12 on the classification of plastic waste are now legally binding for green‑listed plastic waste.
  • For entries classified under EU3011, contamination and non‑target materials must not exceed 6% of the total weight of the consignment.
  • For entries classified under B3011, contamination and non‑target materials must not exceed 2% of the total weight of the consignment.
  • Operators must ensure proper sorting and homogeneity; exceeding limits may result in reclassification and additional regulatory requirements.