The Annex VII form and the two-working-day deadline

In detail

Who fills in what

All undertakings involved in the shipment complete the Annex VII form at their points and make the information available electronically, also during transport Art. 18(4). If the arranger is not the original producer, it makes sure that, where practicable, the producer signs as well.

• The arranger is responsible for completing it and for the shipment matching the form (BMLUK).
• The carriers add only the means of transport, the date of transfer and their signature in fields 5a to 5c, just before the start and electronically (BMLUK; lesson 4.2). If a haulier brings in a subcontractor without saying so, field 5a is no longer right. The BMLUK advises excluding subcontractors by contract or agreeing on a duty to correct the forms.
• The facility confirms receipt and, later, completion of the recovery (lesson 2.4).

The deadline

The arranger completes the form as far as possible no later than two working days before the shipment starts. The actual quantity, the carriers and, where applicable, the container number may be submitted until before the start Art. 18(5). The BMLUK's examples: for a transport on Thursday, report by Tuesday at the latest; for a transport on Tuesday, by the Friday before. Lesson 4.3 explains how to count working days.

Postponing, cancelling, leaving early

• Reported transports can be postponed and cancelled (BMLUK, according to the Commission).
• Leaving early, within the two-working-day period, is not allowed (BMLUK).
• The transport date can be corrected until the transport starts. In the end, the report must match the day of delivery.

An illegal shipment, or only a reporting breach?

The BMLUK distinguishes: if a delivery arrives on a different day than reported, it is an illegal shipment, judged especially strictly if it arrives before the announced date. That is because a Green List shipment that doesn't match the information in the Annex VII document is illegal Art. 3(26)(g). If only the two-working-day deadline was missed, it is not an illegal shipment but a breach of the reporting duty, which arranger and carrier answer for; the waste can be accepted.

When there is no connection

If the information can't be made available online during transport, the arranger and the carriers make sure it is in the vehicle some other way, on paper for example, consistent with what was made available electronically. The arranger then submits any changes made during transport through the system Art. 18(6).

Until DIWASS is fully working, a transition applies to the reports: see lesson 2.5.