Lesson 2.5 · 4 min

Until 1 January 2027: what applies already and what doesn't yet

Open in the coursewith narrated slides, a checklist to tick off and a quiz

At a glance

Reports only from 2027. According to the BMLUK, the reports under Article 18, paragraphs 5, 8 and 9, are due only for shipments from 1 January 2027.
Carry the new form. The new Annex VII form is completed in full and carried on paper or shown electronically.
Contract and registration. All other duties have applied since 21 May 2026: the new form, the contract and the registration in EDM.
No sanctions until then. Until DIWASS is fully working, the BMLUK will not sanction missing reports.

In detail

Why there is a transition

Several Member States, Austria among them, had asked the Commission to postpone the reporting duties for the Green List. At an expert meeting on DIWASS on 27 March 2026, the Commission agreed (BMLUK).

What the BMLUK concludes

The reports under Art. 18(5), (8), (9), that is the transport report, the confirmation of receipt and the recovery certificate in the system, are due only for shipments from 1 January 2027 (BMLUK FAQ).
Until then the Annex VII form is handled as before: completed in full, carried during the shipment and shown at inspections, on paper or electronically. The new form of Regulation (EU) 2024/1157 is to be used.
Until the system is fully working, there are no sanctions if these reports are missing.
If the system is fully working earlier, the BMLUK will inform businesses in writing in good time, through the trade associations (VOEB, WKO) and on its website.

What has applied since 21 May 2026

the new Annex VII form;
the contract under Art. 18(10);
arrangers only with a seat or establishment in Austria;
keeping the forms with fields 14 and 15, also by the arranger;
registration in EDM with a shipment contact person, for arrangers, facility operators and carriers. According to the BMLUK, registrations can already be inspected.

Where the reports will go

According to the BMLUK's FAQ, businesses with a seat or establishment in Austria must report through EDM/eVerbringung; reporting directly in DIWASS is not permitted. A WasteX interface for Green List reports is planned, with work starting in the second half of 2026. Another BMLUK page still speaks of entering Green List reports directly in DIWASS; what counts is what the BMLUK announces before the start.

Checklist

We have used the new Annex VII form since 21 May 2026.
Until the end of 2026, the form travels with the shipment, completed in full, on paper or electronically.
Registration in EDM with a shipment contact person is done.
We follow the BMLUK's announcements on the start of the reporting duty.
Reporting in EDM from 1 January 2027 is planned.

Quiz

A Green List transport runs on 15 October 2026. What must be in place?

The new Annex VII form, completed in full and carried, and a contract under Art. 18(10)
Only the electronic report in EDM two working days before
Nothing, the new rules only apply in 2027
The old form of Regulation (EC) 1013/2006

Show the answer

The answer is A: The new Annex VII form, completed in full and carried, and a contract under Art. 18(10). According to the BMLUK, only the reports under Art. 18(5), (8) and (9) are suspended until DIWASS is fully working. The new form and the contract have applied since 21 May 2026.

Sources

This lesson's statements rest on:

Not legal advice. What counts is Regulation (EU) 2024/1157 and Implementing Regulation (EU) 2025/1290 in the Official Journal, Austrian law and the BMLUK's guidance (read on 4 October 2026). DIWASS is a system of the European Commission. Not an offer of the European Commission, the BMLUK or the Environment Agency Austria.