The EVOA, the EU Waste Shipment Regulation (Verordening Overbrenging Afvalstoffen), governs every cross-border movement of waste into, out of and through the EU. If your shipment is waste in the legal sense, the EVOA decides which procedure you follow before a single container moves. There are two routes, and the gap between them is large: a light information obligation on an Annex VII document, or the heavy notification procedure with prior consent. Get the classification right and you ship on a one-page document; get it wrong and you need written authorisation from several authorities first.
The two procedures, briefly
Waste under the EVOA splits along colour. Green-list waste destined for recovery (recycling, reuse, energy recovery) is low-risk and moves under the information obligation. Orange-list waste, and anything destined for disposal, runs through the notification-and-consent procedure: you notify the competent authorities of dispatch, transit and destination, and you may not ship until they consent. This page is about the green-list route, because that is where most clean recyclables sit.
The Annex VII information obligation
For green-list waste going to recovery, the EVOA does not require prior notification or consent. Instead, a completed Annex VII document (Bijlage VII) travels with the shipment from the moment of loading to the recovery facility. It identifies who arranges the shipment, the carrier, the consignee, the recovery facility, the waste type and quantity. Under Article 18 of the EVOA this same document also covers waste sent for laboratory analysis up to 250 kg.
Two obligations sit around that document:
- Before the shipment moves, the person who arranges it must have a legally binding contract with the consignee for the recovery of the waste.
- New under the 2024 EVOA: the person who arranges the shipment must, before transport, request and hold the permit or proof of registration of the receiving recovery facility. You confirm the processor is actually allowed to handle your waste before you load, not after.
No prior consent, then, but real homework. An incomplete Annex VII, a missing contract or an unverified processor turns a green-list shipment into an illegal one, and the ILT treats illegal waste shipments seriously, including return of the load at the arranger's cost.
The new EVOA: Regulation (EU) 2024/1157 and DIWASS
The framework changed. Regulation (EU) 2024/1157 progressively replaces the old Regulation (EC) No 1013/2006 and applies from 21 May 2026. The headline operational change is digitalisation through DIWASS, the Digital Waste Shipment System, the Commission's central platform for submitting and handling waste-shipment paperwork electronically.
There is a practical catch worth knowing before you plan a shipment. Because the technical specifications ran late, the mandatory digital handling of Annex VII through DIWASS is deferred through 31 December 2026. Until then, Annex VII documents may still be completed on paper. The revised regulation also adds a pre-notification step: transports on Annex VII are to be reported a short window before the transport starts. Check the live state of DIWASS with the ILT before you assume paper or digital, because this is moving.
Who enforces this in the Netherlands
The ILT (Inspectie Leefomgeving en Transport) is the single competent authority in the Netherlands for the import, export and transit of waste. It issues consents for the notification procedure, it is the point of contact for the green-list route, and it inspects and enforces at the border and inland. For background on what the ILT covers and how it sits alongside Customs, see Ilt Inspectorate.
The practical trap: carriers refuse waste HS codes
Here is the part that catches shippers out. Even when your shipment is fully EVOA-compliant, the shipping line can simply refuse to carry it. Carrying waste and scrap is a commercial and reputational decision for the carrier, made on top of the regulation, and several lines publish bans by commodity or HS code. The classic refusals are waste-related:
- HS 3915 waste, parings and scrap of plastics
- HS 4707 recovered (waste and scrap) paper or paperboard
- HS 7204 ferrous waste and scrap, plus comparable non-ferrous scrap chapters
This is not theoretical. CMA CGM announced it would no longer carry plastic scrap (HS 3915) on any of its vessels worldwide, and Maersk, Hapag-Lloyd and MSC have all restricted solid-waste and scrap moves to certain destinations. Each line sets its own list, and it changes. So the rule for any waste booking is two checks, not one: confirm the EVOA status and procedure, and separately confirm the carrier's own policy for that HS code and that trade lane before you book. A perfectly legal Annex VII shipment is worthless if no line will load it. See Container Shipping Lines for how to read carrier restriction lists.
How Nexport Logistics handles waste shipments
We run the Customs side and the booking side together, which is exactly where waste shipments need it. We classify the waste, check whether it is green-list or notification, prepare the Annex VII (or run the notification with the ILT where that is the route), verify the consignee's recovery permit, and we pre-screen the carrier's HS-code policy before we book so the load is not turned away at the quay.
Nexport Logistics is a freight forwarder operating under the FENEX conditions, with its own customs declarants, and you track every step in the Nexportal portal. Shipping waste or scrap and not sure which procedure or which line will take it? Email info@nexportlogistics.nl and we'll sort the classification, the Annex VII and the carrier before you commit to a sailing.
Official sources: ILT — Informatieverplichting (Bijlage VII-procedure) · EUR-Lex — Regulation (EU) 2024/1157 · European Commission — Shipments of waste. Related: Ilt Inspectorate · Container Shipping Lines · Customs · Dangerous Goods