Waste should no longer disappear between the consignment note, the border and the treatment site. From May 21, 2026, the European Union introduced DIWASS - a common electronic system for submitting and exchanging documents for cross-border shipments of waste. Through it, competent authorities and operators should see more clearly who is sending the load, who is receiving it, what the waste is and what treatment is planned.
However, there is an important caveat here. Not all shipments go immediately and completely electronically. For hazardous, mixed and other waste that is subject to prior notification and consent, DIWASS is mandatory. For green-listed non-hazardous waste intended for recovery, the paper procedure remains admissible until December 31, 2026, and the mandatory use of the system for them starts from January 1, 2027. This is the difference between the political message of “fully digital control“ and the real transitional regime.
What enters Bulgaria
The public picture of the movement of waste through Bulgaria is not complete. The daily bulletin of the Ministry of Environment and Water on the incoming quantities was discontinued from January 1, 2025 after the country joined the Schengen area. This means that there is no single public daily flow from which to see in real time what enters and what leaves Bulgaria.
The Regional Inspectorate for Environment and Water in Varna gives a partial but concrete example of the structure of imports. In the planned and extraordinary inspections carried out in 2025, modified combustible household waste and lead waste had the largest share. Transportation of aluminum scrap, oil for technical purposes and plastic waste was also checked. Notification decisions and movement documents were submitted for some of these flows, while others fell into the green list.
The violation often begins before the border
In 2025, the Ministry of Environment and Water identified cases in which packaging waste was transported by carriers without the necessary permits or registration documents, although the final installations had valid treatment permits. The Ministry also points to cases in which the transport was organized through intermediaries or electronic platforms, and the carrier did not have complete information about the nature of the cargo.
This is a significant limitation of the digital trail. The electronic form can show a discrepancy between the sender, carrier, type of waste and recipient, but it cannot itself determine whether the cargo actually corresponds to its description. This requires physical inspection, samples, documents and control of the site.
This is exactly how the data for the 195 joint inspections of the RIEW and the Ministry of Interior, conducted from June 30 to July 10, 2026, should be read. They covered sites for ferrous and non-ferrous metals, car dismantling, waste treatment and sites with information about unregulated activity. The result is 19 acts and 88 mandatory prescriptions. Most often, work without a permit, unregulated storage, treatment and disposal were established. The data is indicative of waste control in general, but does not in itself prove an effect of DIWASS on cross-border shipments.
The trail goes digital, control remains human
The European Commission expects DIWASS to shorten administrative procedures, provide immediate access to shipment data and make it easier to detect illegal trafficking. “A fully functioning digital system across the EU will help Europe take control of its own resource flows“, said Environment Commissioner Jessica Roswall.
Whether this will happen in Bulgaria will depend not only on the software, but on whether the data will be used to target checks on risky shipments and operators. The next important deadline is 21 November 2026, when the ban on the export of plastic waste from the EU to non-OECD countries comes into force. From 21 May 2027, new rules for waste exports to third countries will also apply.
The electronic trail can close one of the old gaps - the lack of common, accessible and timely information. But it will not make waste a transparent entity in itself. As long as import and export data are not publicly comparable and on-site inspections remain crucial, digitalization will be more of a new tool for control than proof that control is already working.
Sources: environment.ec.europa.eu, moew.government.bg, riosv-varna.bg