RENTRI is not working properly: what to do with the digital FIR after Directorial Decree 254/2026

What has changed with Directorial Decree 254/2026

Before the new decree, safety procedures already existed for the unavailability of the RENTRI services, for temporary Internet connectivity problems and for the unavailability of the digital authentication services in the cases provided for.

Directorial Decree 254/2026 adds a different situation: the service exists and is not completely unavailable, but one or more functions needed to manage the digital FIR are degraded, limited or not fully operational.

It is an intermediate case, designed for those malfunctions that can concretely prevent the activity without bringing the whole system to a standstill.

The measures are not a free pass for the paper consignment note

The measures referred to in the Annex do not constitute a free pass for the use of the paper consignment note: they are a derogation, limited to the individual FIR and to the duration of the degradation condition, from the principle whereby the format chosen at the outset by the producer or holder binds the whole chain.

Recourse to these measures is allowed only to the operator who, at its own stage of responsibility, is unable to use the RENTRI services supporting the management of the digital FIR in the presence of a temporary degradation of those services.

Be careful: if the problem arises from a cause within the business, you are not covered by this procedure and the derogation does not apply.

Saying “RENTRI is not working” is not enough

To use the procedure it is not enough for the operator to perceive the system as slow or unstable: there must be evidence of the degradation attributable to the RENTRI services, because the evidence will later have to be attached to the declaration.

The decree states what is meant by evidence: not just any screenshot of a technical problem, but evidence generated by the RENTRI system or by the company management software (the interoperability service). In practice:

• specific response codes and messages returned by the endpoints of the interoperability services (APIs);
• error messages displayed in the reserved area of the RENTRI portal or in the mobile app dedicated to the digital FIR.

RENTRI degradation or a problem inside your own business?

It is important not to confuse different situations. A problem with the company PC, with internal management software or a user error does not automatically become “RENTRI degradation”: Directorial Decree 254/2026 concerns a malfunction of the functions of the RENTRI services.

However, other procedures governed by Directorial Decree 25/2026 also exist for specific cases of temporary unavailability of the Internet connection or of the digital authentication services, when the problem is outside the operator's control and does not arise from negligence.

For this reason, before applying an emergency procedure, you must establish which event has actually occurred.

Three operating situations covered by the decree

Directorial Decree 254/2026 governs three main cases:

• inability to issue the digital FIR;
• inability to update the digital FIR during transport;
• inability to update the digital FIR on acceptance at the recipient's premises.

Scenario 1 — I cannot issue the digital FIR

If the degradation prevents the FIR from being completed, issued or signed correctly, a stamped paper FIR may be used. Operationally:

• collect evidence attributable to the RENTRI degradation: this means evidence generated by the RENTRI system or by the company management software (the interoperability service), that is specific response codes and messages returned by the APIs, or error messages displayed in the reserved area of the RENTRI portal or in the mobile app dedicated to the digital FIR;
• use a stamped paper FIR;
• complete the consignment note in the ordinary way;
• enter in the annotations the wording required by the decree (the wording is to be entered in Italian, as laid down by the procedure): “FIR emesso in modalità cartacea ai sensi di quanto previsto dall'Allegato 1 al decreto direttoriale n. 254 del 9 settembre 2026”;
• manage the FIR according to the rules of Article 6 of Ministerial Decree 59/2023;
• then complete the declaration required by Directorial Decree 254/2026;
• send the declaration by PEC to dit.rentri@pec.it by the first working day following the end of the degradation condition, together with the evidence collected;
• keep the declaration sent to RENTRI.
• The ordinary obligations to transmit the FIR data to RENTRI do not apply to that FIR.

Scenario 2 — The lorry has already left with a digital FIR

The situation changes when the FIR has been regularly issued in digital form but has to be updated during the journey. This may happen, for example, in the event of transhipment, a technical stop or another event requiring an addition. If the RENTRI degradation prevents the operation from being carried out digitally, the carrier may:

• use the printout of the digital FIR;
• enter the necessary data on the printout;
• add the date and a handwritten signature;
• enter in the annotations the wording required by the decree (to be entered in Italian, as laid down by the procedure): “FIR gestito in modalità cartacea ai sensi di quanto previsto dall'Allegato 1 al decreto direttoriale n. 254 del 9 settembre 2026”;
• continue managing that FIR under the paper regime;
• notify the change of format;
• complete the declaration required by Directorial Decree 254/2026 and send it by PEC to dit.rentri@pec.it by the first working day following the end of the degradation, with at least one piece of evidence attached.
• The ordinary obligations to transmit the data of that consignment note to RENTRI do not apply.

Scenario 3 — The problem arises on arrival at the facility

The third case concerns the recipient. If the FIR is still digital when the vehicle arrives at the facility but the degradation prevents the recipient from completing acceptance:

• the recipient adds to the printout the data within its own remit;
• adds the date and a handwritten signature;
• enters the wording required;
• that FIR continues under the paper regime;
• the notification of the change of format is managed;
• the declaration required is made and sent by PEC to dit.rentri@pec.it, with at least one piece of evidence attached.
• Here too, the ordinary obligations to transmit the data of that FIR do not apply.

A printout of the digital FIR is not normally a paper FIR

This is one of the points requiring the greatest attention: printing a digital FIR does not mean automatically turning it into a paper FIR.

Under normal conditions the digital FIR remains a digital document. The printout may accompany the transport, but it is a representation of the digital consignment note.

Only where the conditions laid down by the emergency procedure are met and the required operations are carried out does that printout become the document used to continue moving the waste under the paper regime.

Is it compulsory to have the printout on board?

Not in absolute terms. During transport, Ministerial Decree 59/2023 allows you to use the printout of the digital FIR or to make the consignment note available on a mobile device in the prescribed ways.

However, with the new emergency system, having the printout physically available is a very useful precaution: if the degradation occurs during the journey, the printout can be updated, dated, signed by hand and used to continue under the paper procedure.

For a carrier who wants to be genuinely prepared for emergencies, relying only on a smartphone is therefore not very prudent.

Should you keep pre-stamped blank paper FIRs?

Yes. The decree suggests that operators should keep in advance a quantity of pre-stamped blank paper FIRs proportionate to their needs.

The reason is simple: if the degradation even prevents the digital FIR from being issued, the paper consignment note must be available before the waste leaves. Finding yourself without usable forms at the moment of the emergency can block the transport.

Does the FIR stay on paper even if RENTRI comes back online?

Yes, but only for that specific movement: the procedure is limited to the individual FIR. If a digital FIR is continued in paper form under the emergency rules, that consignment note completes its own cycle on paper.

Once RENTRI is restored, you can return to ordinary management for new movements.

The declaration by PEC is compulsory

The operator using the procedure must complete and sign the declaration provided for in the Appendix to Annex 1 and send it to dit.rentri@pec.it by the first working day following the end of the degradation condition, attaching at least one piece of evidence of the temporary degradation of the RENTRI services supporting the management of the digital FIR.

Here too you need to be careful: the decree states clearly what is meant by evidence, that is specific response codes and messages returned by the endpoints of the interoperability services (APIs), or error messages displayed in the reserved area of the RENTRI portal or in the mobile app dedicated to the digital FIR.

The declarations may be subject to checks, and the operator must be able to demonstrate the correspondence between the degradation event, the RENTRI evidence, the FIR concerned and the emergency procedure used.

How to notify the change of format

When a FIR started as digital and is subsequently managed as paper, the producer or holder must be informed of the change of format through the services provided by RENTRI. On this point Directorial Decree 254/2026 updates some of the procedures contained in Directorial Decree 25/2026.

The notification can be made using the services made available by RENTRI for returning the copy of the paper FIR, or the specific service available in the Area Operatori or through interoperability.

Must the data of these FIRs be transmitted to RENTRI?

For consignment notes managed through the emergency measures of Directorial Decree 254/2026, the ordinary obligations to transmit the FIR data to RENTRI do not apply.

It is preferable to use this wording rather than speaking generically of a “prohibition to transmit”, because the decree acts on the obligation.

Practical case: a carrier during the journey

A carrier sets off with a digital FIR regularly issued. During the journey an event occurs that requires the consignment note to be updated, and the portal or the service used returns a message attributable to the RENTRI degradation. The carrier:

• keeps the evidence;
• uses the printout of the FIR;
• enters the data of the event;
• dates and signs by hand;
• enters the wording required;
• continues the movement under the paper regime;
• later manages the notification of the change of format;
• files the declaration within the prescribed deadline.
• On the other hand, it must not limit itself to writing something on any sheet of paper, or automatically treat the ordinary printout of the digital FIR as a paper document.

Practical case: a business that cannot issue the FIR

A producer has to send waste out. At the moment of issue the RENTRI service shows a documentable degradation that prevents the consignment note from being created or signed.

Where the conditions of Directorial Decree 254/2026 are met, a stamped paper FIR may be used. This is why it is important for the business to have already prepared a small stock of paper forms: waiting for the emergency to obtain them may mean having to postpone the transport.

Mistakes to avoid

• Misunderstanding what counts as evidence: any screenshot of a technical problem is not enough, you need evidence generated by the RENTRI services or by the company management software (codes or messages from the APIs, error messages from the reserved area or from the digital FIR app).
• Confusing any slowness with RENTRI degradation: an event that concretely prevents the activity from continuing is required, and evidence attributable to the RENTRI services must be available.
• Using Directorial Decree 254/2026 during maintenance: maintenance is expressly excluded from the scope of the procedure.
• Confusing degradation and serious unavailability: they are different situations and have different procedures.
• Treating an ordinary printout of the digital FIR as a paper document: the printout becomes usable under the paper regime only within the procedures provided for.
• Forgetting the PEC: emergency management does not end with delivery of the waste, the declaration must also be completed.
• Not keeping the evidence: without evidence of the degradation it becomes difficult to show why the procedure was used.
• Waiting for the emergency to obtain paper FIRs: better to have them already available and stamped.

What a business should do today

The best solution is not to learn the procedure during the emergency. The business should already have:

• an internal procedure for distinguishing degradation, unavailability and problems inside the business;
• stamped paper FIRs available;
• simple instructions for drivers and facility staff;
• a way to keep screenshots and error messages;
• the PEC address and a declaration template easily to hand;
• a person tasked with completing the obligations on the first working day following.

Legal sources

• Directorial Decree No. 254 of 9 September 2026 — temporary degradation of the RENTRI services supporting the digital FIR;
• Directorial Decree No. 25 of 5 February 2026;
• Directorial Decree No. 319 of 30 October 2025;
• Directorial Decree No. 143 of 6 November 2023;
• Ministerial Decree of 4 April 2023, No. 59;
• RENTRI institutional portal.
• Legislation checked on: 11 September 2026.