Over the last decades, the European recycling industries have drastically evolved by modernizing and constantly innovating to turn more waste streams into new resources. By doing so, the sector has contributed to the development of new technologies and automated equipment made in Europe and exported around the globe. The European regulatory framework has accompanied these changes thanks to ambitious targets and a meaningful waste hierarchy. However, the recycling sector continues to be subject to a complex and ever-growing EU regulatory framework, which affects its activities. To ensure a competitive European recycling sector, which is part of a global industry, EuRIC advocates clear, effective and smart European policies which:
- Incentivise recycling across the value chains;
- Minimise regulatory burdens on recyclers, in particular on SMEs;
- Guarantee an open and fair competition within Europe and with the world to foster a genuine internal recycling market.
EuRIC also advocates positive measures to ensure a consistent implementation of existing legislation across Europe.
EuRIC's Position on the Impacts of Biodegradable Plastics on Circularity
In regard to the forthcoming Commission’s policy framework, related to bio-based, biodegradable and compostable plastics, EuRIC is pleased to share its position about biodegradable plastics, especially on packaging, and with this document help to clarify some questions regarding the impact and challenges of these plastic types on mechanical recycling (incl. opportunities and recommendations).
Nowadays, fossil-based plastics account for the biggest market share and correct plastic management of this common plastics through mechanical recycling offers an opportunity for material circularity - with still a lot of untapped potential1- while curbing plastic waste and minimizing environmental pollution and combating global warming.
As an alternative to solve plastic waste accumulation through recycling, which applies for both fossil-based and bio-based plastics, there are materials in the market like biodegradable plastics (BDPs), especially used in packaging applications, which aim to tackle the problem of plastic waste accumulation at the production phase. However, and despite the fact that BDPs can theoretically shorten the life cycle of plastics, due to lack of infrastructure and a misconception by the consumer about what biodegradability means, most of BDPs are not properly disposed at their end-of-life (EoL) and they are mixed with traditional plastics. This creates a negative impact on the efficiency of conventional plastic sorting systems across EU and jeopardizes recyclates quality because BDPs - contrary to bio-based plastics - do not fit in the sorting and recycling infrastructure and therefore they do not contribute to but hamper transitioning towards a circular economy for plastics. Therefore, BDPs should not be considered as a silver bullet to the plastic waste problem but just as another waste to be properly managed. Even when BDPs are properly disposed at their EoL, problems may rise during composting, which is the reason BDPs are not allowed in the bio-waste of many Member States. As a consequence, BDPs from packaging are removed from the bio-waste and incinerated at waste to energy plants.
For the correct functioning of the circular economy, it is EuRIC’s recommendation that all plastic products must be designed according to the design-for-recycling principles, which means that the collection, sorting and recycling of the material must be possible within the existing infrastructure and this needs to be determined by extended producer responsibility (EPR) schemes. For BDPs or other new types of polymers of which their production is more environmentally friendly than conventional plastics, it is necessary to manage their EoL in an efficient manner to effectively protect the circular economy and the environment because, unless very limited exceptions, right now, choosing for BDPs in the name of environmental protection is just wishful thinking.
1 In Europe, approximately 29 million tonnes of plastic waste were collected in 2018, from which around 9 million tonnes of post-consumer plastic waste were sent to recycling.
EuRIC Reaction to the Proposed Batteries and Waste Batteries Regulation (Batteries – modernizing EU rules)
- Recycled content should be made mandatory to all battery categories
- Consistent and further clarified definitions are needed
- Inclusion of Voluntary Agreements
- Removability and replaceability of all batteries and not only of portable ones (with batteries mechanically bounded and easily accessible)
- Consistent adjustment of labelling obligation for all information until 2023 and information provided for all levels of batteries
- Introduction of a clear colour coding, depending on batteries’ types
- Introduction of specific waste code number for the different types of Li-ion Batteries
- Obligation for producers to periodically investigate in which waste streams batteries are disposed of and act upon it
- Continuously adapting to BATs is not feasible for treatment facilities due to constant technological advancement
- End-of-life information to always be made available in a free and public website and be complemented, if necessary, upon request
EuRIC Press Release to Support Continued Use of Tyre-derived Granular Infill
EuRIC REAFFIRMS ITS COMMITMENT TO THE OBJECTIVES OF THE CIRCULAR ECONOMY AND CALLS UPON THE COMMISSION TO SUPPORT CONTINUED USE OF GRANULAR INFILL MADE FROM RECYCLED TYRES
- EuRIC warns about the questionable future of 527,000 tonnes of end-of-life tyres which may be annually incinerated, or worst stockpiled and illegally landfilled, if a ban on granular infill is adopted.
- EuRIC demands that tyre recycling into infill for artificial turfs is regarded as a strategic objective of the new Circular Economy Package considering the substantial environmental benefits of this application.
- EuRIC reiterates that preserving a circular economy for tyre recycling into artificial turf infill can and must go hand in hand with reducing microplastics’ releases through standardized risk management measures.
The European Recycling Industries’ Confederation (EuRIC) representing the collective interests of the European mechanical end-of-life tyre (ELT) recycling industry, calls upon the Commission to strengthen its commitment to the Circular Economy.
With the release of ECHA´s opinions on infill materials, now it is up to the Commission to take a decision on what measures to follow as regards this application.
EuRIC warns about the negative impacts that some of the options covered, including a complete ban, may have on the environment and on the objectives of speeding the transition towards a more circular economy.
EuRIC has raised concerns over the future of 527,000 tonnes of end-of-life tyres annually recycled into artificial turfs, warning on the risks of them being mismanaged and causing a huge environmental impact in the event of a proposal to ban infill materials.
EuRIC Mechanical Tyre Recycling Branch (EuRIC MTR) has expressed its support to the objectives of the European Commission, and it is confident that preventing a mismanagement of waste tyres will be at the focal point of their decision when taking into consideration the different options proposed by ECHA. Especially, knowing that there are no alternatives for an environmental sound management of the aproximatelly 50,000,000 tyres units annually recycled and turned into infill material.
Yet, preserving a circular economy for tyre recycling into artificial turf infill can and must go hand in hand with reducing microplastics’ releases through standardized risk management measures such as those described in the European Standards Committee (CEN) technical report CEN/TR 17519.
“State of the art mechanical tyre recycling entirely supports the European Green Deal and the new Circular Economy Action Plan” stressed Poul Steen Rasmussen, President of EuRIC MTR Branch and Group CEO Genan. “The processing of ELT tyres into rubber is not only the most resource-efficient option but also the most climate-efficient one because for each tonne of ELT recycled as infill for artificial turf pitches- the climate is spared 700 kg of CO2 when compared with co-incineration” he added.
EuRIC entirely supports the efforts of the European Commission to minimise the release of microplastics in the environment.
“We are sure that cutting down microplastics releases into environment and the circular economy goals can coexist and achieve the objective of minimising the environmental impact of microplastics, which is why we encourage the European Commission to introduce risk management measures to avoid unintended releases of microplastics into the environment, one of the options assessed by ECHA.”
EuRIC has expressed their support towards the sustainable recycling system of end-of-life-tyres which they define as “well-functioning and mature circular value chain which directly contributes to the recovery of thousands of tonnes of critical raw materials such as rubber, and also steel and textile fibres, saving substantial amounts of energy and water, and preventing greenhouse gas emissions. Together with millions of euros saved in imports of raw materials and generating thousands of jobs”.
Read more about tyre recycling: EuRIC’s brochure on mechanical tyre recycling
EuRIC Updated Position on EPR Schemes for Textiles
In 2020, the volume of separate collected textiles in the EU-27 was estimated to be between 1.6 and 2.5 million tons (MT). What is currently a self-financing system through revenues generated by the preparation for re-use and the marketing of second-hand textiles will drastically change in the future. For example, 87% of German collectors have reported an average decline in quality due to the increased presence of impurities or inferior quality of the textiles they receive. It is therefore much needed to encourage the development of further markets for used textiles but also recycled fibres. One of the policy tools to strengthen the textile re-use and recycling market is an extended producer responsibility scheme (EPR) as introduced by the Waste Framework Directive 2008/98/EC (WFD). Extended producer responsibility schemes are a set of measures taken by Member States to ensure that producers of textiles would bear the financial responsibility for the management of the waste stage of the textile’s life cycle.
 GftZ: Hintergründe und Strategien zum Aufbau eines Systems für eine „Erweiterte Produzentenverantwortung für Textilien“ (2019)
 Bvse Textilstudie (2020)
EuRIC Circular Metals Strategy
Reaching climate neutrality by 2050 will require drastic changes throughout all value chains, in particular for energy-intensive industries such as metal production. Thanks to their intrinsic properties and market value, discarded metals have been recycled for decades and used to produce new ferrous and non-ferrous metals again and again.
Metal recycling is a must to achieve the climate and circular economy targets set by the European Green Deal and the new Circular Economy Action Plan. Metals are essential in both products and systems which are essential to a low-carbon economy and everyday products. Compared to primary production, steel, aluminium or copper recycling save respectively 58%, 92% and 65% of CO2 emissions and spare primary raw materials often extracted outside Europe where much lower standards apply.
Despite enormous environmental benefits, substantial bottlenecks keep hampering metal recycling in Europe.
- The first one has to do with the fact that Europe’s industry remains mostly linear with only 12% of the materials it uses coming from recycling. As a result, in Europe, the supply of metal scrap from recycling meeting industry specifications often exceeds the demand and remain under-utilised in metal production.
- The second one relates to the fact that commodity prices still fail to internalise the massive environmental benefits of metal recycling. There is in EU legislation no incentive that rewards metal recycling lower-carbon and energy footprint when compared with primary raw materials (often extracted outside Europe).
- The third one is rooted in European waste legislation which hinders more circularity. Metal scrap is a valuable commodity, with a positive environmental footprint, which should not be classified as waste but as secondary raw materials. In addition, a number of procedures pertaining to cross-border shipments or to permitting remain far too burdensome to incentivize circular metal value chains.
For Cinzia VEZZOSI, President of EuRIC, “Time has come to lay down a more ambitious strategy to boost metal recycling in Europe and support the entire metal value chain, which is a backbone of any modern economy”.
She stressed in particular the absolute need to set up framework conditions and incentives that steers metal recycling and metal production from secondary raw materials by rewarding their environmental benefits. “This should be one of the priorities of the EU Recovery Plan”. Taking the example of steel, “it is key to support value chains currently striving to migrate from current blast furnaces which use primary iron ore and coal, to electric arc furnaces which use recycled steel and can use power from renewable sources. Low-carbon impact steel and metals in general are not only vital to achieving climate neutrality, it is also instrumental to compete better in a rapidly changing market”, Vezzosi added.
Of equal importance is the need to simplify legislation applicable to circular value chains. “To create a well-functioning EU market for secondary raw materials, metal scrap meeting industry specifications shall no longer be classified as waste. We need to align legislation which hampers the transition towards a more circular economy with overarching EU policy objectives embedded in the Green Deal otherwise circular frontrunners won’t be able to deliver”, she stressed.
Last but not least, guaranteeing free, fair and sustainable trade is more important than ever. We need to refrain from setting any trade restrictions negatively impacting metal scrap processed to industry specifications which operates on an inherently global market. Forthcoming measures shall focus on better pricing carbon-intense imports to level the playing with low-carbon products made of recycled materials.
EuRIC reaction to the IIA of the Designing mobile phones and tablets to be sustainable initiative
Improving the design of products is a pre-condition to transition towards a circular economy. Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European RecyclingIndustries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for thePeriod 2019 -2024”, 80% of products’ environmental impact are determined at a design stage.
Although the above-mentioned fact is also stated in the Circular Economy Action Plan 2.0 (CEAP), the vast majority of products placed on the EU market – and not only – are still designed without any consideration for their end-of-life stage. Design for circularity is therefore of an outmost importance to move towards a more circular economy and needs to be extended to all products’ categories, including mobile phones and tablets.
EuRIC thus fully supports the necessary Designing Mobile Phones and Tablets to be Sustainable Legislative Initiative to keep the already exploited resources in the market for as long as possible by connecting the dots between the design and end-of-life (EoL) phase of products.
Read the top priorities identified by EuRIC in the linked document below.
EuRIC Annual Report 2020
We are pleased to share with you EuRIC's first annual review featuring its 2020 achievements and future commitments.
In 2020 we expanded, reached new heights and continued pushing ourselves and those listening to our growing voice with one common goal: to get one step nearer to closing the loop.
Our plans for 2021 are just as ambitious as our increased responsibilities. We are confident that with the relentless work of the EuRIC Secretariat and EuRIC Members, our joint efforts will make a lasting and positive impact on the decision making in Europe.
EuRIC Comments on the Industry Voluntary Agreement to improve environmental performance of imaging equipment placed on the European market
Following the publication of a draft Voluntary agreement (VA) v.5 as of 7th October 2020, toFollowing the publication of a draft Voluntary agreement (VA) v.5 as of 7th October 2020, toimprove the environmental performance of imaging equipment placed on the EuropeanMarket, and in addition to the comments made on previous drafts, EuRIC is pleased to sharethe following comments on the new draft VA.
EuRIC Position for a Revision of the Waste Shipment Regulation Supporting the Circular Economy
The Waste Shipment Regulation (WSR) is, as rightly identified in the new CEAP, a pivotal piece of legislation with provisions that need to be aligned with the overarching objectives of transitioning towards a circular economy. Hence, the revision offers the opportunity to make both needed adjustments to fix lasting bottlenecks and radical changes to address long-term obstacles rooted in outdated obligations.
It is time to align the procedures set by the Waste Shipment with the pace of Circular value chains. A paradigm shift requires to treat waste in legislation as a resource enabling the circular economy, stressed Peter FLORMANN, Chair of EuRIC Waste Shipment Task Force.
This paper goes beyond simply identifying lasting problems rooted in waste shipment procedures. It provides detailed solutions to support a revision of the WSR that enables the creation of a well-functioning European market for secondary raw materials. EuRIC calls in particular for
- Simplified waste shipment procedures, be it for green listed waste and waste subject to prior informed consent (PIC) procedure, which make an extensive use of the digitalization (electronic procedures);
- Preserving free and fair trade of secondary raw materials which is vital to the competitiveness of the European recycling industry and to speed up the transition towards a circular economy, while leveling the playing field with primary raw materials;
- Accompanying the revision of the waste shipment regulation by binding requirements to boost the use of secondary raw materials in production processes and reward their well-documented environmental benefits in terms of GHG and energy savings.
For Julia BLEES, Senior Policy Officer at EuRIC, closing boundaries has never brought any benefits except distorting markets. While EuRIC entirely supports avoiding unprocessed waste posing an environmental risk to find its way to countries lacking any infrastructure and makes practical proposals in that respect, it is key to ensure that free and fair trade of secondary raw materials remains unhampered. At a time where Europe’s industry remains mostly linear with only 12% of the materials it uses coming from recycling , truly boosting circular value chains in Europe require decisive measures such as binding recycled content targets and incentives supporting the uptake of recycled materials in manufacturing, not trade barriers, she concluded.
Top 5 Priorities of the Recycling Industry for the Period 2019 -2024
By turning waste into secondary raw materials and reducing Europe’s dependency on primary materials, the recycling industry plays a vital role in the circular economy. In addition, recycling saves a substantial amount of CO2 and energy. Recycling is thus a key sector to make Europe the first climate-neutral continent, a key objective of the European Green Deal highlighted by Ursula von der Leyen, the President of the European Commission. Last but not least, recycling is an inclusive industry providing local jobs which rely on a variety of qualifications and cannot be outsourced. Thus, recycling can significantly contribute to Europe’s re-industrialisation by boosting circular value chains. Hence, EuRIC representing the European Recycling Industry, calls for the completion of a competitive internal market for recycling rewarding circular value chains in Europe and beyond, through a set of 5 key measures.