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 Reaction to the Inception Impact Assessment on the revision of EU legislation on REACH
The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy. Bridging the various phases of products’ life cycle in relation to chemicals to achieve safe products and non-toxic material cycles, including through substitution, is of paramount importance to support a safe circular economy, given the lasting problems posed by legacy substances at recycling stage, regardless of the separation and sorting technologies used for material recovery purposes and streams at stake (WEEE, packaging, ELVs, tyres, textiles, batteries, etc.).
EuRIC finds the problem that the above initiative aims to tackle very relevant not only for downstream users of chemicals but also for companies who recycle – a large number of small, medium and large enterprises scattered across the EU whose role in the Circular Economy journey is considered of an utmost importance.
Thus, the top priorities identified by EuRIC – which will further ameliorate the aforementioned legislative framework - can be found in this paper.
Revision of the Waste Shipment Regulation - One size fits all export restrictions can end EU circular economy ambitions
The Waste Shipment Regulation (WSR) is a key piece of legislation in the move towards circular value chains. Burdensome procedures and lack of harmonisation rooted in the current regulation give an edge to linear value-chains, instead of boosting waste shipment for recycling and the marketing of raw materials from recycling (RMR).
However, the proposals released today by the European Commission pose major problems that will jeopardise Europe’s circular economy ambitions.
European recyclers entirely support the objective to better tackle illegal waste trade and exports of unprocessed waste to countries lacking the infrastructure for proper treatment. Such exports not only threaten human health and the environmental, they also are a major economic loss for Europe’s recycling industry.
Yet, by failing to distinguish between trash and RMR that meet strict quality specifications, the proposal falls short of levelling the playing field with extracted raw materials, which are not subject to any such constraints in EU law.
“Free, fair and sustainable trade of RMR is absolutely essential to boost high-quality recycling in Europe and ensure the recycling industry remains competitive,” says Emmanuel KATRAKIS, Secretary General of EuRIC.
“Europe’s recycling industry is powered by SMEs and large companies, who directly employ over hundreds of thousands of Europeans, and indirectly many more. As stressed in the recent letter signed by 300 European national recycling federations and companies, subjecting RMR - which are still classified as non-hazardous waste - to export restrictions will, in the absence of secured end-markets for circular materials in the EU, pose a vital threat to European recyclers, be them SMEs or large multinational companies, and undermine the creation of green industrial jobs in Europe.”
“With only 12% of raw materials used by the EU’s industry coming from recycling, binding requirements to use RMR in industrial value chains are urgently needed to ensure the excess supply of RMR, that would remain captive in Europe under these proposals, don’t end up in landfills. In the Commission’s toolbox to boost the transition towards a circular economy, binding recycled content targets have proved to be the most efficient yet least utilised instrument, with the exception being for plastic packaging.”
EuRIC looks forward to working with the European Parliament and Council to better distinguish trash from RMR and ensure a fit-for-purpose regime applies to curb exports of problematic waste streams without closing frontiers to the most resource-efficient and carbon-neutral materials needed to achieve EU’s and global climate objectives.
EuRIC also looks forward to working with the co-legislators to further increase the ambition of proposed measures to ease intra-EU waste shipments for recovery and end-use in circular value chains, which are essential to achieve a well-functioning market of raw materials from recycling and level the playing field with extracted raw materials.
EuRIC reaction on the environmental impact of photovoltaic modules, inverters and systems
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 Recycling Industries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024”, 80% of products’ environmental impact are determined at a design stage. Although the above-mentioned fact is also stated in the new Circular Economy Action Plan (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 of an outmost importance to move towards a more circular economy and needs to be extended to all products’ categories, including photovoltaic modules, inverters and systems. Improving the design of products is a pre-condition to transition towards a circular economy.
EuRIC thus fully supports the necessary ‘Environmental impact of photovoltaic modules, inverters and systems’ legislative initiative to keep the already exploited resources - used for the manufacturing of photovoltaics modules, inverters and systems - in the market for as long as possible while at the same time significantly reducing the negative environmental impact that the in-question products are generating when are not designed to support and promote sustainability.
EURIC and ETRMA call for the development of EU-wide End of Waste criteria for the End of Life Tyre-derived Rubber Waste Stream
ETRMA and EuRIC are committed to support the European Commission in developing EU harmonized End of Waste (EoW) criteria.
The rubber supply chain is ready for the next step in the advancement and uptake of the recycling of ELT-derived Rubber.
This will secure that trade across European borders happens normally in equal conditions and with equivalent opportunities across borders, while reducing the administrative burdens associated with trading.
Since many regulations, like Declarations of Performance for construction products, or the REACH restriction of chemical substances only apply once the material has ceased to be waste, EU harmonized EoW criteria will also secure the material’s accountability for safety and quality criteria.
All this is of key importance to increase the uptake of ELT derived rubber in the manufacture of new rubber products for high-value end-use markets.
ETRMA and EURIC believe that securing a common starting point for end-of life tyres rubber to cease to be waste is essential to foster the circular economy in Europe. This can only be achieved with a European End-Of-Waste criteria, that is translated in a legal text, applicable in all Member States. This will add trust to the market, increase investors security and boost the research and development on innovative solutions of this valuable material.
Revision of the ELV and 3R Type Approval Directives
The European Recycling Industries’ Confederation (EuRIC), welcomes the initiation of the Impact Assessment andrevision of both Directive 2000/53/EC on End-of-Life Vehicles (ELVs) and of the Directive 2005/64/EC on the type approval of motor vehicles with regard to their reusability, recyclability, and recoverability (3R type-approval).
EuRIC - via its various branches1 - represents Authorised Treatment Facilities (ATFs) and the vast majority of ELV recycling facilities (shredders and post-shredder installations) which recycle ELVs in Europe, and producers of plastics, rubber and metal recyclates incorporated into new automotive vehicles/parts. The Confederation therefore has a strong interest in the revision of the ELV and 3R Type-Approval Directives, and call upon the European Commission to ensure the highest level of environmental ambition is achieved as a result of this revision process. For the recycling industry, several key concerns must be addressed to build upon the success noted within the European Commission’s Evaluation report on the state of ELV treatment in the EU.2 These concerns include: missing vehicles, the eco-design of new vehicles to allow for future recyclability, recycled content, and free and fair compensation for the implementation of the Circular Economy.
This paper outlines EuRIC’s position in regard to the revision process ahead for both Directives, with a focus on key measures to be addressed.
1 European Shredder Group (ESG), European Plastics Recycling Branch (EPRB), Mechanical Tyre Recycling branch (MTR), European Shredder Group (ESG), European Plastics Recycling Branch (EPRB), Mechanical Tyre Recycling Branch (MTR), European Ferrous Recovery and Recycling Branch (EFR), European Non-Ferrous Metal Trade and Recycling Branch (EUROMETREC).
2 European Commission (2021) Evaluation of Directive (EC) 2000/53 of 18 September 2000 on end-of-life vehicles.
European recyclers warn that restricting exports of raw materials could end the Circular Economy
Nearly 300 European national federations and companies from the recycling industry have issued a powerful warning to European Union leaders over the potentially disastrous effects of a blanket restriction on exports of Raw Materials from Recycling (RMR) in the upcoming Waste Shipment Regulation (WSR).
RMR are currently labelled as non-hazardous waste under EU law and would therefore be impacted by any regulation that issues a blanket ban on waste.
In fact, RMR are not waste but high-quality commodities with a green carbon footprint. They are materials recovered from old products that go into making new ones and as such are an essential component of Europe’s - and the international community’s - circular economy.
Addressed to the Executives of the European Commission, the European Parliament and the Slovenian Presidency of the Council, the letter calls for a clear distinction in the legal regime between “problematic waste streams” and RMR, meeting quality specifications.
While European recyclers entirely support restrictions on exporting unprocessed waste, like electronic waste and end-of-life cars, to places that lack infrastructure for proper treatment, RMR that can be used to substitute extracted raw materials should not be made subject to rules equivalent to export restrictions.
“RMR are intrinsically climate-friendly and circular materials, which are priced and traded globally as commodities. European recyclers are supplying quality materials to both the European industry and globally. Subjecting RMR - which are still classified as non-hazardous waste - to export restrictions will pose a vital threat to European recyclers, be them SMEs or large multinational companies, in the absence of secured end-markets for circular materials in the EU. They will result in massive green job cuts and put a lasting brake on the growth of one of the most dynamic industries in Europe, for no environmental gains. Worse still, with unhampered imports of extracted raw materials in Europe, the competitiveness of RMR will drop and thus the incentive to properly collect, recycle, and invest will be lost, putting at risk the ability to achieve present recycling targets set by legislation”, stressed Cinzia Vezzosi, President of EuRIC.
With only 12% of raw materials used coming from recycling, the EU’s industry remains mostly linear, as opposed to circular, the co-signatories urge the EU to ensure that:
- Export restrictions foreseen in the revised WSR solely target problematic waste streams: a “one-size-fits-all” solution whereby no distinction is made between untreated problematic waste streams and RMR that can be used directly in circular value chains will run against the very objectives of the EU Green Deal;
- Free and fair trade of RMR, which is essential to the competitiveness of the European recycling industry, is upheld: restricting exports of raw materials meeting quality specifications based on their waste classification will significantly impact the competitiveness of the European recycling industry;
- A stable legislative framework with a proper classification for RMR and incentives is implemented to reward the environmental benefits of circular materials and mandate their use in products.
Importance of free, fair and sustainable trade for commodity-grade metal scrap
Europe’s metal recycling industry is one of the fastest growing industries, providing local, non-outsourceable jobs. Composed of SMEs and large players, it offers a unique infrastructure of facilities and processing plants spread all over Europe. Metal recyclers supply steel mills, smelters and foundries located in and outside Europe with commodity-grade metal scrap from recycling, thus playing an essential role in the circularity and climate-neutrality of metals.
Given their intrinsic properties, metals are indefinitely recyclable, making them circular by nature. In addition, the recycling of end-of-life products containing metals is climate-efficient. When compared with raw materials extraction often mined in non-EU countries subject to lower human rights, health and environmental standards, metal recycling saves massive amounts of CO2. Steel, aluminum and copper recycling save respectively 58%, 92% and 65% of CO2 emissions, to name only a few. However, prices still fail to reward these environmental benefits, thus EuRIC calls for incentives to correct this market failure and direct investments in circular value chains. More importantly, metals are valuable making them unlikely to be littered or removed when reaching end-of-life stage but collected and recovered to close new material cycles. Thus, unwanted metal waste is not a problematic stream.
EuRIC welcomes the European plastics producers’ call for a 30% mandatory EU recycled content target by 2030
The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the call made by Plastics Europe for a mandatory EU recycled content target for plastics packaging of 30% by 2030, and looks forward to working with the entire packaging value chain to support an ambitious revision of the Packaging and Packaging Waste Directive (PPWD).
As consistently stressed by EuRIC, European recyclers strongly support mandatory and quantitative recycled content targets for packaging production as an efficient policy instrument to steer the demand for high-quality recycled materials and invest throughout the packaging value chain – from design to end-of-life collection and recycling.
For Paul Mayhew, President of EuRIC Plastics Recycling Branch, “this call made from the voice of plastics manufacturers is a major step forward towards more circularity in the field of packaging and a recognition that binding recycled content targets in EU legislation are a powerful market signal to scale-up circular value chains. It has proved to be an extremely efficient tool for beverage bottles in pulling the demand for food-grade rPET and de-correlating prices from the ever-fluctuating oil market. Extending such an obligation to plastic packaging at large will give the long-term certainty the packaging value chain needs to scale-up and be in a position to supply high-quality recycled polymers”, he added.
With substantial room to improve the uptake of raw materials from recycling (RMR) in a number of plastic packaging types, the recycling industry looks forward cooperating with the plastics industry to meet such a target by 2030.
Emmanuel KATRAKIS, Secretary General of EuRIC, stressed that “transitioning towards a circular economy is key to achieve climate-neutrality. Binding recycled content targets for plastics and other materials will play a key role in achieving that goal. On top of push-and-pull measures, a comprehensive policy framework that gives an edge to circular value chains in the EU and globally is absolutely essential”, he concluded.
Handling & Sorting Specifications - For re-use and recycling of used textiles
Textiles and clothing are essential to our everyday life. Over the last two decades, the clothing consumption has more than doubled, leading to a drastic increase of discarded textiles. The EU-wide obligation to separately collect textiles by 2025 will further increase the supply of used textiles, shoes and accessories. To ensure optimal re-use and recycling of the used textiles, proper handling and sorting is essential.
The newly published “EuRIC Textiles Handling & Sorting Specifications for re-use and recycling of used textiles” are recommended as a guideline throughout the collection and sorting process to prepare items for either re-use or recycling in accordance with the waste hierarchy and best practices of the industry. They are intended to be used by industry professionals throughout the textile value chain in their day-to-day operations as the processes described secure the high quality of second-hand textiles for re-use and/or the appropriate infeed for the subsequent recycling process.
“At EuRIC Textiles, we feel it is important to have uniform and clear specifications describing how used textiles should be handled to achieve the highest possible percentage of re-use and recycling” explained Mariska Zandvliet, EuRIC Textiles President. “With the expected increase of used textiles to be collected after 2025, it must remain our top priority to minimize quality loss throughout the sorting process and maximize possibilities to re-use and recycle. Our specifications, prepared by leading industry professionals, ensure that the quality in collected textiles is retained and describe a sorting process for sustainable re-use and recycling. Thus, serving as reliable source for the entire industry facilitating circularity in textiles“, she concluded.
Joint Press Release - Discover the truth about the used clothing industry
A variety of associations involved in the used clothing trade around the world have joined forces to dispel myths about the industry. The truth is that the used clothing industry is gaining momentum with tremendous environmental, social, and economic benefits. The industry is working towards a circular economy by offering sustainable solutions for used textiles that will benefit everyone and help to reduce the major environmental impacts caused by the global fashion industry.