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.
Europe’s circular economy leaders demand removable, replaceable, and repairable batteries
Actors already building a circular economy for batteries in Europe, i.e., repairers, refurbishers and recyclers, alongside environmental NGOs, call on the European Commission, Parliament and Council to adopt ambitious requirements in the Battery Regulation to enable battery removal, replacement and repair for consumer electronics and LEVs.
Removable, replaceable, and repairable batteries are an essential element of the battery regulation in order to support value retention and circularity, reduce EU dependency on critical raw materials, reduce e-waste and unnecessary consumption, as well as supporting worker safety and fire prevention.
EuRIC calls upon policy makers to set ambitious removability, replaceability and repairability requirements in Article 11 of the battery regulation:
Scope: the scope for these removability requirements should cover all consumer electronics. Light means of transport (e.g., e-bikes and e-scooters) should also be included in the scope. Removal and replacement for all: battery removal and replacement should be enabled for both independent professionals and end users. Enabling removal and replacement by citizens is essential for battery recovery and extending the life of electronics. Battery removal should be possible with no tools at all, or commonly available tools (i.e., with respect to EN 45554:2020).
Battery repair and repurposing for professional repairers: as well as removability and replaceability, battery repair should be enabled for independent professionals. The Commission is encouraged to start a standardisation process for cell level repair and repurposing.
Batteries as spare parts: quality battery packs should be available to end users as spare parts for at least the expected lifetime of the device. The components of the battery packs (e.g., cells, casing,board/BMS) should be available to independent professionals. Clear replacement and repair instructions should be freely available to end users and independent operators respectively to ensure safe battery management.
Software: battery software should not be a barrier to battery replacement or repair. Updates and serialisation should not prevent or discourage replacement by end-users, and independent operators should be able to manage the BMS to restore batteries they repair or repurpose.
Derogations: it is foreseeable that there are justifiable cases for exemptions for these requirements (e.g.,for medical devices) however any derogation should not present a loophole for manufacturers. Overall, single use, unrecoverable applications such as “printed batteries” should be reserved for essential applications.
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.
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.
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.
Packaging and Packaging Waste Directive
The European Recycling Industries’ Confederation (EuRIC), thanks the European Commission and Eunomia for the informative and often detailed series of workshops to support the measures created within the Impact Assessment for the revision of the Packaging and Packaging Waste Directive (PPWD) 94/62/EC. EuRIC strongly supports the need for ambitious measures in the field of packaging waste, to ensure the much-needed drive towards the circular economy, as promised in the new Circular Economy Action Plan (CEAP). The crisis resulting from the COVID-19 pandemic showed that the only manner to de-correlated recycled materials prices from market ones which fail to internalise externalise are binding measures to incentivise circular materials’ use. Thus, a continued focus is required on this level of ambition to avoid the watering down of pro-Circular measures.
This paper outlines the key cross-cutting positions of the European Recycling Industry. We look forward to workingclosely with the European Commission and Eunomia to ensure a progressive push in the revision of the PPWD’sessential requirements.
1. Directive 94/62/EC on packaging and packaging waste. Link here
2. Circular Economy Action Plan: For a cleaner and more competitive Europe. Link here.
3. EuRIC Press Release - Decisive actions needed to support plastics recycling in Europe, June 2020.
Recommendations for tackling fires caused by lithium batteries in WEEE
WEEE Forum, EuRIC, EUCOBAT, EERA, MWE and the WEEELABEX Organisation join forces to counter the occurrence of fires caused by lithium batteries and e-waste containing lithium batteries. A new report compiles good practices addressed to all actors in the value chain and covering all phases of products’ lifecycle.
More and more electrical and electronic products in everyday life contain batteries, making life more convenient and pleasant. However, those same batteries, when damaged, also increasingly cause fires.
In the past few months, organisations representing the industry that manages the collection and treatment of spent batteries and electronic waste (WEEE) along with manufacturers of home appliances and consumer electronics, gathered to exchange views about this issue of growing concern in order to design measures to counter the frequent occurrence of fires. A survey among recyclers resulted in a better understanding of the issue of fires in the WEEE management chain. The report , “Recommendations for tackling fires caused by lithium batteries in WEEE”, has been prepared by the WEEE Forum and EuRIC with the active contribution of experts from various organisations including the co-signatories EERA, EUCOBAT, Municipal Waste Europe and the WEEELABEX Organisation. The report presents a set of recommendations and good practices aimed at countering the occurrence of fire incidents caused by lithium batteries and WEEE containing lithium batteries.
“The report concludes that there is not a magic formula that will eradicate the risk of fires caused by WEEE containing batteries”, says the WEEE Forum. “It is imperative that actions are taken urgently in all steps of the lifecycles of EEE and lithium batteries and by all actors in the value chain: from design to disposal of WEEE and batteries including the consideration of transport and treatment. For this, further work to assess the extent of the issue and potential solutions is required’’.
A thermal event may become a severe incident if is not rapidly detected and extinguished. Training, prevention, and detection measures are therefore essential for identifying and tackling risky situations. The report comprises recommendations and good practices addressed to the main participants in the steps of the EEE and WEEE value chain and includes recommendations to producer responsibility organisations of EEE and batteries, to local authorities, and policy makers.
“The European Green Deal and the new Circular Economy Action Plan identify ‘electronics’ among key product value chains where recycling plays a major role in achieving sustainability goals. Battery fires are a genuine challenge for the recycling industry and the entire value chain. Properly addressing the risk of fires caused by WEEE containing lithium batteries through a multi-stakeholder approach is essential to support electronics’ recyclers which play an essential role in the achievement of the EU’s overarching sustainability goals”, says EuRIC.
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 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 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, toimprove the environmental performance of imaging equipment placed on the European Market, and in addition to the comments made on previous drafts, EuRIC is pleased to share the following comments on the new draft VA.