Position papers
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.
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EuRIC Reaction to the Proposed Batteries and Waste Batteries Regulation (Batteries – modernizing EU rules)
Key points
- 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
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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.
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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.
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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.
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Characterisation of fires caused by batteries in WEEE
More and more electrical and electronic products in everyday life contain batteries, making life more convenient or pleasant. However, those same batteries, when damaged, also increasingly cause these products to catch fires.
In the past few months, organisations representative of the industry that manages the collection and treatment of spent batteries and electronic waste (WEEE) and of 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, “Characterisation of fires caused by batteries in WEEE”, has been prepared by EuRIC and the WEEE Forum with the active contribution of experts from various organisations including the co-signatories namely EERA, EUCOBAT, Municipal Waste Europe and the WEEELABEX Organisation. It seeks to jointly assess the severity of the issue.
The survey shows that the number of fires in the WEEE management chain is going up and that the fires mainly occur in mixed WEEE. Damaged batteries are seen as responsible for those fires.
“Battery fires are one of the most important issue impacting recyclers currently” says Emmanuel Katrakis, Secretary General at EuRIC, the European Recycling Industries’ Confederation. “This fact-based report confirms that fires occur at every stage of the collection and treatment of WEEE, but we see a higher prevalence during treatment and at the logistics and pre-treatment stages during storage”, the survey tells us that for most fires, there is a high prevalence of frequent yet small thermal events that cause no or little damage. The most severe fires identified by respondents were mostly described as intense fires and lasting between 1 to 6 hours. More than a third of the respondents reports one of those severe fires. The report roughly estimates the average costs associated to most frequent fires in 190 000 €, and 1.3 M€ for most severe fires.
The report includes a set of recommendations to further investigate some aspects that were addressed in the survey, but for which an in-depth analysis is key to have a better grasp of the issue. This includes for instance consequences for the reuse sector, the efficiency of the rules concerning the international carriage of dangerous goods by road (ADR), or the detailed cost breakdown of damages caused by battery fires.
“This report provides a set of facts and figures”, says Pascal Leroy, Director General at the WEEE Forum, the international voice of e-waste producer responsibility organisations. “It was extremely important to carry out that work collectively in a Roundtable, gathering the most relevant representative organisations in order to develop a shared understanding of the issues of concern. A follow-up report will analyse best practices to tackle fires associated with batteries”, he added.
For any inquiries on the subject please contact euric@euric-aisbl.eu and info@weee-forum.org.
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EuRIC unveils Metal Recycling Brochure
EuRIC is pleased to publish a factsheet on Metal Recycling highlighting the importance of both ferrous and non-ferrous metal recycling and their substantial benefits for the environment and the economy in Europe.
The Brochure outlines the environmental benefits, the economic and international trade aspects of steel, aluminum and copper recycling. -
EuRIC Position on WEEE Treatment Standards
To level the playing field in WEEE treatment at European level, EuRIC supports laying down mandatory minimum quality standards based on the WEEE treatment standards developed by CENELEC provided they:
- Are based on 50625 treatment standards developed by CENELEC.
- Distinguish informative from normative requirements as provided by the mandate M/518 with such a distinction to be made by a third independent expert and verified by the European Commission;
- Costs of implementation of binding minimum quality standards, in particular the costs of auditing, shall be continuously covered by Extended Producer Responsibility (EPR) Schemes or by Member States (MS)
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EuRIC Statement on issues stemming from the lack of capacity for ultimate residual waste
EuRIC has been informed by multiple recycling operators active in different parts of Europe of strong difficulties in finding outlets for ultimate residual waste treatment and disposal stemming from recycling processes of different industrial and commercial waste as well as of Waste Electrical and Electronic Equipment (WEEE) and End-of-Life Vehicles (ELVs). Shredder light fraction (SLF) having a high calorific value and ultimate residual waste resulting from post-treatment techniques used to minimize the amount of residual waste which can no longer be materially recovered are directly affected. In the absence of current treatment or disposal options respectively in incineration with or without waste-to-energy or final disposal for the fractions with high calorific value, some recycling companies have been forced to stop their entire mechanical recycling operations, permanently or temporary.
EuRIC is pleased to highlight some key elements linked to the lack of capacity and obstacles to the acceptance of ultimate residual waste from industrial and commercial waste as well as WEEE and ELV mechanical recycling.
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Position on the Harmonized classification and Labelling for Cobalt Metal
EuRIC, the European Recycling Industries’ Confederation, is substantially concerned by the proposal made by the Netherlands for harmonized classification of Cobalt metal. The proposal as it stands will significantly disrupt the value chain for steel, be it stainless or carbon steel, as well as for specialty alloys and will have a very negative impact on their recycling.
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International Green Deal North Sea Resources Roundabout to work on new case: ‘Fast-Tracks’ for WEEE
EuRIC was proud to attend the first kick-off meeting of this Green Deal aiming to make shimpments of secondary raw materials faster and easier. ‘Fast-Tracks’ is the fifth case for the International Green Deal North Sea Resources Roundabout (NSRR) - after compost, PVC and non-ferrous metals from bottom ash and struvite. The case, initiated by Müller-Guttenbrunn GmbH and HKS Metals deals with the concept of ‘Fast-Tracks’ for WEEE: making shipments to compliant EU WEEE recyclers easier and faster. Article 14 of the European Waste Shipment Regulation provides ample basis for the concept of ‘Fast-Track Notification’, but implementation can be improved. For this case Flemish, French, UK and Dutch public and private sector experts are joined by Austrian colleagues to explore possibilities for commonly accepted criteria for pre-consents and mutual accepted processes, amongst other things. The Commission (DGENV) is following the case as an observer.
