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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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.[1] 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).[2] 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[3]. 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. -
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.
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EuRIC Indicative Specification Sheets for main grades of sorted plastics
EuRIC’s purpose is to propose with these specification sheets an objective, measurable definition of the new B3011 entry of the Basel Convention which will enter into force on January 1st, 2021 (complete definition below). As you know, from this date on, only plastics registered under this B3011 entry will be eligible to the general information procedure. All other plastics will have to be shipped under the prior informed consent procedure under Y48 entry.
The proposed specifications intend to clarify and provide a more harmonized criterion to assess what “almost free from contamination and other types of wastes” means and help devising a sound classification of sorted plastic waste, in particular in case of customs control, and to avoid excessive discrepancies between Member States when implementing these new B3011 / Y48 entries.
Furthermore, these specifications also aim to be applied to plastic waste shipments within the EU (EU3011).You will find three documents with specification sheets:
- a general plastics from packaging,
- an "all streams" flakes specification- extremely generic and intend to cover for all the small streams waste which are important when put together and are often recycled abroad,
- a stream-specific technical plastics from WEEE & ELVs.
The “All streams – Flakes specification” is intended to apply exclusively to the flakes classified as waste. Currently, the waste / non-waste status of plastics flakes is not homogeneous and varies widely from one state to another, including within the EU. Similar plastic flakes can be classified either as waste or non-waste (product, by-product, product through “end-of-waste” procedure). EuRIC supports the classification as non-waste of flakes that are fit for integration within a manufacturing process.
The proposed standards are not meant to replace, but are meant to be compatible with, contractual agreements on waste quality set between sellers and purchasers, national quality standard, set by national recyclers associations or by EPR schemes (for example DSD specifications or FEDEREC’s waste classification), future Europe-wide quality grades for plastics waste such as those being prepared by CEN, etc.
These specifications have been updated on the 16/02/2021. For a conservative approach, mass should be not expressed as dry matter.
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EuRIC & EERA Joint Call - Boosting Technical Plastics Recycling - A Matter of Urgency
The European Recycling Industries’ Confederation (EuRIC)* and the European Electronics Recyclers Association (EERA) represent the vast majority of technical plastics recyclers collecting, recycling and marketing recycled polymers from Waste Electrical & Electronic Equipment (WEEE) and end-of-life vehicles (ELVs).
The plastics recycling industry has been severely impacted by the COVID-19 pandemic. Technical plastics recycled from ELVs and WEEE are no exception.
Read the complete call by clicking on the link below.
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EuRIC Press Release - Decisive actions needed to support plastics recycling in Europe
The European plastics recycling industry has been severely impacted by the COVID-19 pandemic. Plummeting oil prices have resulted in a sharp decline of virgin plastics prices.
The cost structure and the carbon footprint of virgin and recycled polymers are completely different, yet they compete on prices stresses, Paul Mayhew, President of EuRIC Plastics’ Recycling Branch (EPRB).
Sharp drop in prices and demand for recycled plastics, which can’t compete with virgin polymer prices resulting from the crash in crude oil values, jeopardize the economic viability of many plastics recyclers across Europe, be them active in packaging, engineering or construction and demolition waste plastics recycling, as recently echoed1. Should the current situation continue, the impacts will be far-reaching putting at risks both the attainment of the objectives set in the EU Green Deal and the New Circular Economy Action Plan which require to scale up – not to diminish – the European recycling capacity and resulting in the loss of green jobs in various Member States.
The only positive development relates to food-grade r-PET which thanks to recycled content targets set by the Single-Use Plastics Directive has weathered the storm with stable demand and price, completely de-correlated from plummeting oil and virgin prices, since brand-owners are gearing up for the 2025 and 2030 targets in beverage bottles.
The two-tier market witnessed in the current crisis where plastics used in applications not subject to binding sustainability targets sees there prices driven by short-term cost-savings offered by the crash of oil values versus plastics used in applications benefiting from sustainability targets whose price-setting follows a positive trend, regardless of the crisis, is the ultimate proof of the need to set targets of incorporation of recycled materials in new products, emphasized Sophie Sicard, Vice-President of the EPRB.
EuRIC calls for urgent measures to support plastics recycling in Europe:
- Systemic support in Member States to the plastics recycling industry, in particular in mechanisms to stimulate the demand for recycled materials;
- Pragmatic mandatory EU recycled content targets for plastics commonly used in products to stimulate the demand for recycled materials and secure investments to scale up capacity and create jobs in Europe;
- Incentives, be them market or tax-based, to close the price gap between virgin and recycled plastics proportionally to the well-documented CO2 and energy savings from plastics recycling.
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EuRIC - Plastic Recycling Fact Sheet
Plastic is an important and ubiquitous material in our daily lives and for the European economy. However, to maximize their multiple benefits and mitigate environmental impacts, improving the circularity of plastics at all stages of the value chain – design, production, use and recycling phases – is instrumental. Recycling plays a key role in that respect by turning waste into high-quality recyclates. By doing so, it contributes to save virgin resources, greenhouse gas emissions and energy.
The Brochure highlights the importance of moving towards a circular economy for plastics in Europe. It identifies the most commonly used types of plastics and describes the current state-of-play, challenges faced by the European mechanical plastics recycling industry alongside with key recommendations to overcome them. Plastics recycling’s environmental benefits and economic importance is also touched upon.
Paul Mayhew, President of EuRIC’s Plastic Recycling Branch (EPRB) and General Manager at MBA Polymers, emphasized the major contribution that plastics recycling can make towards a circular economy for improving Europe’s competitiveness and resource efficiency.
Moving towards a more sustainable economy for plastics will deliver considerable benefits. What is missing in order to speed up that transition are measures to stimulate the demand for recycled plastics in products through recycled content targets and incentives rewarding their environmental benefits when compared with virgin plastics and a more consistent legislative framework. It is essential to further restrict landfill and incineration of but also better control unprocessed plastic waste exports outside Europe to countries with lower recycling standards.
These measures are even more urgent today with the plastic recycling industry which has been heavily impacted by the COVID-19 pandemic with a plummeting demand and overly low virgin plastics prices with whom recycled polymers compete.
Following the substantiated call for recycled content of plastics in new cars recently launched by EuRIC, this factsheet will be followed by other publications stressing the vital role played by the recycling industry to realize the transition towards a circular economy and to make of the EU the first world-class economy to achieve climate-neutrality by 2050.
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EuRIC call for Recycled Plastic Content in Cars
By turning waste into valuable resources and hence saving massive amounts of GHG and energy, plastics recycling is at the core of the circular economy. Automotive plastics’ recyclers have developed during the last decades state-of-art post-treatment technologies to efficiently separate and then recycle plastics from end-of-life vehicles (ELV); recycled plastics that once compounded again in new vehicles, meet similar performance standards as those compounds from virgin polymers
In this substantiated call for recycled content of plastics in new cars, EuRIC outlines the state of play of plastics in the automotive sector and highlights the need for an increase content of recycled plastics thanks to targets to be set in the ELV Directive currently under revision.
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Press release: EuRIC signs the Circular Plastics Alliance (CPA) Declaration
Today, on 20 September 2019, EuRIC has co-signed the Circular Plastics Alliance (CPA) Declaration during the High-level event organized by the European Commission. For EuRIC, the CPA perfectly embodies the value chain approach needed to achieve the target of at least 10 million tonnes of recycled plastics by 2025. It shall be seen as complementary to the implementation of regulatory measures that pull the demand for recycled plastics and foster eco-design
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EuRIC Statement: EU position for implementation of Basel decisions into the OECD
EuRIC, the European Recycling Industries’ Confederation, supports to ensure proper plastic waste treatment all over the world and the amendments concerning plastic waste which were decided at the 14th Conference of the Parties of the Basel Convention.
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Position paper - Amendments on the Norwegian Proposal to amend Annexes II, VIII and IX of the Basel Convention - 01.04.2019
EuRIC is pleased to share amendments to the proposals made by Norway to amend Annexes II, VIII and IX of the Basel Convention which would impact the classification of plastic waste under the Basel Convention with the declared objective to curb marine litter.