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.
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.
Fit for 55 Package: An ambitious EU Climate Agenda is key to the Circular Economy
EuRIC welcomes the publication of the Fit for 55 Package, which sets in stone the EU’s ambition to cut Greenhouse Gas emissions (GHG) by at least 55% below 1990 levels by 2030 and reach climate neutrality by 2050.
The substitution of extracted raw materials with Raw Materials from Recycling (RMR) saves massive amounts of GHG and energy, on top of being intrinsically resource efficient, and thus has a key role to play in supporting energy intensive industries to decarbonise and become more circular.
Using recycled steel, copper, or aluminium scrap saves respectively 58%, 65%, and 92% of CO2 when compared with extracted raw materials1. To exemplify the magnitude of these savings, in 2018, the use of 93.8 million tonnes of recycled scrap in steelmaking enabled the saving of 157 million tonnes of CO2. This is equivalent to the emissions released by the automobile traffic in France, Great Britain and Belgium all together.
For Ms. Cinzia Vezzosi, President of EuRIC, “Climate policy and the circular economy goes hand-in-hand. Recyclers expect from the implementation of the Fit for 55 Package a high-level of ambition linked to the EU Emissions Trading System (ETS) and the Carbon Border Adjustment Mechanism (CBAM) to support investments in climate neutral and circular industrial value chains. With only 12% of raw materials used by Europe’s industry coming from recycling2, strong incentives such as mandatory recycled content or a better framed EU ETS are urgently needed to increase the demand for circular materials usage and send strong signals to the market”, she stressed.
Last but not least, it is equally essential to ensure that the right framework is in place to accelerate the transition towards a circular and climate-neutral economy, while protecting the competitiveness of Europe’s energy intensive industries. In that respect, reciprocity is important to meet the EU’s circular and climate objectives. “European recyclers call for the CBAM to adequately price the carbon footprint of imported semi-finished metal products, but also to level the playing field for raw materials (be them mined or recycled), which are sourced from non-European countries often under environmentally and socially poor conditions”, she added.
EuRIC looks forward to work with the European Parliament and the Council to support an ambitious implementation of the Fit for 55 Package.
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 Circular Metals Strategy
Metal recycling is indispensable to reach EU’s climate neutrality objectives by 2050 (EU Green Deal) and shifting from a linear to a circular economy (Circular Economy Action Plan 2.0). Metals can - thanks to their intrinsic properties and market value - be indefinitely recycled and for this reason they play a key role in Europe’s sustainable transition. Metal recycling, is not only the most resource efficient option but also the most climate and energy efficient route when compared to the production of metals using primary raw materials1. Last but not least, given their high value, metals are not littered but collected and recovered to close new material cycles. As a result, metal ores and metal scrap, meeting quality specifications, are commodities priced and traded globally which could help the globe to further close the loop of materials in global value chains and avoid littering related problems.
Europe’s metal recycling industry – which is composed of SMEs and large players – is one of the fastest growing industry, providing local, non-outsourceable jobs. It offers a unique infrastructure of facilities spread all over Europe, that supplies steel mills and smelters located in and outside Europe with quality grade metal scrap which is resource and climate efficient. Metal recyclers’ priorities, as outlined in EuRIC metals strategy, are threefold:
- Creation of a well-functioning internal and global markets for metals
- Rewarding metal recycling environmental benefits
- Increase the intake of commodity-grade metal scrap in metal production
1Compared to primary production, steel, aluminum and copper recycling save respectively 58%, 92% and 65% of CO2 emissions (FEDEREC, 2017).Compared to primary production, steel, aluminum and copper recycling save respectively 58%, 92% and 65% of CO2 emissions (FEDEREC, 2017).EuRIC Circular Metals Strategy
EuRIC Press Release - EuRIC welcomes the provisional agreement on the European Climate Law
The European Recycling Industries’ Confederation (EuRIC) welcomes the provisional agreement on the European Climate Law.
The European Climate Law, one of the key pillars of the European Green Deal, sets ambitious targets ranging from climate neutrality by 2050 to a 55% reduction of net emissions in 2030 compared to 1990. The recycling industry from the outset plays a major role in saving emissions as well as energy.
For instance, as highlighted in the Top 5 priorities of the recycling industry, ferrous metals recycling saves the equivalent of 58% of CO2 emissions when compared with primary steel using iron ore. That percentage raises to 70% for PET, 89% for packaging HDPE, 93% for aluminium and 98% for textiles recycling. Using recovered paper instead of primary materials saves 70% for paper and 77% for cardboard of the energy needed to produce new paper. Last but not least, tyre recycling into rubber granulates saves 58,4% of CO2 when compared with end-of-life tyre’s co-incineration and can reach 95% of carbon footprint reductions when compared to those of virgin materials substituted.
Emmanuel Katrakis, Secretary General of EuRIC said: “We are pleased to see such an ambitious agreement which will eventually lead to a binding legislation in the EU. The recycling industry is inherently resource and climate efficient. As, we strive to reach the targets set in the European Green Deal, Circular Economy Action Plan and now, the new European Climate Law, the European recycling industry is committed to keep contributing its share to bring the EU on an even greener path”.
EuRIC is devoted to bridge the circular economy with climate policies and to advocate the benefits of recycling in reaching the ambitious targets of the European Climate Law. “We look forward to do our part to combat climate change today on Earth Day and every day”, Katrakis concluded.
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.