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.}

Last update on 15.03.2022

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

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.  

We are pleased to share with you EuRIC's first annual review featuring its 2020 achievements and future commitments. 

In 2020 we expanded, reached new heights and continued pushing ourselves and those listening to our growing voice with one common goal: to get one step nearer to closing the loop.

Our plans for 2021 are just as ambitious as our increased responsibilities. We are confident that with the relentless work of the EuRIC Secretariat and EuRIC Members, our joint efforts will make a lasting and positive impact on the decision making in Europe.

The Waste Shipment Regulation (WSR) is, as rightly identified in the new CEAP, a pivotal piece of legislation with provisions that need to be aligned with the overarching objectives of transitioning towards a circular economy. Hence, the revision offers the opportunity to make both needed adjustments to fix lasting bottlenecks and radical changes to address long-term obstacles rooted in outdated obligations.

It is time to align the procedures set by the Waste Shipment with the pace of Circular value chains. A paradigm shift requires to treat waste in legislation as a resource enabling the circular economy, stressed Peter FLORMANN, Chair of EuRIC Waste Shipment Task Force.

This paper goes beyond simply identifying lasting problems rooted in waste shipment procedures. It provides detailed solutions to support a revision of the WSR that enables the creation of a well-functioning European market for secondary raw materials. EuRIC calls in particular for

• Simplified waste shipment procedures, be it for green listed waste and waste subject to prior informed consent (PIC) procedure, which make an extensive use of the digitalization (electronic procedures);
• Preserving free and fair trade of secondary raw materials which is vital to the competitiveness of the European recycling industry and to speed up the transition towards a circular economy, while leveling the playing field with primary raw materials;
• Accompanying the revision of the waste shipment regulation by binding requirements to boost the use of secondary raw materials in production processes and reward their well-documented environmental benefits in terms of GHG and energy savings.

For Julia BLEES, Senior Policy Officer at EuRIC, closing boundaries has never brought any benefits except distorting markets. While EuRIC entirely supports avoiding unprocessed waste posing an environmental risk to find its way to countries lacking any infrastructure and makes practical proposals in that respect, it is key to ensure that free and fair trade of secondary raw materials remains unhampered. At a time where Europe’s industry remains mostly linear with only 12% of the materials it uses coming from recycling ^[1], truly boosting circular value chains in Europe require decisive measures such as binding recycled content targets and incentives supporting the uptake of recycled materials in manufacturing, not trade barriers, she concluded.  

^[1] The European Green Deal, COM (2019) 640 Final.