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.
A united tyre value chain calls for immediate EU-wide end-of-waste criteria for recycled rubber.
23 June 2022
EuRIC and ETRMA are pleased to see rubber recycled from end-of-life tyres among the “top 3” most suitable candidate streams for which to develop further EU-wide end-of-waste (EoW) criteria but further policy makers’ commitment is needed.
Press release - Global free, fair & sustainable recovered paper trade is crucial for recycling industry
Brussels, 23 May 2022 – The recycling industry collects and recovers paper waste into standardized quality grade recovered paper in line with the European standard EN 643 on a daily basis. In 2020, Europe has collected on average 54.4 million tons of recovered paper and used 47.9 million tons internally1. However, there is a lasting gap between supply and demand of around 7 million tons in terms of excess supply of recovered paper in Europe as observed over the past years. In the absence of end markets for around 7 million tons of recovered paper in Europe, exports are vitally important for the European paper recycling industry.
Read more in our press release.
Press release - Revision of the “Waste Shipment Regulation” Free, fair & sustainable trade of metal scrap is essential to the EU recycling industry & the success of the EU Green Deal
Brussels, 13 May 2022 – The proposal to revise the Waste Shipment Regulation (WSR) requires substantial improvements to deliver on its key objectives, namely combat illegal shipments while boosting circular value chains. The one-size-fits all approach subjecting all waste streams to similar export restrictions without making any distinction between untreated and raw materials from recycling (RMR) meeting quality specifications, will result in lasting negative impacts for the EU’s recycling industry. In particular, metal scrap from mechanical recycling should not be subject to export restrictions from the EU. If kept, such restrictions would result in substantial leakage of the recycling capacity to outside Europe. There would be resultant job losses in one of the most dynamic and circular industries. They would also deter business from scaling-up capacities and investing in new technologies to deliver raw materials that the European – and wider – industry needs. In turn, this would significantly hamper an EU circular and climate-neutral economy.
Press Release: EuRIC welcomes the proposal to make sustainable products the norm in Europe
The European Recycling Industries’ Confederation (EuRIC) welcomes the Circular Economy Package that was published by the European Commission on 30 March and aims at making products more sustainable in the European Union.
EuRIC strongly welcomes the increased emphasis placed on recycled content in products as it is a key enabler to boost investments in recycling technologies and will speed up the transition to a true circular economy. The proposal for a Regulation on Ecodesign for Sustainable Products will in addition be a game-changer in making products more durable, reliable, reusable, upgradable, reparable, easier to maintain, refurbish and recycle, and energy and resource efficient.
Joint statement on amending the annexes of Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs)
Adopted in June 2019, the recast Regulation on Persistent Organic Pollutants (POPs) set the contaminant limits that largely determine the treatment of the waste and, in particular for limits in Annex IV, define whether a waste containing specific POP substances should be disposed of in such a way that the POP content is destroyed or irreversibly transformed or whether it can be subjected to other recovery or disposal operations, including recycling.
The entry concerning PBDEs (including DecaBDE) in Annex IV contains a clause requiring the EU Commission (hereinafter the Commission) to review the Low POP Concentration Limit (LPCL) for these substances by 16 July 2021. The limit value for the substances is currently set at 1,000 mg/kg. The Commission was asked to look at the feasibility of reducing the aforementioned value to 500 mg/kg as finally published on 28 October 2021.
The signatory organisations to this position paper acknowledge the challenge set out by the Commission and believe that the discussion and decision around any revision of the LPCL for PBDEs needs to be based on current scientific knowledge and the factual situation concerning the sound waste management and treatment of POP containing materials in the electrical, electronic and automotive sectors in the EU.
Press release - EuRIC backs the ENVI Committee on the Revision of the Battery Regulation
The European Recycling Industries’ Confederation (EuRIC) endorses the ambitious measures adopted by the ENVI Committee of the European Parliament which will govern the entire battery life cycle. These measures are of an utmost importance for the transition to a circular and climate-neutral economy. Such a level of ambition shall be kept as EU institutions are entering the final stages of the negotiations.
We strongly welcome the amendments on recycled content targets (Article 8) which are addressed to more battery types than initially proposed and are crucial to further closing the loop in the battery value chain. As consistently stressed by EuRIC, European recyclers strongly support mandatory recycled content targets for battery production as an efficient and necessary policy instrument to increase the demand for high quality materials coming from recycling and provide the predictability needed to long term investments and capacity-building in Europe along the value chain.
Waste Shipment Regulation (WSR) proposed legislative revision Substantial changes needed to protect Europe's recycling industries
The European Recycling Industries’ Confederation (EuRIC) represents the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion € by treating various waste streams such as household or industrial & commercial waste including ferrous and non-ferrous metals, end-of-life vehicles (ELVs), electronic waste (WEEE), packaging (paper and plastics), end-of-life tyres or textiles. As a result, EuRIC represents the industries that are working tirelessly to transform everyday (and specific) waste streams into high-quality and high-value Raw Materials from Recycling (RMR). These materials directly substitute many extracted raw materials, and therefore represent a drastic reduction in product embedded Greenhouse Gas (GHG) emission and environmental impacts. To achieve the goals defined by the European Commission, we believe it is essential to adopt an approach to waste shipment that necessarily distinguishes high quality RMR from lower quality waste.
EuRIC thanks the European Commission for publishing the recent proposed revision of the Waste Shipment Regulation (WSR). While EuRIC strongly supports the key objectives of the legislative revision namely combatting illegal shipments or improving the internal market for Raw Materials from Recycling (RMR)2, the European recycling industry would like to express its grave concern on the consequences of the proposed measures on the EU’s recycling industry. The one-size-fits-all approach vested in the Commission’s proposal would, if endorsed, result in devastating consequences on the competitiveness of EU’s recycling industry.
This paper provides the position of the European Recycling Industry, which outlines how future Waste Shipment Legislation must be designed with the objective of enabling the Circular Economy, rather than dismantling it. The paper will focus on the three key objectives of the proposed revision of the WSR: enabling intra-EU material recovery, reducing the export of EU waste challenges to third countries, and tackling illegal waste shipments & implementation.
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 to the Inception Impact Assessment on the revision of EU legislation on REACH
The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy. Bridging the various phases of products’ life cycle in relation to chemicals to achieve safe products and non-toxic material cycles, including through substitution, is of paramount importance to support a safe circular economy, given the lasting problems posed by legacy substances at recycling stage, regardless of the separation and sorting technologies used for material recovery purposes and streams at stake (WEEE, packaging, ELVs, tyres, textiles, batteries, etc.).
EuRIC finds the problem that the above initiative aims to tackle very relevant not only for downstream users of chemicals but also for companies who recycle – a large number of small, medium and large enterprises scattered across the EU whose role in the Circular Economy journey is considered of an utmost importance.
Thus, the top priorities identified by EuRIC – which will further ameliorate the aforementioned legislative framework - can be found in this paper.
Revision of the Waste Shipment Regulation - One size fits all export restrictions can end EU circular economy ambitions
The Waste Shipment Regulation (WSR) is a key piece of legislation in the move towards circular value chains. Burdensome procedures and lack of harmonisation rooted in the current regulation give an edge to linear value-chains, instead of boosting waste shipment for recycling and the marketing of raw materials from recycling (RMR).
However, the proposals released today by the European Commission pose major problems that will jeopardise Europe’s circular economy ambitions.
European recyclers entirely support the objective to better tackle illegal waste trade and exports of unprocessed waste to countries lacking the infrastructure for proper treatment. Such exports not only threaten human health and the environmental, they also are a major economic loss for Europe’s recycling industry.
Yet, by failing to distinguish between trash and RMR that meet strict quality specifications, the proposal falls short of levelling the playing field with extracted raw materials, which are not subject to any such constraints in EU law.
“Free, fair and sustainable trade of RMR is absolutely essential to boost high-quality recycling in Europe and ensure the recycling industry remains competitive,” says Emmanuel KATRAKIS, Secretary General of EuRIC.
“Europe’s recycling industry is powered by SMEs and large companies, who directly employ over hundreds of thousands of Europeans, and indirectly many more. As stressed in the recent letter signed by 300 European national recycling federations and companies, subjecting RMR - which are still classified as non-hazardous waste - to export restrictions will, in the absence of secured end-markets for circular materials in the EU, pose a vital threat to European recyclers, be them SMEs or large multinational companies, and undermine the creation of green industrial jobs in Europe.”
“With only 12% of raw materials used by the EU’s industry coming from recycling, binding requirements to use RMR in industrial value chains are urgently needed to ensure the excess supply of RMR, that would remain captive in Europe under these proposals, don’t end up in landfills. In the Commission’s toolbox to boost the transition towards a circular economy, binding recycled content targets have proved to be the most efficient yet least utilised instrument, with the exception being for plastic packaging.”
EuRIC looks forward to working with the European Parliament and Council to better distinguish trash from RMR and ensure a fit-for-purpose regime applies to curb exports of problematic waste streams without closing frontiers to the most resource-efficient and carbon-neutral materials needed to achieve EU’s and global climate objectives.
EuRIC also looks forward to working with the co-legislators to further increase the ambition of proposed measures to ease intra-EU waste shipments for recovery and end-use in circular value chains, which are essential to achieve a well-functioning market of raw materials from recycling and level the playing field with extracted raw materials.