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 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, toimprove the environmental performance of imaging equipment placed on the European Market, and in addition to the comments made on previous drafts, EuRIC is pleased to share the following comments on the new draft VA.
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EuRIC Position for a Revision of the Waste Shipment Regulation Supporting the Circular Economy
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to make both needed adjustments to fix lasting bottlenecks and radical changes to address long-term obstacles rooted in outdated obligations.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.
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Top 5 Priorities of the Recycling Industry for the Period 2019 -2024
By turning waste into secondary raw materials and reducing Europe’s dependency on primary materials, the recycling industry plays a vital role in the circular economy. In addition, recycling saves a substantial amount of CO2 and energy. Recycling is thus a key sector to make Europe the first climate-neutral continent, a key objective of the European Green Deal highlighted by Ursula von der Leyen, the President of the European Commission. Last but not least, recycling is an inclusive industry providing local jobs which rely on a variety of qualifications and cannot be outsourced. Thus, recycling can significantly contribute to Europe’s re-industrialisation by boosting circular value chains. Hence, EuRIC representing the European Recycling Industry, calls for the completion of a competitive internal market for recycling rewarding circular value chains in Europe and beyond, through a set of 5 key measures.
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EuRIC Brochure on Mechanical Tyre Recycling highlighting its contribution towards circular economy and climate neutrality
EuRIC Brochure presents key facts about end-of-life (ELT) mechanical tyre recycling, which is a major enabler of circularity and climate mitigation for the entire tyre value chain.
The Brochure describes the current state of play of ELT management with recommendations to overcome key challenges faced by the European mechanical tyre recycling industry be them embedded in legislation, market failures or eco-design. It features key numbers outlining the economic importance of the ELT recycling sector as well as its benefits for the environment and society.
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’s Mechanical Tyre recycling (MTR) Branch and Group CEO Genan. The processing of ELT tyres into rubber is not only the most resource-efficient option; it also the most climate-efficient one since for each tonne of ELT recycled -for example as infill for artificial turf pitches- the climate is spared 700 kg of CO2, he added.
Currently, out of the approx. 3 million tonnes (Mt) of tyres reaching end-of-life stage annually in Europe, there are more than 1 Mt of tyres down-cycled annually in energy recovery, while less than 50% (approx. 1.5 Mt) are mechanically recycled into rubber, steel and textile fibers. Increasing material recovery is essential as natural rubber is a critical raw material in Europe[1].
A landfill ban for ELT is far from sufficient to boost tyres circularity. The EU needs to consider further measures to closing the loop of the Circular Economy of tyres, in particular:
- Incentives rewarding ELT recycling benefits and recycled content targets to drive the demand for recycled materials from tyres, especially rubber, be it in new tyres, asphalts, moulded products and construction materials.
- EU-wide end-of-waste criteria for ELT which are essential to alleviate obstacles impacting circular uses of materials derived from ELT recycling into a variety of applications benefiting society, the environment and industrial symbiosis. While national end-of-waste criteria as the recently adopted by Italy[2] are strongly supported, harmonization at EU level is key for a well-functioning of internal market for secondary raw materials.
Sustainable design of tyres to boost their recyclability and minimum thresholds of recycled content to stimulate the demand. Product design requirements shall go hand in hand with a better enforcement at European borders of imported new tyres which must comply with European standards to level the playing and protect the environment.
[1] European Commission (2020). Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability
[2] Regolamento recante disciplina della cessazione della qualifica di rifiuto della gomma vulcanizzata derivante da pneumatici fuori uso, ai sensi dell'articolo 184-ter del decreto legislativo 3 aprile 2006, n. 152. (20G00094) (GU Serie Generale n.182 del 21-07-20) -
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 Statement in support of the State of the Union 2020
Today, Ursula von der LEYEN, President of the European Commission, delivered a landmark speech on the State of the Union 2020. The European Recycling Industry renews its support to the European Commission in making the European Green Deal, Europe’s strategic priority.
EuRIC strongly welcomes in particular the proposal made by the European Commission to increase the 2030 target for emission reduction to at least 55% which is a necessary step forward in order to make Europe the first climate-neutral continent by 2050. EuRIC equally supports the decision to allocate 37% of Next Generation EU to European Green Deal targets as massive investments are needed to deliver on these objectives.
The European Recycling Industry is ready to play its part. By turning waste into quality raw materials used to manufacture new products, recycling companies, be them SMEs or market leaders, enable the circular economy and create local, non-outsourceable jobs across Europe. In addition, recycling is not only intrinsically resource-efficient but also climate efficient by saving significant amounts of Greenhouse Gas Emissions (GHG) and energy, well-documented in robust studies for a variety of resource streams.
“To speed up the transition towards a circular economy and meet the ambition set by the European Green Deal, it is instrumental to incentivize the use of secondary raw materials in manufacturing” stressed Cinzia VEZZOSI, President of EuRIC. “Recycled content targets for a variety of products as well as incentives to reward recycling environmental benefits and level the playing field with primary materials are absolutely essential. In addition, time has come to speed up the adaptation of the EU’s regulatory framework to create a well-functioning market for secondary materials and streamline requirements hampering circular value chains, keeping in mind the global nature of commodity markets which are key to balance supply and demand. Last but not least, decisive actions are needed to boost eco-design for re-use and recycling of all product categories. Products which cannot be recycled when they reach end-of-life by using best available techniques should not find their way on the internal market. We have a vested interest in working with producers to ensure that design for circularity becomes the new norm”, she concluded.
For more information, please contact: euric@euric-aisbl.eu
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EuRIC & SMART Joint Statement - Kenya Textile Recycling
The Secondary Materials and Recycled Textiles Association (SMART) and the European Recycling Industries’ Confederation (EuRIC) are urging Kenyan trade and health officials to quickly finalize guidelines for the safe handling of secondhand clothing (Mitumba) imports so that economic benefits of the industry may be rapidly restored.
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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 Factsheet - LCA Tyre Recycling Environmental Benefits
LCA study demonstrates positive climate and environmental benefits of the recycling of end-of-life tyres for artificial turf pitches.
Read more about EuRIC’s position by following the link below. -
Press Release - Environmental Benefits - Tyre Recycling - Infill Artificial Turf
Tyres are complex products subject to strict standards to fulfill mobility and safety requirements. Proper treatment of end-of-life tyres (ELTs) is essential to recover valuable materials of which tyres are made, namely rubber, steel and textiles. A new peer-reviewed study, based on Life Cycle Assessment (LCA) meeting ISO 14040 and ISO 14044 standards, made by the Danish FORCE Technology Institute and the German ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH1 demonstrates that mechanical recycling of ELTs into infill for artificial pitches is, by far, the most sound treatment option in terms of circularity and climate benefits. The LCA study shows that the mechanical recycling of an average of 400,000 tonnes of ELTs processed into infill for artificial turf - when compared with energy recovery - spares the environment 280,000 tonnes of CO2 emissions annually in the EU. To give an order of magnitude, ELT recycling as infill into artificial turfs offsets greenhouse gases emissions (GHS) comparable to the amount of GHS absorbed by 140,000 hectares (approx. 250 million trees) of forest land in the EU2.Tyres are complex products subject to strict standards to fulfill mobility and safety requirements. Proper treatment of end-of-life tyres (ELTs) is essential to recover valuable materials of which tyres are made, namely rubber, steel and textiles. A new peer-reviewed study, based on Life Cycle Assessment (LCA) meeting ISO 14040 and ISO 14044 standards, made by the Danish FORCE Technology Institute and the German ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH1 demonstrates that mechanical recycling of ELTs into infill for artificial pitches is, by far, the most sound treatment option in terms of circularity and climate benefits. The LCA study shows that the mechanical recycling of an average of 400,000 tonnes of ELTs processed into infill for artificial turf - when compared with energy recovery - spares the environment 280,000 tonnes of CO2 emissions annually in the EU. To give an order of magnitude, ELT recycling as infill into artificial turfs offsets greenhouse gases emissions (GHS) comparable to the amount of GHS absorbed by 140,000 hectares (approx. 250 million trees) of forest land in the EU2.
Continue reading the full press release by clicking on the link below.
1 Life cycle assessment of waste tyre treatments: Material recycling vs. coincineration in cement kilns, Force Technology with contribution by ifeu – Institut für Energie- und Umweltforschung Heidelberg GmbH, for GENAN Holding A/S, May 2020.
2 European Parliament News. Climate change: using EU forests to offset carbon emissions (Eurostat), April, 2018.