On the occasion of the adoption of the EU Circular Economy Package ("Towards a circular economy: A zero waste programme for Europe") by the European Commission, four EU recycling industries are committing to work together and pursue the common goal of promoting circular economy.The four recycling industries include the Confederation of European Paper Industries (CEPI), the EU Non-ferrous Metals Industry Association (Eurometaux), Plastics Recyclers Europe (PRE) and the Groupement Européen de l'Industrie de la Régénération (GEIR). The four industries welcome a number of proposals included in the package such as: the progressive landfill ban on recyclable waste, better reporting of data, new requirements on waste exports to fight against illegal shipments of waste, the link between innovation and ambitious recycling targets.
While the Package is a right step forward in promoting recycling, the four recycling industries believe that a number of elements included in the package require further clarification:
- The proposed definition of recycling is too broad; it can create confusion with collection, sorting or pre-processing, while it should be clearly defined to favour high quality processing/recovery of materials so as to contribute to resource efficiency and a sustainable access to valuable materials. The absence of a robust recycling definition can lead to recycling targets miscalculation. The proposed change in the methodology to calculate recycling rates should serve ambitious targets but also consider industrial reality.
- The reference to high quality recycling, while very valuable, focuses too much on quantity and not enough supporting higher quality collection, sorting and recycling of the various types of materials. A more product centric approach to recycling which considers the entity of raw materials in specific product groups is recommended.
- End of waste status: the concept of quality treatment and recycling should be applied here too. If waste reaching end-of-waste status is simply exported outside the EU with no guarantee of quality treatment, the status will not contribute to the EU circular economy.
- Ambitious collection and recycling targets can be an important driver for increasing recycling levels. As an example, for waste oils, EU-wide recycling and collection targets should be introduced. Re-refining waste oils to base oils contributes to the EU circular economy and is a technically feasible way to manage this hazardous waste stream.
