Open letter

To the kind attention of:

Ursula von der Leyen, President of the European Commission
Frans Timmermans, Executive Vice-President of the European Commission
Thierry Breton, Commissioner for Internal Market
Virginijus Sinkevičius, Commissioner for Environment, Oceans and Fisheries

Dear Ms von der Leyen,

Dear Mr Timmermans,

Dear Mr Breton,

Dear Mr Sinkevičius,

The signatories of the statement, namely CEWEP, EuRIC and FEAD, representing waste management and recycling industries at European level, would like to emphasize the need to safeguard the level of ambition of The European Green Deal¹ and of the new Circular Economy Action Plan² as an integral part of Europe’s COVID-19 recovery plan.

IWhile the signatories understand the need to re-shuffle some priorities in order to provide swift responses to the most urgent problems caused by the outbreak of COVID-19 which has disrupted the European economy including our industries, we see any reduction of the level of ambition set by the EU’s sustainable agenda as being the wrong answer. To the contrary, the post-crisis offers a momentum to make the EU Green Deal a motor of Europe’s economic recovery. The new Circular Economy Action Plan and the new Industrial Strategy for Europe are the right responses to the economic recession. In that respect, it is instrumental to direct a significant part of massive public investments expected through the European Recovery Fund towards circular industrial value chains and infrastructures needed to make Europe climate-neutral by 2050.

The waste management and recycling industries have played a key role for Europe’s economy and society during the ongoing COVID-19 crisis. With more than 400 000 local jobs, they are an essential partner to other industries, to innovative and green economic recovery.

Waste recovery and recycling outputs do not only substitute primary resources often imported from third non-EU countries but save significant amounts of greenhouse gas emissions and energy³.

Among the priorities set in the new Circular Economy Action Plan, the signatories would like to stress the absolute need to:

• Lay down measures to stimulate the demand for secondary raw materials in products through recycled content and green public procurement, incentives rewarding value chains that contribute to save GHG and energy to bridge circular economy and climate policy;
• Further strengthen the internal market and, in particular, fasten the creation of a well-functioning EU market for secondary raw materials thanks to simplified waste shipment procedures and EU-wide end-of-waste criteria;
• Speed up work on eco-design to ensure that tomorrow’s products will last longer and be easier to recycle when reaching end-of-life;
• Enhance investment certainty by implementing current recycling targets with the necessary financial support for countries lagging behind and consider the setting up of targets for industrial and commercial waste;
• Resume a fact-based discussion on proper treatment of residual waste⁴ in Europe, which cannot be recycled, through energy-recovery or final disposal⁵.

Furthermore, the signatories ask the European Commission and policy makers to prevent the leaking of waste streams suitable for recycling or recovery to large scale landfills. Existing recycling and landfilling targets for municipal waste need to be implemented without further delay and further ambitious measures are needed for other waste streams to be recycled and recovered, and diverted from large scale landfills. This would be a significant contribution to climate mitigation.

We stand ready to support your services in relation to the above-mentioned call for a recovery plan that supports a much needed transition towards a more circular and climate-neutral economy.

Yours sincerely,

^{1 The European Green Deal, COM(2019) 640 final.
2 A new Circular Economy Action Plan, COM(2020) 98 final.
3 ADEME/FEDEREC (2017). Environmental Assessment of Recycling in France according to Life Cycle Analysis Methodology or BDSV (2019) – Study of the Fraunhofer Institute’s Umsicht for the BDSV – The future of the steel scrap. Technical, economic, ecological and social characteristics of steel recycling.
4 The role of waste-to-energy in the circular economy, COM(2017) 34 final
5 CEWEP, June 2019, Residual waste treatment capacity calculations for 2035}