The Waste Shipment Regulation (WSR) is an important piece of legislation at EU level to ensure safe shipments of waste, traceability and to guarantee an appropriate treatment of waste at its final destination. Therefore, FEAD has actively followed the evaluation of the current Waste Shipment Regulation by answering the public consultations, sending a position paper and participating in both workshops.
Although FEAD members understand that this procedure of evaluation is part of a standardised European review for a better regulation, we nevertheless regret that the assessment of the WSR has not placed a greater emphasis on identifying solutions at this stage and ensuring that the WSR is not just preferable to national legislation, but as effective as possible at achieving its intended aims, including facilitating the recovery of secondary raw materials.
That’s why, we stress again that the shortcomings we have identified are not due to the WSR itself, but to inconsistencies or problem of interpretation with other related pieces of the legislation (i.e differences of interpretation between waste/non-waste, hazardous/non-hazardous waste and recovery/disposal) or with differences of enforcement within the EU Member States. However, we do believe that part of the solution to this lies in amending legislation.
You may find our letter sent to the European Commission here.