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FEAD issues Joint statement on the European Commission’s legislative proposal for a regulation establishing a framework to facilitate sustainable investment

The undersigning associations noticed with great concern that the Commission’s proposal for a regulation establishing a framework to facilitate sustainable investment (also known as “taxonomy”), lists activities like “avoiding incineration and disposal of waste” as sustainable (Art. 9.1.i), while activities that “[lead] to a significant increase in the generation, incineration or disposal of waste” (Art. 12.d) are considered as harming environmental objectives.

For waste that contains substances of concern and therefore cannot be recycled in an environmentally sound way, incineration is the only sustainable option. It destroys these substances, and avoids that pollutants are spread into the environment.

Sustainable investment should follow the integrated approach and respect the waste hierarchy. As indicated in Article 4 of the Waste Framework Directive, life-cycle thinking should be taken into consideration when applying the waste hierarchy, in order to choose the most environmentally sustainable waste management option.

We need an integrated waste management approach with an appropriate and sustainable interaction of quality recycling, efficient energy recovery and environmentally sound disposal of waste that cannot be recovered. In order to achieve high recycling rates with low landfill rates, the whole waste management system from communication and collection to treatment of the residual fraction must be carefully designed and executed. Only with such a holistic process, can effective waste management which prevents environmental degradation, protects human health and generates recovered raw materials and energy to feed a circular economy.

Read more about our proposed amendment and reasoning here.