Disclosure of information on unsold consumer products

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, would like to comment on section 3 of the Disclosure format, related to waste treatment operations. While we understand that waste management operators will not be directly responsible for filling in this information, as the responsibility is of the economic operators that discard unsold consumer products, in practice, several contractors may be involved in storage, logistics, and final waste treatment. As a result, waste operators are likely to be asked by the obliged parties to provide the relevant details.

However, the current template is not suitable for waste management purposes, and we therefore propose the following adjustments:

• Adapt the first column (CN-Code) or add a separate column for waste codes – The template should allow for the use of waste codes as an alternative to CN-Codes. Otherwise, we suggest adding an additional column next to the CN-Code column to specify the corresponding waste code, ensuring compatibility with existing waste management practices. Once a product becomes waste, traceability is conducted using the European List of Waste (EWL) codes. Please consider that the relevant products covered by this legislation listed in Annex II of the Discussion paper, could fall under the same waste code, making it impractical for waste operators to report CN-Codes.
• Remove the “% on number of items treated” column – Waste operators receive waste loads in bulk and are unable to provide a breakdown of treatment by the number of individual items. Additionally, the regulation itself does not require this level of detail. Therefore, we suggest to remove the “% on number” column.

• Clarify the scope of disclosure – The disclosure requirements should be limited to the first waste treatment operation to which the load was handed over. It should not mandate traceability of subsequent treatments applied to residues from this first operation, as it would not be feasible to distinguish these from other waste streams processed at later stages.

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 20 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fuelling €5 billion of investments into the economy every year.

For more information: contact us at info@fead.be