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December 17, 2020

FEAD Position Paper on the Conclusions of the Council of the 17th of December 2020 on the new Circular Economy Action Plan

FEAD, the European Waste Management Association representing the private waste and resource management industry across Europe welcomes the Council’s draft Conclusions on the new Circular Economy Action Plan (CEAP).

FEAD has distinguished some points as very positive, and which should be encouraged:

  • The highlighted need for mandatory recycled contents (paragraphs 10, 32, 37).
  • The need for mandatory Green Public Procurement criteria (paragraph 20).
  • The importance given to the need to boost the market for secondary raw materials (SRMs) (paragraphs 37, 59, 60 and 61).
  • Setting up standards for food-grade (paragraph 34).
  • Recognising the need to strengthen separate collection systems and selective sorting systems, while acknowledging that there is no EU harmonisation of collection schemes (paragraph 56, and 63).
  • The need for a clarification on bio-based, biodegradable and compostable plastics (paragraph 39).
  • Targets for recycling demolition and construction waste (paragraph 48).
  • The need to address all upcoming revisions of waste legislation by grouping related initiatives, i.e., by establishing a unique legislative initiative (paragraph 55).
  • The need to regulate “waste exports to third countries that could be harmful to the environment and human health in the countries of destination, as well as to ensure effective controls of shipments and to strengthen enforcement against illegal shipments of waste while at the same time simplifying procedures, without affecting the level of protection of the environment, to ensure a smoother functioning of waste shipments within the EU which is crucial for building up strong secondary raw material markets” (paragraph 59, and also paragraph 37 on the need to “limit the export of plastic waste outside the EU”).
  • The significance of funding and investments in the field of innovative circular entrepreneurship and infrastructure, and the importance of the sustainable finance agenda and especially the EU Taxonomy (paragraph 72), and towards incentivising the competitiveness of circular business models (paragraph 69).

However, we have identified some important gaps and problematic points in the draft conclusions:

1) Highlighting the need to higher-up the treatment of waste pursuant to the waste hierarchy, should be the occasion to acknowledge the role of Waste-to-Energy in the circular economy, instead of recognising the importance of separate collection, sorting and high-quality recycling with only a regard to “minimising the need for incineration” (paragraph 63).

2) We do not understand what the term “untreated waste” means, in the sentence “end landfilling of untreated municipal waste” (paragraph 63). A genuinely integrated waste management should be promoted to successfully implement the waste hierarchy, and to higher-up the treatment of waste. Strong measures to boost the demand for recyclates, public support for investment in selective collection and sorting, and in capacities for recovering non-recyclable waste are needed.

Such strong measures are crucial to ensure the success of the CEAP by the end of 2030. By this date there should be a strong movement within the EU with no landfilling of recyclable or recoverable waste, and in Member States where landfilling is still dominant, the necessary measures should be enforced. Landfilling/disposal must be the last resort in the hierarchy for residual waste. To avoid “harmful effects”, safe and environmentally sound operating conditions must be ensured.

3) There is a persistent focus on EPR schemes. (paragraphs 36, 37, 43, 46, and 54). EPR schemes are useful, for instance for certain household waste flows to help put in place selective collection schemes. But we, the private waste management industry, are concerned that EPR schemes compete against performant existing B-to-B waste management contracts, particularly for industrial and commercial waste.

4) Deposit and return schemes (paragraph 37) can be good alternatives for waste packaging that are not collected door-to-door. But such schemes should not be promoted as a one-size-fits all solution at EU level and they compete with other selective collection schemes already in place.

5) The need for harmonised end-of-waste criteria and standardisation (paragraph 62) is welcomed and we appreciate EU-wide E-o-W criteria when feasible (paper, construction, and demolition waste, etc.). But for other waste flows, such as plastics, we have already pointed out that setting up E-o-W criteria is not always feasible.

FEAD is committed to the objectives of the European Green Deal and considers the above-mentioned aspects apt for providing the adequate stimuli both for addressing GHG emissions and enhancing of the circular economy in Europe.

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