FEAD’s key demands for competition in waste markets and competitiveness of the sector
FEAD considers competitive waste markets and a competitive European waste management industry essential conditions for delivering the circular economy. Europe’s ambition to become a global leader in circularity by 2030 will require major private investment in collection, sorting, recycling and recovery capacity. This investment can only take place where operators have fair access to markets and where waste management and recycling are recognised as strategic industrial activities.
The EU is currently rolling out its competitiveness and industrial policy ambitions through the Clean Industrial Deal and initiatives such as the Industrial Accelerator Act (IAA). The Circular Economy Act (CEA) must ensure that the waste management and recycling sector benefits from equivalent industrial conditions while safeguarding open and fair competition within waste management markets.
- A strategic sector: permitting, State aid, and industrial recognition
FEAD expects the CEA to be not only an environmental policy, but also an industrial and market policy for the waste management sector. This means ensuring industrial conditions comparable to those being developed for primary manufacturing, notably regarding permitting and environmental impact assessment.
As it stands, the IAA does not place recycling on an equal footing with manufacturing. This omission must be corrected through the CEA. Waste management must be recognised as a strategic industrial activity, benefiting from streamlined and accelerated permitting procedures, as for other manufacturing activities, in particular, net-zero technologies.
FEAD also calls for recycling to be explicitly included in the scope of the Climate, Energy and Environmental State Aid Guidelines (CEEAG), allowing sorting and recycling operators to be compensated for high energy costs on the same basis as other manufacturing industries. The sector is currently not recognised as eligible for indirect cost compensation schemes or other energy-related State aid measures, placing it at a disadvantage compared to primary manufacturing.
Without such recognition, the cost gap between recycled and virgin materials cannot be closed, undermining the very market conditions the CEA seeks to establish.
- Fair competition in waste management markets
Fair competition must also be safeguarded within waste management markets themselves. FEAD is concerned about the growing recourse by municipalities to in-house procurement and public-public cooperation arrangements, which allow contracts to be awarded without an open tender.
While such arrangements may be lawful under specific conditions, their expanding use risks foreclosing market access for private operators and undermining the competitive pressure that drives efficiency, innovation, quality of service and private sector investments. The CEA should therefore reaffirm that public procurement of waste management services must, as a rule, proceed through open, transparent and fair competitive procedures.
Together with a cross-sectoral coalition of industry and business associations, FEAD issued in May 2026 a joint statement calling for stronger competition in public procurement. From a waste management perspective, the exclusion of in-house contracts and public-public cooperation arrangements from the scope of public procurement law – combined with the exemption of public waste management companies from VAT in some EU Member States – can create a significant competitive disadvantage for private companies and lead to shrinking markets, limiting their overall economic power and investment capacity.
This matters directly for the EU’s circular economy ambitions. Europe cannot simultaneously call for a major increase in private circular-economy investment while progressively restricting the markets in which private waste management companies can compete. Competitive tendering gives operators the visibility and stability needed to justify long-term investments in infrastructure, technology and innovation.
The European Investment Bank and the European Commission estimate that achieving the objectives of the Circular Economy Action Plan will require an additional € 1 229 billion in investments between 2025 and 2040. This translates to an annual investment gap of €82 billion, demanding a 68% increase over current levels. Notably, 27% of this gap is attributed to end-of-life activities, particularly recycling, underscoring the urgent need for investments in collection, sorting, and recycling technologies. Currently, 93% of circular economy investments originate from private sources, and this trend is expected to continue.
A competitive private waste management industry is therefore indispensable to closing Europe’s circular investment gap. The CEA should help reverse current market-closing dynamics and ensure that waste management contracts are awarded on the basis of quality, efficiency, innovation and environmental performance, through open and fair competition.
FEAD, the European Waste Management Association, represents the entire waste management value chain, from collection and sorting to recycling, energy recovery, and final disposal. It brings together the private waste and resource management industry across Europe through its 21 national member associations and associate members, which collectively represent over 3,000 companies. Together, the sector provides more than 500,000 local jobs and fuels €5 billion in investments into the economy every year. For more information, please contact: info@fead.be