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Early Warning Report on Waste

Environment

In this early warning report, the Commission will assess Member States’ waste management performance and their prospect to reach the 2025 recycling targets and the 2035 landfill target. The report will identify Member States at risk of not meeting the 2025 recycling targets and provide them with recommendations on how to improve their performance, including by sharing best practices.

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Public consultation

ID: 13511

Lobbying Activity

23 responses

Consultation response

European Environmental Bureau, 25 Jul 2022

The Early Warning Mechanism required by the Waste Framework Directive is a good and important tool to mobilize Member States for a more ambitious and urgent action to decrease waste generation, improve separate collection, increase recycling and composting capacity and disincentivize incineration…

Consultation response

Confederation of European Paper Industries, 30 Jul 2022

The Confederation of European Paper Industries-Cepi welcomes the Commission’s intention to assess Member States’ progress towards reaching the recycling targets of municipal waste and packaging waste, and the 2035 landfill target. We endorse the policy maker’s intention to optimise waste management…

Zero Waste Europe Urges Stricter Enforcement of Waste Targets

Zero Waste Europe, 28 Jul 2022

The organization calls for stricter infringement procedures and decisive legal action against countries failing to meet recycling targets. They also advocate for a holistic European waste prevention plan to address insufficient infrastructure investment.
Stricter rules would help propagate their zero-waste city model across Europe by reducing incineration.
The incineration industry and underperforming national governments face legal pressure and lost investment incentives.

Huhtamäki pushes for mandatory recycling in the hospitality sector

Huhtamäki Oyj, 1 Aug 2022

The company advocates for mandatory take-back and recycling targets within the hospitality sector. They also request investments in sorting infrastructure and consistent EU collection rules. They highlight that fiber-based packaging, including paper cups, is fully compatible with recycling systems.
Mandatory targets would secure a steady supply of valuable fiber resources for Huhtamaki.
Hospitality businesses would face new costs and logistical burdens to meet mandatory targets.

Consultation response

European Paper Packaging Alliance, 1 Aug 2022

The European Paper Packaging Alliance (EPPA) is a not-for-profit association representing food and food service packaging companies from across Europe. EPPA’s priority is to provide paper-based low carbon and health-safe products with a low environmental impact and improved recycling solutions to…

Seda Group highlights Italy’s high paper packaging recycling rates

Seda International Packaging Group, 1 Aug 2022

Seda asserts that fibre-based packaging like paper cups is effectively collected and recycled. They claim that thin plastic coatings do not prevent effective recycling in standard paper streams.
Proving high recycling rates protects their business from future regulatory restrictions on single-use paper.

ACE Urges Mandatory 90% Collection Target for Beverage Cartons

The Food and Beverage Carton Alliance, 1 Aug 2022

The industry calls for a 90% mandatory collection target for beverage cartons by 2030. They also want cartons included in deposit return schemes unless national collection rates are already high.
Guaranteed collection volumes would provide investment predictability and create a level playing field with competitors.
Plastic packaging manufacturers may lose their current regulatory advantage over the beverage carton industry.

Metal Packaging Europe urges improved sorting for recycling targets

Metal Packaging Europe External Affairs ASBL, 26 Jul 2022

Metal Packaging Europe supports the report to identify Member States missing recycling targets. They claim optimized separate collection and sorting are prerequisites for high-quality recycling. They also suggest incentivising modern sorting equipment and effective deposit return systems.
Well-sorted aluminium and steel scrap constitutes a major resource for their new products.

Waste-to-Energy Industry Urges Better Enforcement of EU Waste Laws

Confederation of European Waste-to-Energy Plants, 28 Jul 2022

The organization calls for stronger implementation and enforcement of existing EU waste legislation, focusing on reducing waste generation and improving separate collection. They emphasize the need for quality recycling standards, better product design for recyclability, and ambitious future legislation tackling additional waste streams beyond municipal waste.
This positions waste-to-energy facilities as essential infrastructure for meeting EU targets and climate goals.
Landfill operators lose business as the industry pushes to reduce landfilling of organic waste.

European Bioplastics urges EU to recognize compostable polymers

European Bioplastics, 29 Jul 2022

The organization asks that the report recognize biodegradable and compostable polymers as tools for waste prevention. They also want industrial composting recognized as a primary solution for collecting and recycling organic waste.
Official recognition would validate their products as recycled materials, facilitating market growth across all Member States.
Member States with restrictive rules would face pressure to overhaul their existing waste management policies.

NGO ZERO blames underfunding for Portugal's recycling failure

ZERO - ASSOCIAÇÃO SISTEMA TERRESTRE SUSTENTÁVEL, 1 Aug 2022

ZERO calls for a shift from ecopoints to door-to-door collection and better treatment of organic waste. They demand an end to fraudulent packaging declarations and the removal of economic incentives for incinerating recyclables.
Stricter waste management enforcement would advance the organization's mission of promoting sustainable development.
Electronics manufacturers and packaging producers would lose profits by paying higher waste management fees.

France Nature Environnement demands moratorium on new waste incinerators

France Nature Environnement, 1 Aug 2022

FNE advocates for a moratorium on new incinerators and stricter biowaste separation targets. They argue that chemical recycling should be classified as energy recovery rather than recycling. The organization also stresses the importance of waste prevention over landfill or incineration.
This would force a shift from incineration to recycling, lowering environmental impact.
Industry players in waste-to-energy and chemical recycling would face capacity limits and financial risks.

FNADE backs EU recycling alerts while seeking industrial incentives

Fédération Nationale des Activités de Dépollution et de l'Environnement, 29 Jul 2022

FNADE supports the warning mechanism to identify Member States at risk of missing deadlines. They urge mandatory recycled content and including waste-to-energy within the green taxonomy. They also demand competitive access to recycled raw materials without priority rights.
Taxonomy inclusion would provide the necessary financial incentives for advanced treatment infrastructure.
Large producers who want priority access to recycled materials would lose their advantage.

Consultation response

CITEO, 1 Aug 2022

Citeo, the French mission-driven company in charge of the extended producer responsibility (EPR) for household packaging and graphic papers, would like to share its analysis of collection, sorting and recycling in France with the Commission, as part of the early warning report aimed at assessing…

Consultation response

INDELOOP Ltd., 31 Jul 2022

European goals for the green transition and especially with the circular economy model. We believe only the creation of a quality legislative framework with an effective implementation strategy can help Europe reduce waste pollution. EU has clearly stated its waste treatment targets.…

ESWET: Waste-to-Energy is vital for EU recycling targets

European Suppliers of Waste-to-Energy Technology, 1 Aug 2022

ESWET argues Waste-to-Energy is a crucial partner for recycling non-recyclable materials. They want its role in meeting landfill targets to be officially recognized.
This ensures a permanent role and market demand for thermal treatment technologies.
Landfill operators lose business as waste is diverted to energy recovery facilities.

Consultation response

CONSORZIO NAZIONALE IMBALLAGGI, 1 Aug 2022

Extended Producer Responsibility is the main measure set by the waste framework law to achieve the targets. Organisations set up behalf and /or by Producers to fulfil such obligation are reporting waste management, and in some case also waste prevention, according to European and National rules and…

Consultation response

AVR-Afvalverwerking B.V., 1 Aug 2022

Introduction AVR welcomes the review of the Early Warning Report (EWR) by the European Commission, introducing reports which will effectively keep EU Member States on the right path towards achieving their targets laid out in the ‘2018 Waste Package’. In particular, AVR supports the goal of the…

Consultation response

Chamber of Commerce and Industry Romanian-German, 29 Jul 2022

Please review the attached feedback of AHK Romania

Consultation response

European Bioeconomy Bureau, 1 Aug 2022

The consequences of the failure to create binding targets for the recycling of the largest municipal waste stream, biowaste, is now being seen. Although all EU member states will have to implement separate collection of biowaste from 2024 many have still not begun to even plan the changes needed to…

Czech district heating association calls for immediate landfilling ban

Association for District Heating of the Czech Republic, 29 Jul 2022

The association suggests that EU reports should prioritize tracking greenhouse gas emissions and fires at landfill sites. They urge the Commission to recommend a total ban on landfilling municipal waste as soon as possible.
Diverting waste from landfills would secure a fuel source to help the sector replace coal.
Landfill operators would lose business as nearly half of municipal waste is currently buried.

Senior Corporate Silver Spoon slams waste report legal basis

Senior Corporate Silver Spoon, Environment & Nature Association/Ezüstkanál Nyugdíjas Társasági, Környezet- és természetvédelmi Egyesület, 6 Jul 2022

The association demands correcting the legal basis, as a directive cannot serve as one. They also urge the inclusion of environmental engineering expertise.
Correcting the legal framework would align the report with established international environmental laws.
Citizens lose out as environmental targets may not be achieved without specialized engineering input.

Asociatia Principia slams high costs of European green transition

Asociatia Principia, 6 Jul 2022

The association argues taxpayers are unfairly blamed for waste problems created by EU laws. They challenge the polluter-pays principle regarding fossil fuels and high green energy costs.
This would protect consumers from the financial burden of new environmental taxes and mandates.
Environmental interests are harmed if the transition to sustainable energy is delayed or abandoned.