BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V.

BDE

BDE represents 750 German and European companies in recycling, waste management and water sectors.

Lobbying Activity

German recycling industry urges inclusion in Advanced Materials Act

12 Jan 2026
Message — Include materials from existing recycling streams, especially mineral materials, in the Act. Adopt binding recycled content quotas and harmonized end-of-waste certifications. Fund sensor-based processing and digital material passports to improve resource efficiency.123
Why — This would grant recycled products equal legal status with primary materials, boosting market competitiveness.4
Impact — Primary material producers lose their regulatory advantage over secondary raw material suppliers.5

BDE Urges EU to Better Include Waste-to-Energy in Taxonomy

5 Dec 2025
Message — BDE requests removing the exclusivity rule for biogenic energy recovery to reflect actual plant operations. They also want carbon capture technology and private waste collection to be eligible for green investment.123
Why — This would enable German waste management companies to secure more sustainable financing.4
Impact — Bio-based plastic producers would lose their classification as contributing to a circular economy.5

Meeting with Andreas Glück (Member of the European Parliament)

18 Nov 2025 · Kreislaufwirtschaft

Meeting with Christian Doleschal (Member of the European Parliament) and Bundesarchitektenkammer e.V.

5 Nov 2025 · Public Procurement

German recycling association demands stricter green procurement standards

14 Oct 2025
Message — BDE requests higher recyclability targets for wind blades and solar panels. They want manufacturers held accountable for designing components that are easily separated.123
Why — Stricter standards would increase demand for domestic recycling services and secondary materials.45
Impact — Technology manufacturers would face higher costs to meet mandatory design-for-recycling standards.6

Meeting with Pascal Arimont (Member of the European Parliament)

24 Sept 2025 · Lithium battery fires and waste management

Response to Review ecodesign electric motors and variable speed drives.

22 Sept 2025

The Federation of the German Waste Management, Water and Circular Economy Management Industry (BDE) welcomes the European Commissions Call for evidence to review the ecodesign measures on electric motors and variable speed drives. This entails the possibility to further improve the regulation by including better information requirements that facilitate the end-of-life treatment and reiterate the need to strengthen treatment infrastructures and secure closed CRM flows in Europe. We suggest the following points: Tackling a lack of information about product materials through the DPP: The recycling of neodymium and recyclable electric motors from scrap and waste electrical equipment is often very costly and economically unviable. A key problem is the lack of knowledge about where the critical raw materials (CRM) are located in the old appliances and in what quantities they were used. Mandatory labelling or colour coding of recyclable components and a description of the material composition, for example via a digital product passport, could improve the ability of recyclers to identify, separate, and recover CRMs Strengthening recycling infrastructure and demand for closed critical raw material flows: Even with improved information and labelling, Europe still faces a shortage of recycling facilities capable of extracting and processing CRMs from motors and drives. Currently, due to the fact that the procurement of primary materials from non-European countries remains usually cheaper than the production of recycled materials, there is a lack of the necessary treatment infrastructure for processing raw materials, as well as a lack of suitable customer structures. In the short term, therefore, promoting the construction of appropriate recycling facilities and, in the medium term, a gradual increase in the use of recycled materials via Minimum Recyclate Content Requirements can help to stimulate demand for recycled critical raw materials.
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Meeting with Jan Ceyssens (Cabinet of Commissioner Jessika Roswall)

17 Sept 2025 · Address the Board of Directors of the BDE (Federation of the German Waste-, Water- and Circular Economy Management Industry)

Meeting with Christian Doleschal (Member of the European Parliament, Shadow rapporteur)

7 Jul 2025 · Public Procurement

Meeting with Marion Walsmann (Member of the European Parliament)

2 Jul 2025 · Internal Market Strategy

Meeting with Andreas Glück (Member of the European Parliament)

17 Jun 2025 · Environment Policy

Meeting with Aurel Ciobanu-Dordea (Director Environment) and FEAD and Confederation of European Waste-to-Energy Plants

22 May 2025 · Exchange of views on the feasibility study to include waste incineration and landfilling in the ETS Directive (greenhouse gas emission allowance trading).

Meeting with Jessika Roswall (Commissioner) and

5 May 2025 · Exchange on Commission priorities in the area of environment and circularity

Response to Shipments of waste - systems interoperation for electronic submission and exchange of information and documents

2 Apr 2025

Please find attached our feedback on Waste shipments interoperability of systems for electronic submission and exchange of information and documents.
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German waste association urges broader EU Taxonomy reporting relief

26 Mar 2025
Message — BDE requests a materiality test to exclude non-material activities from internal collection. They also advocate for including waste-to-energy and bottom ash recovery as sustainable.12
Why — The industry would save billions in administrative expenses and free up excessive personnel.34
Impact — Investors lose access to granular operational expenditure data and specific breakdowns of activities.56

BDE Demands Stricter EU Limits on Municipal Procurement Privileges

7 Mar 2025
Message — The BDE calls for restricting in-house procurement exemptions that favor municipal companies over private firms. They demand mandatory green criteria and a European preference principle for recycled materials. Finally, they propose raising the activity threshold for in-house awards to 100%.123
Why — This would allow private firms to reclaim market share from municipal entities and non-EU competitors.45
Impact — Municipalities and non-European recyclate exporters would lose their current competitive and regulatory advantages.67

German circular economy industry demands binding water reuse rules

4 Mar 2025
Message — The BDE supports improving infrastructure for water reuse and rainwater storage to fight droughts. They argue that treated wastewater must be a key source for irrigation in urban areas. Finally, they want the Commission to replace non-binding advice with mandatory legislative rules.123
Why — Mandatory reuse systems would create significant new business opportunities for private wastewater companies.4
Impact — EU Member States would face new mandatory requirements and increased infrastructure costs.5

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

14 Feb 2025 · Clean Industrial Deal and the EU Circular Economy Act

German waste industry urges removal of barriers for private recyclers

31 Jan 2025
Message — The BDE demands an end to tax and procurement advantages for public waste companies. They also urge the Commission to ease rules on waste shipments and lift export bans for plastic and electronic waste.123
Why — Removing these barriers would decrease compliance costs and open new markets for private recycling operators.45
Impact — Public waste management authorities would lose their protected status and tax-free competitive edge over private firms.67

Meeting with Hildegard Bentele (Member of the European Parliament)

27 Nov 2024 · Waste Managment

German waste industry urges Commission to reduce biofuel reporting burdens

7 Nov 2024
Message — The BDE requests that reporting apply only to first collection points instead of individual origins. They propose extending reporting deadlines to 30 days and implementing a transition period until 2025. The group also demands stricter controls to prevent auditors from accessing sensitive supplier data.123
Why — This would minimize administrative overhead and protect proprietary customer and supplier data from unauthorized access.45
Impact — European regulators would lose granular data intended to ensure biofuel sustainability and prevent fraud.6

Meeting with Kerstin Jorna (Director-General Internal Market, Industry, Entrepreneurship and SMEs)

6 Nov 2024 · Clean Industrial Deal

Meeting with Andrea Wechsler (Member of the European Parliament) and BASF SE and

1 Oct 2024 · EU Energy and Industry Policy

Meeting with Andreas Glück (Member of the European Parliament) and Liquid Gas Europe

31 Jul 2024 · Climate and Energy Policy

German waste industry urges EU to include short-lived carbon capture

16 Jul 2024
Message — BDE requests including short-term carbon cycles like synthetic fuels rather than just permanent mineralization. They also want waste incineration CCU recognized under the EU Taxonomy to secure investment.12
Why — This allows waste plant operators to secure vital funding for expensive carbon capture infrastructure.34
Impact — Fossil fuel suppliers face reduced demand as recycled carbon replaces virgin sources in production.56

Meeting with Jens Geier (Member of the European Parliament)

8 Jul 2024 · Exchange on Expectations on the new European Parliament and EU Commission (EU Industry Policy, Global Trade, Green Deal, Energy Policy)

Response to Environmental Implementation Review 2025

5 Jul 2024

Please find attached our feedback on the EU environmental law 2025 implementation review.
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Meeting with Hildegard Bentele (Member of the European Parliament)

18 Apr 2024 · Ongoing files in waste management and priorities next term

Meeting with Daniel Freund (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · Exchange with economic associations

Meeting with Rasmus Andresen (Member of the European Parliament) and Bundesverband der Deutschen Industrie e.V. and

5 Mar 2024 · socio economic situation

Response to Technical specifications for the preparation of risk management plans to ensure the safe reuse of treated waste water in

8 Feb 2024

Please find attached our feedback on the European Commission's Draft Delegated Act on reusing wastewater in agriculture.
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Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

Please find attached our feedback on the 8th Environment Action Programme Mid-term Review.
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German recycling industry seeks free allowances for heat by-products

2 Jan 2024
Message — The BDE requests deleting requirements that fuel combustion must primarily generate heat. Excluding processes producing heat as a by-product unfairly penalizes many efficient technologies. The association calls for removing restrictive language to protect integrated production processes.12
Why — This avoids the unnecessary penalisation of efficient technologies that use integrated heat generation.3
Impact — The EU's climate progress and innovative manufacturers lose when efficient recovery is penalized.4

BDE supports new EU car recycling rules with less bureaucracy

4 Dec 2023
Message — The association supports mandatory recycled plastic quotas and a digital vehicle passport. They demand removal of gas tanks before shredding to prevent explosions. They also oppose excessive reporting requirements and too many delegated acts.123
Why — The rules create a market for recycled plastics and curb illegal dismantling.456
Impact — Exporters lose the ability to sell non-roadworthy vehicles as used cars abroad.7

BDE Urges EU to Cut Waste Industry Reporting Red Tape

1 Dec 2023
Message — BDE seeks standardized ETS rules and exemptions for recycled materials from due diligence laws. They also demand shorter permitting procedures and a level playing field for private recyclers.123
Why — Streamlining rules would lower administrative costs and improve the marketability of recycled raw materials.45
Impact — Public sector entities may lose their competitive advantage over private companies in public tenders.6

Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Nov 2023

Please find attached the BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V. (Federation of the German Waste, Water and Circular Economy Management Industry)'s detailed feedback on the Revision of the Waste Framework Directive. A short summary of our responses can be found here: While the BDE strongly supports the aim of the proposed revision of the Waste Framework Directive to reduce the environmental and climate impact of the textile and food sector, there are some aspects concerning textiles in the Commissions proposal that should be amended. Primarily, they need to be corrected to ensure the regulations effectiveness and the comprehensiveness of the circular economy framework. Changes should be made to the revisions text on the separate collection of used and waste textiles and the introduction of a sorting obligation for all market participants, the inclusion of all textile producers in the circle of producers, the critical consideration of special rules for social enterprises and the mandatory designation of extended producer responsibility organisations (PROs). Furthermore, while the BDE in principle very much supports a comprehensive revision of the entire Waste Framework Directive, it would have required a corresponding stakeholder consultation and an impact assessment appropriate to its scope prior to any legislative changes. Since neither has taken place, an extension of the scope beyond textiles and food waste is not advisable. Moreover, in light of the fast-approaching end of the legislative period (European elections in June 2024), a timely finalisation of the Parliaments position now would be preferrable. Thus, the BDE advocates against the inclusion of additional elements at this stage but calls for a broad revision of the Waste Framework Directive in the next legislative period.
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German waste industry urges flexible EU carbon reporting rules

23 Aug 2023
Message — The associations request flexible measurement rules and lower, more realistic pollution values for waste. They also propose a transitional period to avoid immediate, unfeasible technical adjustments.123
Why — This would lower operational costs and prevent companies from facing excessive technical and administrative reporting requirements.45

German waste industry urges EU to allow national recycling labels

20 Jul 2023
Message — BDE requests removing the prohibition on introducing new national or regional environmental labels. They argue Member States should retain national labels to support green public procurement.12
Why — Maintaining national labels helps their members win public contracts by highlighting recycled content.3
Impact — Multinational companies lose a level playing field if diverse national labels are allowed.4

Response to European Critical Raw Materials Act

30 Jun 2023

Please find attached our feedback on the European Commission's Proposal for a Critical Raw Materials Act.
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BDE Demands More Funding and Faster Permits for Recycling

27 Jun 2023
Message — The BDE demands specific funding from existing EU programs and shorter permit timelines. They advocate for including biomass and carbon capture as strategic net-zero technologies. Recycling should receive state aid for energy costs to ensure market competitiveness.1234
Why — These changes would reduce energy expenses and increase investment incentives for recycling companies.5
Impact — Primary material manufacturers would lose their unfair competitive price advantage over recycled goods.6

German waste association urges recognition of waste-to-energy as sustainable

3 May 2023
Message — BDE wants thermal recovery of non-recyclable waste recognized as a sustainable climate activity. They claim it avoids methane from landfills and replaces fossil-based energy sources.12
Why — Taxonomy recognition would enable waste companies to market their energy as sustainable.34
Impact — Landfill operators would lose business as waste is diverted to thermal recovery plants.56

German waste association BDE urges realistic EU taxonomy recycling targets

3 May 2023
Message — The BDE requests that sorting and recovery be recognized as independent activities that both contribute to the circular economy. They advocate for recycled content quotas that are realistic and aligned with other EU packaging regulations. Additionally, they urge the inclusion of thermal waste recovery to recognize its role in reducing methane emissions.123
Why — This would reduce compliance costs and allow companies to qualify for green financing with current technology.4
Impact — Environmental groups lose if lower recycling targets for plastic and construction waste are adopted.5

German waste industry urges mechanical recycling priority in EU law

24 Mar 2023
Message — The group wants packaging design to prioritize mechanical recycling over chemical methods. They also advocate for mandatory participation in collective producer responsibility systems.12
Why — This ensures long-term investment security for their existing mechanical recycling facilities.3
Impact — Chemical recycling companies lose out as their technology is relegated to a subordinate role.4

German waste association supports producer responsibility for wastewater treatment

10 Mar 2023
Message — BDE supports the "introduction of an extended producer responsibility" to fund a "quaternary treatment stage" for filtering micropollutants. They argue the "veterinary medicine industry must also be subject" to these pollution costs. They also suggest energy "obligations should start with plants" serving 100,000 people to stay "realistic."123
Why — This would shift treatment costs to manufacturers and lower compliance burdens for smaller facilities.45
Impact — Pharmaceutical and veterinary firms would face new fees to fund treatment of their pollutants.678

Response to European Critical Raw Materials Act

25 Nov 2022

Please find attached our feedback to the European Commissions announcement of a proposal for a European Critical Raw Materials Act.
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German waste association urges inclusion of waste-to-energy in fuel rules

17 Jun 2022
Message — The BDE recommends including thermal treatment of non-recyclable waste as an accountable carbon source. They also propose removing the 2035 deadline to provide enough time for investment returns.12
Why — This would allow waste management firms to commercialize captured carbon and secure long-term investment.34
Impact — Future fuel project developers lose because current rules prevent long-term financial viability.56

Response to Update of concentration limit values of persistent organic pollutants in waste

22 Dec 2021

Feedback on the Proposal for a Regulation amending Annex IV and V of the POP-Regulation The BDE fully supports the objectives of the European Commission to protect human health and the environment from harmful effects of persistent organic pollutants (POPs). In this context, the BDE is committed to contribute to an adequate balance between the European Green Deal’s objectives to achieve a toxic-free environment, increase recycling and circular economy and effectively reduce greenhouse gas emissions. Having regard to the Commission’s Proposal, however, we underline that the proposed changes for stricter POP limits lack technical feasibility in practice and would cause great challenges to the European recycling industry. Despite the legitimate interest in reducing POPs in waste, the proposed thresholds would have negative impact on the environment and run counter to the transition to a circular economy. The following three arguments oppose the lowering of the thresholds: 1. Less recycling and more CO2 emissions The planned changes for stricter POP limits cause great challenges because they are not feasible in practice. Regarding WEEE recycling, for instance, a large part of the plastic fractions would no longer be available for recycling and would have to be incinerated. With a CO2 savings potential of 4 tonnes per tonne of recycled plastic for the WEEE fraction compared to new plastic, it must therefore be carefully examined what added value can be expected from ever stricter thresholds for waste containing POPs and whether this is in reasonable proportion to the costs of non-recycling. The consequences are certainly not intended from an environmental point of view. 2. Less investments in circular economy In recycling plastics from WEEE our industry focuses primarily on the plastic materials ABS, PS and PP. Here, established separation processes based on density measurements allow the safe exfiltration of plastic fractions of concern that contain brominated flame retardants. Furthermore, research is being conducted on various processes (sensor-based technologies, solvent-based processes) that should make it possible to separate other types of plastics (PC-ABS, PA, PMMA) in the future. The current thresholds for POPs can be met (bromine content of 1150 ppm possible and in line with Cenelec standard EN-60625). However, if the threshold values are set further and further down, moreover at very short intervals (the last change in POP limits was in 2019 only), industry can no longer keep up through research and development. As a result, investments in corresponding processes and plants are no longer worthwhile because of the legal ambiguity and, above all, future legal uncertainty. This does not mean that stricter thresholds will not be achievable in the future but the Commission's planned quasi-phase-out comes too soon according to the current state of technology and would mean the end of many innovations. 3. Technical infeasibility Another problem is the control of compliance with the thresholds. The XRF screening method, measuring with X-ray fluorescence, for instance, is used to detect the bromine content in WEEE. This is a complex measurement method that was developed to ensure compliance with the RoHS Directive, which allows bromine levels of up to 1,000 mg/kg. While it is possible to reliably detect lower contents in standardised samples, this is not possible for mixed plastic waste occurring in practice. It contains many different additives. The consequence is that tests deliver very inaccurate results. This means that the control effort for compliance with the POP regulation is constantly increasing while there are to date no suitable methods that can test such low values in the required level of detail. This makes the recycling of WEEE plastics more expensive or technically impossible. 4. Conclusion All in all, we must therefore conclude that the proposed changes in POP limits come too early.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

Der BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Rohstoffwirtschaft e. V. ist mit rund 750 Mitgliedsunternehmen die stärkste Vereinigung der deutschen Entsorgungs-, Rohstoff-, Recycling- und Wasserwirtschaft und vertritt zahlreiche Mitglieder, die aus Abfällen wertvolle erneuerbare Kraftstoffe oder elektrische Energie gewinnen und damit aktiv zum Klimaschutz und einer funktionierenden Kreislaufwirtschaft beitragen. Aus diesem Grund sind die Regelungen der Erneuerbaren Energien Richtlinie von großem Interesse. Der BDE begrüßt ausdrücklich die Anstrengungen der Europäischen Union auf dem Weg zu einem klimaneutralen Kontinent 2050 mit dem gesetzten Zwischenziel von 2030 zu dessen Erreichen das “Fit for 55” Paket der Europäischen Kommission beitragen soll. Insbesondere die Nachhaltigkeitskriterien und Kriterien für Treibhausgaseinsparungen für Biokraftstoffe, flüssige Brennstoffe und Biomasse-Brennstoffe des Artikel 29 Richtlinienvorschlages sind von Relevanz. Diese weisen eine Regelungslücke für den Bereich des Altholzes auf. Altholz ist ein wertvoller, nachhaltiger Rohstoff, der nach Möglichkeit im Rahmen sinnvoller Kaskadennutzung einer stofflichen Verwertung zugeführt werden muss. Dies ist jedoch für einen erhebliche Menge des Altholz nicht möglich. Dieser Anteil wird in häufig hocheffizienten KWK-Anlagen genutzt, um erneuerbare, klimaneutrale Elektrizität und Wärme bereitzustellen. Teile der Altholzfraktion fallen unter den Begriff “solid municipal waste” und sind daher von den in Art.29 Absatz 10 festgelegten Kriterien für Treibhausgaseinsparungen ausgenommen. Dies gilt z.B für Sperrmüll aus privaten Haushaltungen. Andere Altholzfraktionen wie z.B. Bahnschwellen sind von dem Begriff nicht umfasst. Die Bestimmung der THG Emissionen des Brennstoffs Altholz ist aufgrund der äußerst unterschiedlichen Herkunft, Zusammensetzung und komplexer Lieferketten sehr aufwendig. Es wird nach Altholzkategorien gehandelt, die sich aus vielen unterschiedlichen Quellen (Sperrmüllsammlungen, Bauabfälle, Reststoffe der Holzindustrie) zusammensetzten. Es sind zahlreiche Sachverhalte zu erfassen, z. B. Bagger des Abbruchunternehmens, Aufteilung in der Industrie auf Emissionen des Produkts und des Reststoffs. Diese Situation ist mehr der vergleichbar, die zu dem Ausnahmetatbestand “solid municipal waste” geführt hat und sollte folglich gleichbehandelt werden. Alternativ bietet sich eine Aufnahme von geeigneten Standardwerten für Altholz als eigene Kategorie in Anhang VI RED II an. Hier könnte man sich an den Standardwerten von Holzschnitzeln aus Industriereststoffen orientieren.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

25 Aug 2020

BDE, the Federation of the German Waste, Water and Raw Materials Management Industry, welcomes the revision of the 30-year-old Sewage Sludge Directive (SSD) to match the contemporary needs and policy ambitions of the European Green Deal. In the context of a green and circular transition, the questions of sludge, the valuable biological resource resulting from wastewater treatment, needs to be carefully considered. The ongoing review of water-related policies has already underlined this need. For example, the quality of sewage sludge could be improved through a successful revision of the urban wastewater treatment directive. In general, the safe and efficient use of treated sewage sludge-products, that meet strict quality standards should be maintained as a proven means of returning valuable nutrients to the cycle. It is crucial that land use criteria are identical or at least consistent between the different fertilizing materials and crop supports (concerning the safety threshold, agronomic efficiency, dose input, etc.). For that reason, a quality assurance system for sewage sludge products should be established, ranging from the examination of the recorded wastewater origins to the treatment process (treatment, digestion and conditioning) and product testing. This quality assurance system should set uniform limit values throughout the EU. An obligation to recover phosphorus should be specified for all sludges to strengthen Circular Economy, resource efficiency and climate protection. However, this does not necessarily have to be achieved by technical processes. The soil-related use of sewage sludge as fertiliser is also a form of P-recycling. The sewage sludge directive should be technology neutral on the wastewater treatment technologies. A general ban on landfilling of all sewage sludge (raw sludge, stabilised, non-stabilised, untreated/treated), should be taken into consideration.
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Response to EU Methane Strategy

5 Aug 2020

BDE, the Federation of the German Waste, Water and Raw Materials Management Industry, welcomes and supports a European Methane Strategy. We believe that it is necessary to structurally address the reduction of methane emissions through a holistic approach to effectively fight climate change. That is because Methane is a greenhouse gas which is more than twenty times more harmful than CO2 over one hundred-year period. There are several promising steps in the waste management sector that can be taken and have already been proven effective on national level. In order to drastically reduce the enormous methane emissions emanating from landfills, may they be managed or unmanaged, a EU-wide landfill ban for untreated residual waste will have the biggest impact. In Germany, according to calculations of the Federal Environment Agency, this step reduced the CO2-equivalent emissions by more than two thirds between 1990 and 2015. The same observations were made in Austria after the landfill ban came into force. A time frame of 10 years is realistic for the transition to such a landfill ban, so that it could be implemented by 2030. In addition, bio waste must be treated in suitable facilities, where possible methane leakage is prevented and synergies between sectors e.g. biogas production can be used for the benefit of climate protection. This requires the effective introduction of European-wide separate collection of biowaste till the End of 2023.
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