Bureau of International Recycling
BIR
Founded in 1948, BIR was the first federation to support the interests of the recycling industry on an international scale.
ID: 081383691814-72
Lobbying Activity
Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and European Recycling Industries' Confederation
1 Jul 2025 · European and global recyclers in the context of EU circularity transition
Meeting with Jessika Roswall (Commissioner) and
19 Mar 2025 · Steel and Metals Action Plan and Circular Economy Act
Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)
13 Jun 2024
Full comments attached Summary The United Nations found that global generation of electronic waste is rising five times faster than documented e-waste recycling, with collection rates globally decreasing due to differences in recycling promotion relative to the explosive growth of e-waste generation. Data shows non-OECD countries greatly increasing their e-waste collection and recycling capacity in the past years, much of which is in specialised components arriving from the EU. Due to its complexity, the e-waste recycling process is decentralised, and various components are treated in different specialised sites across various countries. Without sufficient and adequate recycling capacity in the EU, a ban on the export of e-waste would overwhelm European e-waste treatment facilities and lead to waste accumulating at collection. Additionally, the loss of primary export markets for these materials would threaten the viability of specialised recycling businesses in Europe and around the world. In practice, the European Union is opting to expand the restrictions of the Basel Convention, which forbid only the export of hazardous e-waste to non-OECD countries, to cover non-hazardous e-waste. These materials are internationally traded commodities which feed international recycling value chains. This decision goes against the letter and the intent of the Basel Convention, which aims to safeguard developing countries from international dumping of hazardous waste. The proposed deadline for the export ban, alongside a transitional period of one year for shipment consents granted before 1 January 2025, is untenable due to months-long processing times these applications usually take. Thus, BIR recommends that the European Commission: Incorporate the new entry Y49 to Annex III Instead of Annex V of the new Waste Shipments Regulation, allowing non-OECD countries to request the import of such materials as provided by Art. 40(2) ; and Increase the transitional period by three years or until 2027 earliest, allowing shipments to be requested until 1 January 2026, to allow the recycling industry to adjust to important changes to their operations. BIR, as the voice of the global recycling industry, is deeply concerned about the effects of such prohibitions for the global path to circularity. The recycling industry operates at a global level, with no country being self-sufficient in its recycling needs. Unnecessary restrictions in place of prudent action will only lead to lower recycling rates and harm to the environment. BIR is of the opinion that without flexibility in this matter, the EU will likely see numerous recycling companies, already damaged by other recent regulations, unable to cope with the drastic changes to their operations. Without existing capacity for treating major parts of the e-waste recycling process, these valuable materials will accumulate at the place of origin. The consequent loss in collection and recycling capacity would be counterproductive for the environmental ambitions of the EU. Additionally, third countries would suffer greatly from the loss of economic activity, leading to lower rates global recycling and increased environmental harm.
Read full responseResponse to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste
13 Jun 2024
Full comments attached Summary The United Nations found that global generation of electronic waste is rising five times faster than documented e-waste recycling, with collection rates globally decreasing due to differences in recycling promotion relative to the explosive growth of e-waste generation. Data shows non-OECD countries greatly increasing their e-waste collection and recycling capacity in the past years, much of which is in specialised components arriving from the EU. Due to its complexity, the e-waste recycling process is decentralised, and various components are treated in different specialised sites across various countries. Without sufficient and adequate recycling capacity in the EU, a ban on the export of e-waste would overwhelm European e-waste treatment facilities and lead to waste accumulating at collection. Additionally, the loss of primary export markets for these materials would threaten the viability of specialised recycling businesses in Europe and around the world. In practice, the European Union is opting to expand the restrictions of the Basel Convention, which forbid only the export of hazardous e-waste to non-OECD countries, to cover non-hazardous e-waste. These materials are internationally traded commodities which feed international recycling value chains. This decision goes against the letter and the intent of the Basel Convention, which aims to safeguard developing countries from international dumping of hazardous waste. The proposed deadline for the export ban, alongside a transitional period of one year for shipment consents granted before 1 January 2025, is untenable due to months-long processing times these applications usually take. Thus, BIR recommends that the European Commission: Incorporate the new entry Y49 to Annex III Instead of Annex V of the new Waste Shipments Regulation, allowing non-OECD countries to request the import of such materials as provided by Art. 40(2) ; and Increase the transitional period by three years or until 2027 earliest, allowing shipments to be requested until 1 January 2026, to allow the recycling industry to adjust to important changes to their operations. BIR, as the voice of the global recycling industry, is deeply concerned about the effects of such prohibitions for the global path to circularity. The recycling industry operates at a global level, with no country being self-sufficient in its recycling needs. Unnecessary restrictions in place of prudent action will only lead to lower recycling rates and harm to the environment. BIR is of the opinion that without flexibility in this matter, the EU will likely see numerous recycling companies, already damaged by other recent regulations, unable to cope with the drastic changes to their operations. Without existing capacity for treating major parts of the e-waste recycling process, these valuable materials will accumulate at the place of origin. The consequent loss in collection and recycling capacity would be counterproductive for the environmental ambitions of the EU. Additionally, third countries would suffer greatly from the loss of economic activity, leading to lower rates global recycling and increased environmental harm.
Read full response