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DERICHEBOURG ENVIRONNEMENT

Leader au niveau européen, Derichebourg Environnement propose au monde de l’industrie, aux collectivités et aux particuliers une offre complète et intégrée de services couvrant la collecte, la gestion, le recyclage et la valorisation des déchets.

Lobbying Activity

Response to Clean corporate vehicles

5 Sept 2025

Derichebourg Environnement soutient pleinement les objectifs de décarbonation, la transition vers des flottes à faibles émissions et la mise en œuvre dune réglementation ciblée, proportionnée et opérationnelle. Toutefois, il est nécessaire que la nouvelle obligation réglementaire prévoit un seuil clair, un calendrier réaliste tout en tenant compte de la disponibilité technologique et des infrastructures de recharge. Pour cela, nous plaidons en faveur de cadres réglementaires clairs au niveau de lUE. Nous recommandons : 1- Appliquer lobligation aux parcs supérieurs à 100 véhicules pour maximiser limpact sur les immatriculations tout en fixant le seuil au niveau du pays, et non de lentreprise ; 2- Inscrire dans le texte une distinction explicite entre véhicules légers et lourds ; 3- Adopter une trajectoire progressive et réaliste avec des paliers intermédiaires fondés notamment sur la réglementation française actuelle ; 4- Mettre en place des mesures daccompagnement pour le déploiement des bornes de recharge
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Response to Commission Implementing Regulation on the list for the purposes of Article 26 of Regulation (EU) 2024/1252

23 Jul 2025

Derichebourg Environnement is one of the global and European leaders of circular economy, specialized in metal waste recycling, working with local authorities, industries and Extended Producers Responsibility (EPR) systems. We continue our reindustrialization efforts, strengthening our territorial presence in the European countries where we operate (France, Spain, Germany, Belgium, Hungary, Romania), with the production in 2024 of more than 5 million tons of recycled metals (recycled steel, aluminum, copper). Recycling is a major issue for the Derichebourg group, with more than 250 recycling plants in the EU, implying green jobs, huge investments and innovative technologies. The industrial recycling plants of Derichebourg enables the recycling of various metal waste, such as end-of-life vehicles (ELV), electronic waste (WEEE), copper cables, but also industrial metal waste or municipalities waste. As a leading recycling player, the Derichebourg Group is navigating a complex landscape of challenges and regulatory changes. The future Circular Economy Act will continue reshaping our sector, while the emergence of new Extended Producer Responsibility (EPR) channels, the in-depth overhaul of the European automotive recycling sector, and the rapid development of the battery sector are creating both opportunities and challenges. Additionally, lack of targets for mandatory recycled content into new products are further impacting our recycling industry. Derichebourgs key figures for 2024: 4,4 million tons of recycled steel produced 700 000 tons of recycled non-ferrous metals produced 650 000 end-of-life vehicles recycled 370 000 tons of electronic waste recycled 75 000 tons of aluminium ingots produced The Derichebourg Group attaches particular importance to the strategic issues linked to Critical Raw Materials (CRMs), and in particular positions itself as a leading player in aluminium and copper recycling. On a general point of view, as the Annex is directly linked to upcoming National Measures (Article 26 of the CRM Act, Regulation 2024/1252), one must keep in mind that some of the parts/components listed are very difficult to access and to recycle for both technical reasons and lack of strong business models, such as permanent magnets stemming from ELVs and WEEEs. Regarding specific comments linked to the Annex, please find attached our comments and questions regarding: Electrical and electronic equipment; Motor vehicles; Light means of transport; Energy and telecommunications infrastructure; Digestate or compost from separately collected biowaste and Slags, sludges, and ashes.
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Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

18 Jun 2025 · Major topics included metal and electronic waste recycling capacities and market demand challenges.

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné)

11 Mar 2025 · Priorities of the metals recycling industry in view of the upcoming Steel and Metals Action Plan

Meeting with Bruno Tobback (Member of the European Parliament)

18 Feb 2025 · Metal recycling and electrical cables

Meeting with René Repasi (Member of the European Parliament)

23 Jan 2025 · Unternehmensbesuch bei Derichebourg Environnement - Austausch zu Industriepolitischen Themen

Meeting with Estelle Ceulemans (Member of the European Parliament)

16 Jan 2025 · Dossier ENVI à venir

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

12 Jan 2025 · Circular Economy

Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

Derichebourg wishes to react in the context of the public consultation launched by the European Commission until the 3rd of July 2024, concerning the draft amendments to the Waste Shipment Regulation 1013/2006 and 2024/1157, with respect to the e-waste codes changes under the Basel Convention. Derichebourg is a family-owned group, created in 1956 by entrepreneurs aware of the recovery potential of metal waste. Particularly present in France and Europe, with a dense territorial network, the group produced 5,4 million tons of recycled metals in 2023. Derichebourg is a long-standing member of FEDEREC, the French federation of recycling companies, as well as EuRIC, the European confederation of the recycling industry. Derichebourg is a major player in e-waste recycling in France and Europe with 14 dedicated plants. DERICHEBOURG express its concerns about the EU's incorporation of Decision BC-15/18 of the Basel Convention amending the entries relating to electronic waste in its annexes. In particular, the draft delegated regulations would lead to unprecedented administrative burdens for intra-European cross-border shipments of non-hazardous e-waste, components and fractions. Such a development, which would come into force on 1st January 2025, would be seriously detrimental to the European recycling industry and the circular economy. The draft revised regulations - amending regulations 1013/2006 and 2024/1157 impose the Prior Informed Consent (PIC) procedure for all e-waste shipped within the EU. Not only will it lead to a complex system with a heavy administrative burden, but it will also represent a barrier to resilient European recycling channels for critical and strategic metals. OUR KEY PROPOSALS The European Commission's mission is to facilitate the circularity of materials within the EU, especially when they are critical and strategic. It is therefore essential to keep the information procedure, for non-hazardous e-waste fractions and components shipped within the EU, so as not to hinder their recycling in Europe. Maintain the GC010 and GC020 codes in part 2 of Annex III for intra-EU shipments until Regulation 2024/1157 comes into force. From May 2026, the situation may be reassessed in the light of the enhanced traceability linked to the dematerialization of the information procedure and Annex VII. To facilitate the harmonized application of these new codes and associated procedures, the adoption of guidelines is highly recommended, as it was the case for plastics, to define the e-waste covered by GC010 and GC020 codes for shipments within the EU, and Y49 and A1149 codes for shipments to OECD member countries .
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste

3 Jul 2024

Derichebourg wishes to react in the context of the public consultation launched by the European Commission until the 3rd of July 2024, concerning the draft amendments to the Waste Shipment Regulation 1013/2006 and 2024/1157, with respect to the e-waste codes changes under the Basel Convention. Derichebourg is a family-owned group, created in 1956 by entrepreneurs aware of the recovery potential of metal waste. Particularly present in France and Europe, with a dense territorial network, the group produced 5,4 million tons of recycled metals in 2023. Derichebourg is a long-standing member of FEDEREC, the French federation of recycling companies, as well as EuRIC, the European confederation of the recycling industry. Derichebourg is a major player in e-waste recycling in France and Europe with 14 dedicated plants. DERICHEBOURG express its concerns about the EU's incorporation of Decision BC-15/18 of the Basel Convention amending the entries relating to electronic waste in its annexes. In particular, the draft delegated regulations would lead to unprecedented administrative burdens for intra-European cross-border shipments of non-hazardous e-waste, components and fractions. Such a development, which would come into force on 1st January 2025, would be seriously detrimental to the European recycling industry and the circular economy. The draft revised regulations - amending regulations 1013/2006 and 2024/1157 impose the Prior Informed Consent (PIC) procedure for all e-waste shipped within the EU. Not only will it lead to a complex system with a heavy administrative burden, but it will also represent a barrier to resilient European recycling channels for critical and strategic metals. OUR KEY PROPOSALS The European Commission's mission is to facilitate the circularity of materials within the EU, especially when they are critical and strategic. It is therefore essential to keep the information procedure, for non-hazardous e-waste fractions and components shipped within the EU, so as not to hinder their recycling in Europe. Maintain the GC010 and GC020 codes in part 2 of Annex III for intra-EU shipments until Regulation 2024/1157 comes into force. From May 2026, the situation may be reassessed in the light of the enhanced traceability linked to the dematerialization of the information procedure and Annex VII. To facilitate the harmonized application of these new codes and associated procedures, the adoption of guidelines is highly recommended, as it was the case for plastics, to define the e-waste covered by GC010 and GC020 codes for shipments within the EU, and Y49 and A1149 codes for shipments to OECD member countries .
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Response to Revision of EU legislation on end-of-life vehicles

4 Dec 2023

DERICHEBOURG, a European player in automotive recycling DERICHEBOURG is a family-owned group, created in 1956 by entrepreneurs who were aware of the recovery potential of metal waste. Particularly present in France and Europe, with a dense territorial network, the group produced 6 million tons of recycled metals in 2022. DERICHEBOURG is a long-standing member of FEDEREC, the French federation of recycling companies, as well as EuRIC, the European confederation of the recycling industry. DERICHEBOURG is a major player in end-of-life vehicle (ELV) recycling in France and Europe with: - 200 authorized treatment facilites (ATFs), including 25 shredders in Europe (Belgium, Germany, Spain, France, Italy, Romania). - More than 500,000 ELVs recycled in 2022 in Europe. - Recycling and recovery rates of 87 % (85 % target) and 97 % (95 % target). A new framework for vehicle design and recycling DERICHEBOURG welcomes the European Commission's decision to revise the legislation applicable to vehicle design and recycling. The Commission's approach, which encompasses the entire life cycle of the vehicle, is an excellent approach for the circular economy. Since the early 2000s, the political, economic, and geopolitical context in Europe has undergone profound changes, which make evolution essential for the automotive industry. The transformation of the vehicle fleet on a European scale, the challenges of carbon neutrality and industrial sovereignty, are all issues that are the subject of strong framework measures, such as the European regulation on batteries, the draft European regulation on critical raw materials (CRM Act) and the draft regulation on zero-emission industry (NZI Act). While DERICHEBOURG supports the European Commission's desire to considerably strengthen the circularity and eco-design requirements of new vehicles, the timing of the draft regulation must be consistent. The deadlines for the new end-of-life requirements must be consistent with the time limit set for the new production criteria and take into account the average age of end-of-life vehicles of almost 20 years. A time shift between design and recycling requirements is essential for overall text coherence. In addition, some requirements seem to be uncorrelated from the reality and reflect either a lack of pragmatism or the absence of a prior technical and economic feasibility study, especially the requirement regarding the removal of parts and components before shredding (article 30). Finally, the leading role given to car manufacturers through the principle of Extended Producer Responsibility (EPR) must be accompanied by safeguards to avoid an unbalanced balance of power, to the detriment of the recycling value chain. DERICHEBOURG makes comments and proposals, which are intended to be constructive, to actively contribute to the European legislative process. The attached note gathers our main points and more than 20 specific proposals. Our keys proposals for a well-functioning European vehicle recycling industry : 1. Reassess the deadlines for the application of the new ELV management obligations, to consider the average age of end-of-life vehicles [Art. 7] 2. Extend the obligation of fair representation in the governing bodies of Extended Producers Responsibility schemes, to producers who fulfil their obligations individually [Art. 18] 3. Rely on an independent body, as part of the monitoring mechanism, and study the implementation of indexation on a regular basis [Art. 20] 4. Complete the materials preventing high-quality recycling, as part of the modulation of fees [Art. 21] 5. List the essential parts and components triggering to take back the vehicle free of charge [Art. 24] 6. Carry out a technical and economic study to validate the list of parts and components to be extracted before shredding [Art. 30] 7. Carry out an annual publication of the inspections and rely on artificial intelligence to identify illegal sites [Art. 46]
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