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Društvo Ekologi brez meja

EBM

Our mission is activation, motivation and cooperation of individuals, communities, policy makers, industry, businesses and researchers in the area of an efficient use of natural resources with the aim to reduce costs, preserve nature & energy and create new green jobs.

Lobbying Activity

Meeting with Milan Brglez (Member of the European Parliament)

26 Sept 2023 · Right to repair; Packaging waste

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

We welcome the Commissions proposed renovation of PPWD with open hands, especially the explicit reuse and prevention targets that are so rarely proposed yet key for a successful move towards more circular packaging. They should be higher though, as for example a 5 % decrease will only undo a few years' worth of growth of packaging waste amounts. Slovenia is one of the few laggards when it comes to implementing DRS for plastic packaging, as practically mandated by the SUPD collection targets (which PPWR should expand to cover glass bottles as well). We thus very much support the mandatory nature, certain minimal standards and a VAT waiver that are in the proposal. One thing that is missing is mandating DRS for glass bottles as well, considering glass is the least environmentally efficient packaging when used only once and considering how appropriate it is for refill. Our study of roadside littering in Slovenia showed that glass bottles have a significant share, so even mandating a DRS only for single-use bottles would make sense, let alone for refill. Our existing DRS for glass bottles has been eroded almost into irrelevancy through time, so treating it the same as DRS for cans and plastic bottles would revitalize it. Considering the target of 100% reusable or recyclable packaging by 2030 from the EU Plastics strategy, it does not make sense that the application of recyclable packaging requirements is delayed to 2030 (for design) and 2035 ("recyclable at scale"). Loopholes like the "innovative packaging" 5 year derogation on sharing information, not really addressing most flexible packaging and a lack of economic incentives for (design for) reuse & refill (eg. from EPR fees as in France) will only make meeting the target harder. We urge the Commission to address these shortcomings. Submitted by Ekologi brez meja on behalf of the resource efficiency working group of the Plan B za Slovenijo environmental network.
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Meeting with Franc Bogovič (Member of the European Parliament)

12 Oct 2022 · Waste treatment legislation in Slovenia

Response to Environmental impact of mobile phones and tablets - Ecodesign

28 Sept 2022

We welcome this attempt at ensuring better e-product design, greater repairability plus improved user and repairer agency. However there are some gaps that will enable producers to still limit repairs and encourage device replacement instead. In the spirit of Open Knowledge, access to repair information should be public and not limited to professional repairers. It should also be available for free not to further burden usually already financially unattractive repair activities. Gatekeeping such information is not in the spirit of extended producer responsibility, the implementation of the waste hierarchy and the overall circular economy agenda.The same holds for the unwelcome restrictions on who can access spare parts and use of 3rd party parts. All these problems are akin to vendor lock-in seen in software, which has itself led to shorter product life spans and the inability to repair. It is especially alarming that practices of part pairing are not limited, or better yet, outright prohibited by the draft regulation. There are no practical security benefits, even more so considering high security devices are exempt from regulation. It is simply a wasteful monopolisation practice that should be nipped in the bud. Endurance and repairability should both be promoted, not freely one or the other, since not all need for repair comes from wear and tear. Additional criteria should be added to ensure easier end-of-life handling and CRM extraction — limit the presence of chemicals of concern, since they inhibit recycling and the preservation of material value.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

EBM welcomes the revision of the EU waste framework as it is clear that further regulatory measures will be needed to ensure a satisfactory transition to a circular economy. Waste prevention has been at the top of the waste hierarchy since its inception, yet decades of practice show it only has this position nominally. Time after time again has waste treatment and disposal been in the limelight, while prevention was relegated to rare interventions and civil society organizations. The revision provides a great opportunity to introduce stimulating targets for at least municipal waste reduction, reuse (subtargets) and a cap on residual waste generation. It is also a good opportunity to expand EPR coverage to additional product groups, specifically those that are now ignored as part of residual waste. Eg. composition analyses show the share of nappies in the residual waste stream can be upward of 10 %. Menstrual products should also be covered also as a way to reduce waterway pollution from improper disposal down the drain. Back to bigger quantities, textiles are another key substream, with most systems currently focusing only on collection of clothes appropriate for reuse. Lastly, consider introducing EPR for C&DW as it could significantly reduce the frequency of illegal dumping of construction waste. C&DW has been the most common waste illegally disposed of in Slovenia and the often high price of disposal is regularly recognized as one of its drivers. Lower down the waste hierarchy care should be taken to ensure plastic2fuel processes are not counted as recycling, nor any other chemical recycling that doesn't produce high quality outputs. The 10 % landfill target should be amended in its calculation to account for waste reduction or better yet, be replaced with targets on landfilling unstabilized waste. Measures targeting the minimization of residual waste should be prioritized in favour of disposal, with or without energy recovery.
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Response to Food waste reduction targets

29 Oct 2021

We welcome the intention of establishing binding food waste reduction target(s), as at these have proven to be effective in Slovenia time and time again. It may also be beneficial to consider separate targets for food losses, additionally since there is risk that food loss prevention will sometimes be reported as food waste prevention. Or targets encompassing both together as option S1 states, representing a simplification. Considering the official monitoring framework distinguishes between contributions by sector, we believe per-sector targets could contribute to better and faster results, as now the omen is mostly on the consumer. The way the targets are worded should additionally encourage work at the top of the food waste hierarchy, preferring human consumption to food to feed systems. For fairness, we prefer options E2 and T3.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

Considering all our experience with intentional and unintentional miscommunication and misuse of bioplastics, we welcome the decision to cautiously resolve some of the mess. Improved and stricter labelling, certification and minimum standards can help, but it will not be sufficient. The concepts are too complicated to be explained away trivially and both confusion and greenwashing will continue. Bioplastics simply aren't a silver bullet sollution to plastic pollution. Therefore we propose to limit the use of biodegradable (only properly industrially compostable!) plastics to where it can truly and safely contribute to reaching a more circular economy. So far we've seen too many hasty substitutions just because fossil plastics have a bad public image. Instead of rethinking business models, reusing and avoiding the need for certain plastic items, we're seeing a shift to biodegradable alternatives, both compostabile and not (often thinking this will circumvent the measures in the SUPD). Or worse, just biobased plastics, which considering we are not food self-sufficient in Slovenia, make no sense at industrial scales. The situation is worsed by poorly understood end-of-life impacts, the disruptive effect on separate waste collection (particularly from packaging) and the fact that some people still believe biodegradable means it can be freely littered in nature.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

The planned revision of the ETS is a good opportunity to account for more GHG emissions stemming from waste management operations. In particular, we feel the incineration of municipal solid waste has so far been unduly excluded. As a result, there has been little pressure to reduce GHG emissions, which would automatically also reduce toxic emissions, ticking the box also for the "zero pollution" ambition of the EC. Considering: - these emissions are on the rise — they have increased by 288% at EU-28+ISL level between 1990 and 2017 (EEA, 2019), - that climate efficiency of incineration is worse than that of burning fossil fuels directly, - Europe is transitioning to a low carbon circular economy, where management higher up the waste hierarchy is required for success, - the sustainable investment taxonomy (Regulation 2020/852) classifies incineration as an "activity causing significant harm to environmental objectives" in Article 17, we urge the Commission to include all forms of incineration and thermal treatment of municipal solid waste into ETS. This would help compensate for the environmental damage, incentivize emission reduction, and promote more low-carbon waste treatment options alongside waste reduction. EBM on behalf of the Efficient Resource Use and Waste working group of the Slovenian network of environmental NGOs Plan B za Slovenijo.
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Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

According to the impact assessment, avoiding releases of POPs from waste is a priority. Yet a large part seems to be geared towards facilitating negligent recycling, all the while some of the limit values are already not low enough to ensure public health and environmental safety (both Stockholm Convention objectives). For example, high concentrations of dioxins have recently been found in incinerator ash and similarly, high levels of PBDEs have been found in toys made from recycled plastics. POPs are a contaminant of recyclates, so the limits for waste should be stricter, not looser, to maintain clean waste streams and enable several recycling cycles, without needing to worry too much about the concentration effect. Toxics like POPs need to be primarily designed out of the system, not delegated to be dealt with at the end-of-pipe. That's the true way to ensure circularity. The situation with incinerator ashes is even more alarming, as Petrlik and Bell showed in 2017 that incineration derived dioxin deposits are absurdly high. But also in practice, even BAT compatible state-of-the art incinerators like the REC in Harlingen or the AEB in Amsterdam fail to operate safely. The weak limits then lead to all sorts of use in construction and even soil improvement. Even the use of fly ash on the surface of landfills was found to be problematic due to potential leakage and/or wind dispersion of dioxins into the surrounding environment (Wang, Wang et al. 2006) . We believe that it is necessary to set limits for dioxins in wastes that will increase the fraction of such waste that is safely treated and disposed and which will highlight the need to prevent the generation of wastes containing high levels of dioxins. So we call on the Commission to implement strict POPs limits and act as a lighthouse globally, as per the European Green Deal diplomacy provisions. Weak limits allow more exports of dangerous materials from developed to developing countries because these are not considered as POPs wastes. We propose more protective POPs content limits for the following substances: - 1 ppb (= 1 ng/g WHO-TEQ) for PCDD/Fs + dl-PCBs with additional limit of 50 pg WHO-TEQ/g (0.05 ppb) of these substances for untreated waste used on land surface - 10 ppm for sum of PFOA/PFHxS and related substances - 50 ppm for sum of PBDEs (including Deca-BDE) - 100 ppm for SCCPs - 100 ppm for HBCD We also urge the EC to be open and supportive of other technologies for destruction of POPs waste, which do not create new POPs as waste incineration or co-incineration does, in order to meet obligations set in Article 5 of the Stockholm Convention. EBM on behalf of the Efficient Resource Use and Waste working group of the Slovenian network of environmental NGOs Plan B za Slovenijo
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

3 Aug 2020

At EBM we welcome the goals  of the review and will stress a few points. One of its specific objectives is to ensure a reduction in packaging waste generation. Waste prevention has been a priority since the introduction of the waste hierarchy in the WFD, yet it never received much attention — and definitely not as much as it pertains to an item touted as a foremost priority. Both legislative, funding and even corporate lobbying efforts still mostly target lower levels of the hierarchy, recycling and disposal. Sure, recycling has its role and we fully support the 2030 target from the Plastics Strategy, however it's time for reduction/prevention to step into the limelight and be taken seriously. This review presents a good opportunity to address our current packaging (waste) crisis, caused largely by the fact that much of packaging isn't designed to be reused, recycled or even properly disposed. Environmental and human health related externalities are not well accounted for, enabling the continuing drive for single-use packaging from virgin plastics. To be able to reach the 2030 reuse and recycling target, binding reduction (and reuse) sub-targets are paramount, material diversity needs to be limited (in particular for plastic resins), overpackaging reduced, secondary packaging raw materials made viable if not competitive, disposal penalized (be it landfilling or any form of incineration) and its burden brought to producers, who need to redesign their packaging and delivery systems with circularity in mind. Current EPR systems have proven to be inadequate even with ecomodulation of fees and the generated funding rarely ends up accelerating reuse, reduction and other actions at the top of the waste hierarchy. More and targeted funding needs to end up in prevention activities at all levels. For consumers to be able to choose better packaging and vote with their wallets, proper labelling is very important. More than the hard to navigate flood of certificates, the requirements review is the perfect place to standardize and mandate improved labelling. For example, the provision pondering mandatory labelling from Commission Decision 97/129/EC establishing the identification system for packaging materials has *still* not been made mandatory, so there are plenty of products on the market made of unmarked, unknown materials — without recourse. In a sampling of common goods we did in 2019[1], we had several issues identifying packaging materials and about a sixth of plastic packaging was indeterminable, while a third was made out of category 7 (other), so nothing well known or recycled. At the same time producers keep shifting the blame for packaging waste pollution to the consumers, which is an unacceptable deflection of their responsibility. [1] https://ebm.si/r/Ko%C5%A1arica_dobrin_in_embala%C5%BEa_v_njej.pdf
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Response to EU rules on industrial emissions - revision

20 Apr 2020

Considering the goals of the Green Deal, it's a shame that IED doesn't address the climate crisis directly. The regulation of GHG emissions is left to the ETS Directive, but at the same time more than 90% of industrial greenhouse gas emissions are covered by free ETS emissions allowances, so that Directive provides almost no incentive to energy-intensive industries to decarbonize. This is supported by the observation that industrial (non-power sector) GHG emissions under the EU ETS have been stagnating since 2012. Considering also the goal of "Contribution to the circular economy", we propose for the updated IED to equalize the emissions limits for waste incineration and co-incineration plants that use over 20 % waste as a fuel (most commonly cement kilns). Co-incineration is currently unduly in an advantageous position, both from an environmental and human health perspective, also driving some illegal waste trade (eg. documented cases between Italy and Romania). The fact the limits are based on concentration is offset by the much higher volumes of air flow, netting a higher negative impact. We are in a situation, where some waste co-incineration plants even burn more waste than fuel, begging the question whether they are waste or fuel co-incinerators. Germany paved the way by equalizing some of the limits already (PM, NOx), so it is not too much to ask. Considering access to information and effective enforcement or compliance, the problems at the Danish Norfors and Amsterdam's AEB last year or the great Dutch example of Reststoffen Energie Centrale[0] incinerators all show the need for true continuous monitoring, not just a few times yearly during normal operation, tighter control and shorter feedback loops. [0] See case study: https://zerowasteeurope.eu/downloads/hidden-emissions-a-story-from-the-netherlands/
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Response to A new Circular Economy Action Plan

19 Jan 2020

Društvo Ekologi brez meja lauds the continued determination of the EC to see Europe transition from a linear economic model. The CEAP might be a broad and high level roadmap, but we'd like to stress some key points where we find the used language weakest. We've had the waste hierarchy enshrined in legislation for over a decade, often pictured as an upside down pyramid, prevention being at the top (as a top priority) and disposal at the narrow bottom. Yet considering the current status of waste management across the EU and both historical and ongoing investments, the situation is reversed, with too much attention still going to end-of-pipe solutions, while preventative measures remain mostly nominal. Therefore we urge the EC to implement quantified and binding waste generation targets at minimum for municipal solid waste as a whole, while tackling industry through material resource efficiency targets, ecodesign requirements that go beyond a select list of product types and taxation of primary raw material use. Reuse could also be boosted by decoupling the Plastic strategy 2030 packaging target into two and speeding up the process of creating a general target for (preparation for) reuse of waste. Ecodesign criteria should include provisions from chemicals policy both to ensure a faster phase out of hazardous substances (eg. endocrine disruptors), ease further processing and to prevent the contamination of recycled materials, which is undermining the circularity of recycling. When it comes to disposal and energy recovery, emission limits for cement kilns need to be brought in line with the ones of waste-to-energy plants and the monitoring framework reformed, as systemic issues in the past few years have showed it is not fit for purpose or the 21st century. Such activities also need to lose any exemptions from the Emissions Trade System (ETS). Any waste sent for disposal or energy recovery should be regularly audited to identify key product design gaps, problematic materials, compliance gaps and opportunities to further capture recyclables. Lastly, the investment policy should reflect the CEAP and waste hierarchy as well — unlike now, when it is still lagging behind the circular vision for Europe and too often financing false solutions and ineffective infrastructure, particularly in the less developed MS. The Taxonomy is a good step forward and it needs to be complemented through other fiscal and economic instruments to ensure private, European and public funds support only sustainable circular solutions.
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