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European Co-Processing Association

EUCOPRO

EUCOPRO is composed by Waste Treatment companies that prepare waste alternative fuels and raw material mainly from hazardous waste, with the aim of recovering them in co-processing processes, such as cement kilns.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

EUCOPRO European association for co-processing brings together European best in class management companies dealing services of recovery and treatment of hazardous waste. We treat and transform hazardous waste into alternative fuels and raw materials. Our waste products substitute fossil fuel and raw material in industrial processes by co-processing. Co-processing is the simultaneous recovery of energy and materials when prepared waste is used in industrial production processes such as cement manufacturing. In synergy with co-processing processes, we give a second life to hazardous waste bringing it into the circular economy. We contribute to energy self-sufficiency and the reduction of the industrial carbon footprint in Europe, as well as to the preservation of natural resources. EUCOPRO welcomes the European Commissions ambition to accelerate the transition to a circular economy and this opportunity to provide feedback for the upcoming Circular Economy Act. As our scope concerns hazardous waste, we have answered the questionnaire with this scope in mind. We support administrative simplification in the field of waste treatment. However, the primary purpose of hazardous waste management lies in protecting the environment and human health. The traceability of this hazardous waste is necessary to enable information about its origin, quantity, characteristics, destination, and treatment method to be retained. EUCOPRO is in favor of European harmonized rules for the end-of-waste and by-products procedures but applying end-of-waste and by-products on all waste streams is not the way forward and careful consideration has to be taken when setting up new criteria, even more so for hazardous waste.
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Response to Waste shipments - information on certificates on interim recovery and disposals and non-interim recovery and disposals

28 May 2024

Eucopro comments on th draft proposal on certificates on the completion of subsequent interim or non-interim recovery operation or a subsequent interim or non-interim disposal operation.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Eucopro comments on Annex III to Environmental Delegated Act (PPC) - PPC 2.2 Treatment of Hazardous Waste
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

In the context of climate change and saving of resources, Eucopro is committed to promote the transition towards a circular economy. Eucopro welcomes this initiative from the European Commission. Eucopro 's comments are included in the joined Position Paper.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

28 Oct 2020

Eucopo comments on the Roadmap "EU Action Plan - Toward a Zero pollution Ambition for air, water and soil" (joined document).
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

EUCOPRO comments - Inception Impact Assessment - Review of the Regulation on E-PRTR
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Response to Chemicals strategy for sustainability

19 Jun 2020

EUCOPRO comments are included in the joined document.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

EUCOPRO Contribution - Inception Impact Assessment : Revision of the Industrial Emissions Directive
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Response to Climate Law

6 Feb 2020

EUCOPRO Comments
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Response to A new Circular Economy Action Plan

17 Jan 2020

See joined document
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Response to Evaluation of the Industrial Emissions Directive

4 Dec 2018

In the context of this first consultation, the following points seems important to EUCOPRO : 1. On the provisions of the Industrial Emissions Directive 2010/75 of 24 November 2010, and in particular its Chapter II, Eucopro considers that the existing provisions are adequate and sufficient to ensure the protection of the environment. At this stage Eucopro would only ask for increased monitoring of the application of the IED requirements in Member States, in order to prevent possible discrepancies in the directive implementation. 2. On the procedures for the BREFs elaboration and reviewing Eucopro followed both the initial elaboration in 2006 of the Waste Treatment BREF and its revision, which ended on August 10, 2018. This revision was totally conducted under the IED directive requirements. Compared to the first elaboration procedure, Eucopro have seen many improvements both in the working process and on the quality of exchanges. These concern especially the working methodology which included now, when it is necessary working dedicated groups, intermediate exchange meetings,…. The questionnaire processing for data collection relating to water and air emissions is also a great improvement. Improvements of the Bref reviewed procedure could be envisaged mainly on methodology aspects but they do not imply changes to the corresponding provisions of the Directive. 3. Request for a procedure to follow the implementation of BAT conclusions in the European Union. The BREF implementation under the IED directive is a new process. Some BAT conclusions could be subjected to interpretation by the member states for their implementation. Difficulties of implementation of certain provisions could also occur. Eucopro are in favour to develop at European level, regular feedback meetings between TWG members who will wish to do so. Such exchanges would both reach to resolve some questions and also to focus the next revision of the considered Bref to the subjects that require it. Here again, it is not certain that it is a matter of provisions specific to the Directive, but rather of methodological provisions related to the BREF process.
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