OpenLobby.EU
Explore

European Recycling Industries' Confederation

EuRIC

EuRIC represents European recycling industries, advocating for policies that support recovery and recycling activities across EU member states.

Lobbying Activity

Recycling Europe seeks 36-month derogation for foam container recycling

19 Dec 2025
Topic — The EU is amending regulations to restrict medium-chain chlorinated paraffins in chemical products.
Message — The group proposes a 36-month derogation from chemical limits for recycled foam containers. They request a 3% limit alignment to phase out substances without halting recycling.12
Why — This avoids high incineration costs and supports the continued recycling of hazardous prepolymers.3
Impact — Environmental groups lose as persistent organic pollutants continue to circulate in recycled materials.4
Read full response

Meeting with Adam Romanowski (Cabinet of Commissioner Maroš Šefčovič)

16 Dec 2025 · European aluminium recycling and export measures

Meeting with Pierfrancesco Maran (Member of the European Parliament, Shadow rapporteur) and MUST Partners

8 Dec 2025 · End-of-Life Vehicles Regulation

Recycling Europe Urges Simpler EU Taxonomy Reporting for Recyclers

5 Dec 2025
Topic — Review of technical criteria within the EU taxonomy environmental delegated act.
Message — The group calls for removing complex chemical and climate adaptation criteria to simplify reporting. They also request making operating expenditure disclosures optional to reduce administrative burdens.123
Why — These changes would lower compliance costs and simplify reporting for small recycling businesses.45
Impact — Investors lose standardized data required to assess how recycling companies adapt to climate change.6
Read full response

Meeting with Astrid Van Mierlo (Head of Unit Taxation and Customs Union)

25 Nov 2025 · discussion about CBAM's impact on the recycled materials produced by European metal recyclers represented by Recycling Europe

Meeting with Francois Wakenhut (Head of Unit Environment) and Federation française des entreprises du recyclage

12 Nov 2025 · Courtesy meeting requested to introduce FEDERREC and establish contact in the context of the preparation of the Circular Economy Act

European Recyclers Urge Strong Internal Market and Fair Competition Rules

6 Nov 2025
Topic — EU Circular Economy Act aims to boost recycled materials supply and demand.
Message — The organization requests EU-wide end-of-waste criteria, mandatory recycled content targets across sectors, and protection from unfair imports. They seek financial support for recycling technologies and simplified permitting procedures.12345
Why — This would increase demand for their recycled materials and protect them from cheaper imports.678
Impact — Third-country exporters lose access to EU markets for cheaper virgin and recycled materials.910
Read full response

Meeting with Jessika Roswall (Commissioner) and

29 Oct 2025 · Roundtable- closing the Loop : Addressing the Plastic Recycling Crisis in Europe

Meeting with François Kalfon (Member of the European Parliament)

22 Oct 2025 · Circular economy act, Plan acier et Fin de vie des véhicules

Meeting with Jessika Roswall (Commissioner) and

3 Oct 2025 · Circular economy and chemicals

Meeting with Stefano Soro (Head of Unit Internal Market, Industry, Entrepreneurship and SMEs) and Plastics Europe and

29 Sept 2025 · Discussion of several issues that European plastics value chain is facing.

Meeting with Eric Mamer (Director-General Environment) and

3 Sept 2025 · Exchange of views about the upcoming Circular Economy Act and its impact on the recycling market in Europe

Recyclers urge CBAM expansion while protecting recycled materials' exemptions

26 Aug 2025
Topic — The consultation addresses extending CBAM to downstream products and implementing anti-circumvention measures.
Message — The organization supports extending the carbon mechanism to downstream goods and textiles while preserving exemptions for recycled materials. They also recommend using default emission values for imports to prevent producers from manipulating reporting.123
Why — This would maintain a competitive price advantage for European recycled metals over high-carbon imports.4
Impact — Foreign producers would lose the ability to bypass carbon costs through selective export practices.5
Read full response

EuRIC demands fair recycled plastic rules

18 Aug 2025
Topic — Common rules for calculating, verifying, and reporting recycled content in beverage bottles.
Message — EuRIC requests prioritizing mechanical recycling over chemical methods and implementing a 'mirror clause' for imported materials. They also demand separate categories for plastic and non-fuel products to ensure transparent traceability.123
Why — This would safeguard the competitiveness of European recyclers against cheap foreign imports.4
Impact — Chemical recycling firms would lose feedstock if mechanical recycling is technically and environmentally preferable.5
Read full response

Response to Waste batteries - Format to be used by Member States reporting on their collection and treatment

11 Aug 2025

After reviewing the draft, EuRIC, on behalf of European battery recyclers, EuRIC highlights that requests from national competent authorities for detailed, country-specific data, as outlined in the reporting templates should refrain from introducing a high level of granularity. Most of the information required cannot be provided in an accurate manner because the input data for the individual materials is not available for any of the battery types.
Read full response

EuRIC calls for stricter limits on destroying unsold clothes

30 Jul 2025
Topic — The European Commission is defining legal exceptions for destroying unsold apparel products.
Message — EuRIC urges the Commission to close loopholes that let companies destroy usable clothing. They demand independent verification to stop firms from using subjective reasons to justify destruction.12
Why — Stricter rules would ensure more materials flow to recycling and reuse companies.34
Impact — Fashion brands lose the ability to destroy stock for brand protection reasons.56
Read full response

Response to EU industrial maritime strategy

28 Jul 2025

The Ship Recycling Group of the European Recycling Industries Confederation (EuRIC) welcomes the opportunity to provide feedback on the EU industrial maritime strategy. EuRIC supports the assessment that targeted measures are needed to enhance the sustainability, resilience and competitiveness of the EUs maritime sector. Such measures must adopt a holistic perspective, considering the entire life cycle and value chain of the shipping industry, including ship recycling. In this regard, EuRIC welcomes the strategys aim to reinforce Europes waterborne industrial and technological base, including its wider value chain. As highlighted in the call for evidence, promoting circular business models within the maritime sector is crucial to ensuring both the sectors competitiveness and its decarbonisation. However, while the call for evidence highlights the fact that European shipbuilding companies face severe competition from third countries, which negatively impacts the number of ships being built in Europe, it overlooks that not only ship building but also ship recycling faces issues with the lack of a level playing field. This has an equally negative impact on the EUs strategic autonomy and competitiveness. European ship recycling facilities operate under high environmental and occupational safety standards. These high standards ensure that vessels are recycled in an environmentally responsible way while safeguarding workers health and safety. However, European yards struggle to compete with facilities in third countries, especially in South Asia and Turkey, where regulatory requirements are often significantly lower. Even third country yards that fall under the scope of European legislation, namely the Ship Recycling Regulation (SRR), and are included in the EU list of ship recycling facilities, do not have to comply with the same requirements as EU yards and do not operate under the same standards. Consequently, the volume of ships recycled in the EU has remained consistently low over the last decade. Between 2013 and 2023, although the share of vessels recycled in EU yards has increased modestly from 4,5% to 5,3% in terms of number of vessels, it even decreased from 1,5% to 1% in terms of vessel size. The current legislative framework, especially the SRR, is widely circumvented, undermining its effectiveness and failing to support the sectors development in Europe. At the international level, the recently ratified Hong Kong Convention for the safe and environmentally sound recycling of ships also lacks ambition and is thus equally unlikely to promote a global level field or to raise standards significantly. Given these shortcomings, more ambitious action is urgently needed, both within the scope of the EU industrial maritime strategy and in forthcoming initiatives such as the EU Circular Economy Act. The European ship recycling sector has the potential to significantly contribute to the EUs strategic autonomy, decarbonisation and competitiveness goals. Among others, it can play an important role in securing raw materials, such as recycled steel, which is essential to the transformation of the European steel sector. Moreover, expanding the ship recycling capacity within the EU would significantly reduce the negative environmental and health impacts associated with substandard practices. As the EU works towards strengthening its maritime sector, ship recycling must be a key priority. Failing to support this sector this would represent a missed opportunity to bolster a strategic and sustainable industry. For further details on strengthening the ship recycling sector in Europe, please consult EuRICs position paper attached.
Read full response

EuRIC opposes mandatory targets for critical raw material recovery

25 Jul 2025
Topic — This regulation identifies waste streams with high potential for recovering critical raw materials.
Message — The group insists the list remains guidance rather than setting mandatory recovery targets. They argue producers should cover extraction costs and request a dedicated investment fund.123
Why — This shift protects recyclers from high innovation costs while addressing competition with cheaper materials.45
Impact — Manufacturers face increased costs for managing the recycling and recovery of materials they use.6
Read full response

Meeting with Maroš Šefčovič (Commissioner) and

11 Jul 2025 · Implementation dialogue on customs legislation - Rules of origin

Recycling industry urges EU to center circularity in decarbonization

8 Jul 2025
Topic — The Industrial Decarbonisation Accelerator Act supports energy-intensive sectors through investment and competitiveness.
Message — EuRIC calls for bridging circularity and decarbonization goals by creating lead markets for low-carbon products. They advocate for harmonized sustainability requirements in public procurement based on a life-cycle approach. The group stresses avoiding biased methodologies to properly reward recycled materials.123
Why — This framework creates reliable demand for secondary raw materials, ensuring long-term profitability for recyclers.4
Impact — Producers of primary raw materials may lose their competitive advantage against cheaper, recycled alternatives.5
Read full response

Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and Bureau of International Recycling

1 Jul 2025 · European and global recyclers in the context of EU circularity transition

Meeting with Jessika Roswall (Commissioner)

20 Jun 2025 · Visit to the sorting plant Evadam with EuRIC Exchange of views on Commissions work on textiles such as upcoming Circular Economy Act and Extended Producer Responsibility (EPR.)

Meeting with Aleksandra Kordecka (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné) and Federation française des entreprises du recyclage

30 Apr 2025 · Steel and Metals Action Plan and End of Life Vehicles (ELV)

Meeting with Jessika Roswall (Commissioner) and

24 Apr 2025 · Exchange of views on circular economy and the recycling industry

Meeting with Grégory Allione (Member of the European Parliament)

22 Apr 2025 · Visio FEDEREC et EURIC

Meeting with Vita Jukne (Cabinet of Commissioner Jessika Roswall)

11 Apr 2025 · Revision of REACH

Meeting with Giorgio Gori (Member of the European Parliament)

7 Apr 2025 · Export restrictions, scrap, waste, IED, recycled content provisions, Waste shipment regulation

Meeting with Aurel Ciobanu-Dordea (Director Environment) and NGO Shipbreaking Platform

2 Apr 2025 · Exchange of views on ship recycling

Meeting with Aurel Ciobanu-Dordea (Director Environment) and FEAD

1 Apr 2025 · Exchange of views on the textile sector and EPR schemes

Meeting with Felix Fernandez-Shaw (Director Directorate-General for International Partnerships) and

1 Apr 2025 · In the context of the EU-LAC Global Gateway Investment Agenda, the European Commission’s Directorate-General for International Partnerships (DG INTPA) launches an initiative with a view to develop circular economy value chains in Latin America

Recyclers' group EuRIC backs simpler EU sustainable finance reporting

26 Mar 2025
Topic — The initiative aims to simplify sustainability reporting to reduce administrative costs for companies.
Message — EuRIC calls for voluntary reporting standards for SMEs and alignment with CSRD thresholds. They support simplifying 'Do No Significant Harm' criteria and establishing clear guidelines for auditors.123
Why — Simplifying these rules would lower administrative costs and facilitate access to green financing.45
Read full response

Meeting with Peter Van Kemseke (Cabinet of President Ursula von der Leyen)

14 Mar 2025 · on Steel sector

European recycling industry urges mandatory green public procurement rules

7 Mar 2025
Topic — This initiative evaluates the effectiveness and relevance of three existing public procurement directives.
Message — EuRIC calls for mandatory environmental standards in procurement to stimulate demand for recycled materials. They advocate shifting from lowest-price bidding to a life-cycle perspective considering carbon impacts. The industry also seeks ambitious sustainability standards for construction products and metals.123
Why — This would create a stable market and higher demand for recycled materials.45
Impact — Primary raw material producers would lose market share as resource extraction declines.67
Read full response

Meeting with Piotr Müller (Member of the European Parliament, Shadow rapporteur)

3 Mar 2025 · Circularity requirements for vehicle design and management of end-of-life vehicles

Response to Implementing Act for guidelines on strategic projects

20 Feb 2025

EuRIC highlights that a material transition, in line with circularity ambitions, is essential to achieving the net zero transition, and that including mechanical recycling in NZIAs Annex I is key to this end.
Read full response

Meeting with João Cotrim De Figueiredo (Member of the European Parliament)

20 Feb 2025 · Recycling industry and automotive sector

Meeting with Aurel Ciobanu-Dordea (Director Environment) and Plastics Recyclers Europe and FEAD

13 Feb 2025 · Exchange of views on increasing the competitiveness of EU plastic recycling industry

Meeting with Pascal Canfin (Member of the European Parliament, Shadow rapporteur)

7 Feb 2025 · End-of-life of vehicles Regulation

Meeting with Pär Holmgren (Member of the European Parliament)

3 Feb 2025 · Circular economy and recycling

Meeting with Ingeborg Ter Laak (Member of the European Parliament)

30 Jan 2025 · Recycling, circular economy

Meeting with Michele Piergiovanni (Acting Director Competition)

29 Jan 2025 · Issues related to the European recycling industry

Meeting with Benedetta Scuderi (Member of the European Parliament)

28 Jan 2025 · Steel/Scrap

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

The European Recycling Industries Confederation (EuRIC) welcomes the opportunity to give feedback on the future delegated act laying down rules on the operation of the Digital Product Passport (DPP) and the role of service providers. Overall, EuRIC considers the DPP as a good opportunity for advancing recycling and the circular economy. To ensure that the DPP benefits European recyclers and is useful to their daily operations, the reality of recycling processes as well as the different needs of different product categories must be taken into account when designing and implementing it. Please find our detailed feedback attached.
Read full response

Response to Ship recycling – European list of ship recycling facilities (14th edition)

4 Dec 2024

The Ship Recycling Group of the European Recycling Industries Confederation (EuRIC) would like to take this call for feedback as an opportunity to address structural problems in the ship recycling sector. EuRIC calls for clear, detailed and enforceable guidelines and harmonised third-party audits for non-EU facilities to ensure that all yards included on the European list actually meet the same high environmental, waste treatment and worker safety and health standards. Additionally, there is a need for strengthening the ship recycling sector in Europe and thus increasing the EUs ship recycling capacity. Please find our detailed feedback attached.
Read full response

EuRIC urges three-year delay for new battery waste codes

8 Nov 2024
Topic — The European Commission is updating the official list of battery waste classifications.
Message — EuRIC requests a 36-month transition period to update facility permits for handling waste. They argue that classification should focus on product properties rather than chemical ingredients. They also advocate for fast-track notification procedures to streamline battery transport within the EU.123
Why — Recyclers avoid immediate operational disruptions and the high costs of permit updates.45
Impact — Environmental monitoring and waste traceability are delayed by the requested transition periods.67
Read full response

EuRIC warns battery recycling targets are currently unrealistic

18 Oct 2024
Topic — The EU is defining how to calculate battery recycling efficiency rates.
Message — EuRIC argues the proposed method is unrealistic because it assumes battery compositions are consistent. They request better data on material inputs and clearer technical definitions.123
Why — This would prevent recyclers from being penalized for failing to meet unachievable targets.45
Impact — Battery manufacturers would face higher costs to redesign products for easier recycling.6
Read full response

Meeting with Pascal Arimont (Member of the European Parliament) and FEAD and

15 Oct 2024 · Circular Economy and waste management

Meeting with Christian Ehler (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

4 Oct 2024 · Clean Industrial Deal

Meeting with Kurt Vandenberghe (Director-General Climate Action)

26 Sept 2024 · Video message with "decarbonization" as main topic

Response to Environmental Implementation Review 2025

5 Jul 2024

The European Recycling Industries Confederation (EuRIC) welcomes the opportunity to provide feedback to the EU Environmental Law - 2025 Implementation Review to enhance the effectiveness of environmental policies within the EU. EuRIC represents the recycling industry at a European level, bringing together the majority of national recycling federations from EU/EEA Member States. As the voice of over 5,500 recycling companies, ranging from market leaders to SMEs, EuRIC members generate an aggregated annual turnover of approximately 95 billion by treating various waste streams such as ferrous and non-ferrous metals, end-of-life vehicles (ELVs), electronic waste (WEEE), packaging, end-of-life tyres, textiles, and construction and demolition waste. Earlier this year, EuRIC published its priorities for the new EU institutions mandate, emphasizing the importance of effective implementation to transition from a linear to a circular economy and enhance EU environmental policies. The main priorities where implementation is crucial include: - Accelerating the adoption of EU-wide End-of-Waste criteria through a fast-track procedure when all the stakeholders in the value chain or several Member States have agreed upon them. Additional EU-wide end-of-waste criteria could be developed for example for recovered paper, tyres and those metals that are not yet covered. - Waste Hierarchy: More targets, better enforcement, and guidelines are necessary to prioritise high levels of prevention, reuse and recycling. Rethinking the waste hierarchy with an approach that views waste as a resource could be a game-changer in minimizing waste and ensuring that recycled materials are incorporated back into new products. - Economic incentives: Fit-for-purpose economic incentives are crucial for increasing the share of recycled materials used in the EU. EuRIC supports Green Public Procurement policies as well as VAT Reduction for recycled materials. These incentives catalyse investments, foster innovation in recycling technologies, and bridge product design with high-quality recycling. - Legislative framework and enforcement: The existence of a harmonised and binding legal framework ensures uniform application of the rules and encourages product circularity at European level. In order to ensure a harmonized implementation and enforcement of new environmental rules, EuRIC supports the development of Regulations (instead of Directives), as appropriate. Increasing the enforcement efforts by the European Commission is key for a proper environmental implementation at national level.
Read full response

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

3 Jul 2024

EuRIC and Eurometaux jointly call upon the European Commission to reconsider its assessment of the alignment of the WSR 1013/2006 with the new e-waste entries under the Basel Convention and to do it only for WSR 2024/1157 where we also suggest to create an intra-EU waste code for non-hazardous waste for which the information procedure (WSR Annex VII) is maintained. From now until May 2026, when the Art. 27 under the WSR 2024/1157 has to be fully implemented, we shall focus on preparing and introducing the EU digitalised system (EDI) for electronic submission of documents and more harmonised and streamlined procedures by notifiers and competent authorities. For more details see the joint paper attached.
Read full response

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

3 Jul 2024

EuRIC and Eurometaux jointly call upon the European Commission to reconsider its assessment of the alignment of the WSR 1013/2006 with the new e-waste entries under the Basel Convention and to do it only for WSR 2024/1157 where we also suggest to create an intra-EU waste code for non-hazardous waste for which the information procedure (WSR Annex VII) is maintained. From now until May 2026, when the Art. 27 under the WSR 2024/1157 has to be fully implemented, we shall focus on preparing and introducing the EU digitalised system (EDI) for electronic submission of documents and more harmonised and streamlined procedures by notifiers and competent authorities. For more details see the joint paper attached.
Read full response

Meeting with Kurt Vandenberghe (Director-General Climate Action)

4 Jun 2024 · lower the carbon footprint of steelmaking

Meeting with Michael Bloss (Member of the European Parliament) and Transport and Environment (European Federation for Transport and Environment) and

2 May 2024 · Green Industrial Deal

Meeting with Maroš Šefčovič (Executive Vice-President) and

22 Mar 2024 · Clean Transition Dialogue with the Steel Sector

Meeting with Margrethe Vestager (Executive Vice-President) and

22 Mar 2024 · Discussion of current challenges facing the European Steel sector attended by private industry as well as Ministers and official representatives of Italy, Romania, Poland, Czechia, Belgium, Hungary and Luxembourg

EuRIC demands product-based rules to boost steel recycling

18 Dec 2023
Topic — The European Commission is updating rules for free emission allowance allocations.
Message — EuRIC requests a methodology independent of feedstock. They advocate for a product-based approach treating all steel producers equally.12
Why — Recyclers would benefit from increased demand for ferrous scrap in steelmaking.3
Impact — Traditional steel producers would lose profits from the current overallocation system.4
Read full response

Response to Persistent organic pollutants – Annex I amendment

18 Dec 2023

The European Recycling Industries Confederation (EuRIC) strongly welcomes the objective of the European Commissions proposal to protect human health and the environments from persistent organic pollutants (POPs) prohibiting and phasing out, or restricting the manufacturing, placing on the market and use of substances subject to the Stockholm Convention on POPs. EuRIC represents the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5,500+ recycling companies from market leaders to SMEs generating an aggregated annual turnover of about 95 billion EUR by treating various waste streams such as household or industrial & commercial waste including ferrous and non-ferrous metals, end-of-life vehicles (ELVs), electronic waste (WEEE), packaging (paper and plastics), end-of-life tyres or textiles as well as waste from construction and demolition (C&D). Although EuRIC and its national recycling federations and companies fully support the rationale of the proposal in-question, we would like to point out the importance of aligning any proposal for new limit values with the circular economy to make sure that legacy substances are being phased out without jeopardizing the close the loop concept. The attached paper outlines EuRICs position on the proposed Unintentional Trace Contaminant (UTC) values for PFOS and its salts as well as UTC for PFOS-related substances in substances, mixtures and articles.
Read full response

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

13 Nov 2023 · Waste Shipment Regulation

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

18 Oct 2023

The Waste Framework Directive is a critical legislative instrument guiding waste management operators across EU Member States. As the EU seeks to continually enhance its environmental policies, the European Recycling Industries Confederation (EuRIC) commends the efforts to partially revise this Directive to address current challenges. EuRIC Textiles, EuRICs branch dedicated to textiles reuse and recycling, welcomes the focus placed on textile waste. While EuRIC Textiles supports the overall aim of the revision, we have identified several critical points that require careful consideration to ensure the Directives effectiveness. We refer to our attached paper for a detailed overview of our position.
Read full response

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

27 Sept 2023 · Waste Shipment Regulation

Response to European Critical Raw Materials Act

29 Jun 2023

The European Recycling Industry welcomes the European Commissions (EC) proposal for a Regulation on Critical Raw Materials and acknowledges the Commissions commitment to set ambitious measures to boost the circularity of CRMs, which are often indispensable inputs for a wide set of strategic sectors including renewable energy. EuRIC represents the European recycling industry at an EU level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies from market leaders to SMEs generating an aggregated annual turnover of about 95 billion by treating various waste streams (e.g., metals, plastics, textiles, e-waste including batteries, tyres, paper etc.,). This paper outlines the position of the European Recycling Industry on the aforementioned proposal and is meant as a response to the EC open public consultation. EuRIC looks forward to working closely with the European Commission and the co-legislators to ensure the introduction of harmonized rules on critical raw materials that promote the Unions circular economy targets. The recycling industry stands ready to provide support in the development of delegated acts and implementing provisions. For more information on EuRIC's position, please consult the attached pdf document.
Read full response

Recyclers demand independent expert verification for green claims

21 Jun 2023
Topic — The EU proposes rules requiring companies to substantiate environmental claims using specific footprint methods.
Message — EuRIC requests that environmental claims are verified by independent third-party experts with specific competence. They also call for all data to be transparent, freely accessible, and sufficiently detailed.12
Why — The industry benefits from rules preventing competitors from falsely claiming products contain recycled materials.3
Impact — Producers making false or exaggerated environmental claims will lose the ability to mislead consumers.4
Read full response

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton)

15 Jun 2023 · will follow

EuRIC urges inclusion of mechanical recycling in net-zero list

2 Jun 2023
Topic — The consultation addresses the proposed Net Zero Industry Act for manufacturing technologies.
Message — EuRIC requests that co-legislators include mechanical recycling technologies in the regulation's Annex. They also advocate for regulatory sandboxes to test innovative recycling methods under flexible conditions.12
Why — This would lower administrative costs and accelerate permitting for recycling infrastructure.3
Read full response

EuRIC Urges Flexible Recycling Targets in EU Taxonomy

3 May 2023
Topic — The EU is establishing a classification system for sustainable investment in waste management.
Message — EuRIC requests deleting the 50% recovery target for waste sorting activities. They advocate for technology-neutral plastic targets and allowing commingled collection of certain materials.12
Why — This would ensure recycling companies maintain access to vital sustainable finance.3
Impact — Environmental safety might suffer from reduced oversight at hazardous waste treatment sites.4
Read full response

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and EuroCommerce and

28 Mar 2023 · Packaging Waste

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

20 Dec 2022 · Waste Shipment Regulation

Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

The European Recycling Industries Confederation (EuRIC) is pleased to provide its feedback to the fitness check of the Polluter Pays Principle (PPP) opened by the European Commission and aiming at assessing whether policies ensure that polluters bear the cost to prevent, control and remedy pollution.
Read full response

Response to European Critical Raw Materials Act

25 Nov 2022

The European Recycling Industries Confederation (EuRIC) welcomes the European Commissions initiative on Critical Raw Materials (CRMs) and is pleased to share the view of European Recyclers about what is needed at an EU level to achieve the very goals of it. EuRIC is the authoritative voice of the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States and leading recycling companies, the Confederation represents about 5,500+ recycling companies from market leaders to SMEs generating an aggregated annual turnover of about 95 billion EUR by treating various waste streams such as household or industrial & commercial waste including ferrous and non-ferrous metals, electronic waste (WEEE), end-of-life vehicles (ELVs), packaging (paper and plastics), end-of-life tyres or textiles. As also highlighted in the call for evidence - published by the EU Commission on September 30, securing sufficient supply of critical raw materials will be of paramount importance for the EUs green and digital transitions. This is strongly linked and connected with the fact that currently, the EU is heavily dependent on concentrated supply sources from a few third countries for a number of critical raw materials, which shows the urgent need to further close the loop in the EU critical raw material value chain. Further closing the loop of the aforementioned value chain will also bring the EU COM one step closer to reaching the ambitious but necessary targets of both the EU Green Deal and new Circular Economy Action Plan (CEAP). EuRIC would like to reiterate that the principles of the circular economy are based on the fact that production processes without a closed cycle of material use have no future in a world of finite resources. For the entire position of the European Recycling Industries' Confederation, please consult the attached documents.
Read full response

Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

The European Recycling Industries Confederation (EuRIC) represents the recycling industry at a European level. Uniting national recycling federations from EU/EEA Member States, the Confederation represents more than 5,500+ recycling companies from large industry to SMEs generating an aggregated annual turnover of about 95 billion EUR by treating various waste streams such as household or industrial & commercial waste including ferrous and non-ferrous metals, end-of-life vehicles (ELVs), electronic waste (WEEE), packaging (paper and plastics), end-of-life tyres and textiles. EuRIC strongly supports the European Commissions initiative to evaluate the Directive on Waste Electrical and Electronic Equipment (WEEE) which goal is to protect the environment and human health, contribute to sustainable production and consumption as well as ensure that resources are used efficiently in an EU circular economy. In terms of sustainability, although EuRIC believes that a significant step forward has been made since the Directives entry into force in 2012, European recyclers believe that there is room for improvement in order to realise the objectives of the EU Green Deal and the new Circular Economy Action Plan (CEAP). The entire position of EuRIC can be read in the attached document.
Read full response

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Rapporteur)

22 Aug 2022 · Waste Shipment Regulation

Response to Type approval of motor vehicles regarding access to in-vehicle generated data

2 Aug 2022

The European Recycling Industries' Confederation - EuRIC - represents Authorised Treatment Facilities (ATFs) and the vast majority of ELV recycling facilities (shredders and post-shredder installations) which recycle ELVs in Europe. EuRIC therefore has a strong interest in ensuring that access to vehicle data, functions and resources supports the objectives set by the new Circular Economy Action Plan regarding ELV recycling and protects the ecosystem of treatment facilities which is indispensable to achieve very high recovery rates (95%). Access to (encrypted) vehicle data will play an essential role in the circularity of the vehicles. The automotive sector is undergoing two revolutions at the same time. One related to the replacement of combustion engines with batteries (EV) and the other one to the massive digitalisation of cars, which impacts both cars’ hardware and software used to render services. As a result, vehicles will be permanently linked to the car manufacturer throughout their lifetime. Access to data is not only essential for the car user, but also for the operators performing repair operations during the lifetime of a car and operators performing dismantling and recycling operations when the car reaches end-of-life stage. While some of the requirements related to the vehicle data are already regulated by specific legislation, namely the EU-type approval vehicle legislation and the End-of-Life Vehicle Directive, it is essential to remind a few critical points, at the time major pieces of legislation are being revised. This is obviously the case of the Commission’s proposal for the Data Act in the hands of the co-legislator and of the upcoming revision of the ELV Directive into a Regulation with a likely merger with Directive 2005/64/EC on the type approval of motor vehicles with regard to their reusability, recyclability, and recoverability (3R type-approval). Against that dynamic landscape, EuRIC would like to stress the importance of some key principles aiming at ensuring that access to all necessary data will be granted to operators carrying out dismantling and recycling activities. Should such access to relevant data be denied, the objectives set in the new Circular Economy Action Plan will be impossible to meet in the field of ELV recycling. This will come at huge costs in terms of job losses and investments made by the industry to recycle cars in Europe (as highlighted by a study made by the Trinomics study for the European Commission (DG Environment), within the framework of the revision of the ELV Directive, 88% of the costs borne to meet the targets set by the ELV Directive are paid by dismantlers & recyclers) and substantial negative impacts on the circularity of cars. EuRIC calls for overarching principles should be set in EU legislation that all relevant data to perform activities contributing to the circularity of cars shall be: 1. Made available, without any restriction, to duly licensed economic operators active in the treatment of ELVs (car dismantlers, car shredders and post-shredders, etc.) to i) enable them to compete on a level playing field and ii) provide circular services and industrial activities at a competitive price for end-users. 2. Economic operators active in the treatment of ELVs shall have the right to use the data the way they want/need to perform their activities. This is equally important to enable the creation of new services or meet regulatory obligations, which may arise regarding repair and re-use. Should such rights be disregarded, car manufacturers having a natural access to the data generated by the vehicle will enjoy a monopolistic position, which will be easy to abuse, that will render overly difficult if not impossible even basic repair, re-use and recycling operations and more widely challenge the circularity of the entire vehicle / mobility sector.
Read full response

Response to Ozone layer protection – revision of EU rules

23 Jun 2022

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the proposal - published by the EU Commission on April 8, 2022 - for a Regulation on substances that deplete the ozone layer. Ozone depleting substances (ODS) have depleted throughout the years the stratospheric ozone layer which has led to an increased solar UV-B radiation at the surface of the Earth (Norval et. all, 2011). This has had as a consequence a huge negative impact on the environment and human health and hence reducing emissions is crucial – now more than ever. EuRIC is the umbrella organisation that encompasses a network of European Member State and National recycling associations. It is the link between the recycling industry and the European Union, acting as the platform for co-operation and the exchange of best practices across the industry. EuRIC represents key companies included in the collection, processing, recycling, transport, and trade of various recyclables (metals, paper, plastics, tyres, construction & demolition waste from household or industrial waste, WEEE, ELV, Packaging, etc.) across Europe. For more information on the opinion of European Recyclers, please consults the attached document.
Read full response

Response to Sustainable Products Initiative

22 Jun 2022

EuRIC strongly welcomes the publication of the proposal for a Regulation on Ecodesign for Sustainable products (2022/0095 (COD)) accompanied by the Communication on making sustainable products the norm (COM (2022) 140 final). Eco-design for recycling is a pre-condition to move towards a more circular economy. As stressed in the Top 5 Priorities of the Recycling Industry for the Period 2019 -2024, it is estimated that 80% of products’ environmental impacts are determined at design stage. Still, the vast majority of products placed on the market are designed without any consideration for their end-of-life stage. For this reason, EuRIC strongly believes that the proposal, provided it is being further strengthened during the adoption process, will bring many benefits which will help close the loop of materials in many product-related value chains. EuRIC also welcomes the proposal of the European Commission to extend the scope of Ecodesign Directive to non-energy related products and to opt for a regulation instead of a directive. The wide scope, provided it is combined with a smart prioritisation of product-categories to complement existing sectorial legislation (for battery, packaging, ELV recycling, etc.) in which eco-design requirements will be set, should ensure that products placed on the market are more circular. Among the various ecodesign criteria to be taken into account, EuRIC strongly supports the inclusion of recycled content (RC). Binding RC targets have proved to be an essential component to boost design for circularity and internalise in prices the environmental benefits of recycled materials compared with extracted or bio-based (wood) materials. Indeed, recycled content targets are not only the most efficient incentive to boost circular value chains and de-correlated prices of raw materials from recycling from extracted raw materials, they also result in a shared responsibility to design products for recycling, since regulatory targets can only be achieved if the very design of the products placed on the market facilitates materials recovery. Regarding the introduction of a Digital Product Passport (DPP) to provide clear, structured and accessible data relevant to their circularity and sustainability, it can prove to be very useful regarding in particular streams such as textiles for which materials recovery have an important margin for improvement, for the share of the stream which is not fit for re-use. The DPP will not only help consumers make informed choices and public authorities perform better checks and controls but will also provide information about the materials contained in a particular product, any repairs that may have taken place, how to extend the lifetime of the product and most importantly useful information regarding material recovery for streams such as end-of-life textiles or tyres. Work is being done by the recycling industry on data that would be the most useful within the DPP for specific waste streams. In addition, EuRIC entirely shares the findings of the European Commission’s preliminary assessment identifying “that product categories such as textiles, furniture, mattresses, tyres, detergents, paints, lubricants, as well as intermediate products like iron, steel and aluminium, have high environmental impact and potential for improvement, and may thus be suitable candidates for the first workplan”. Setting eco-design requirements not only at end-product level but also at production stage, such as for steel or aluminium, is essential to boost the circularity and climate-neutrality of semi-finished products which will be used in a variety of applications, thus maximising the impacts of such requirements. Particularly, it is essential to set ecodesign requirements for tyres and textiles as well as iron, steel and aluminium. EuRIC looks forward to work with the EU institutions to support an ambitious implementation of the Sustainable Products Initiative.
Read full response

Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of the call for evidence published by the European Commission on the restriction of hazardous substances in electronics. EuRIC is fully in line with the fact that restricting the use of hazardous substances will have as a result cleaner material cycles and environmentally sound waste treatment of electrical and electronic equipment (EEE). For the full position of EuRIC, please consult the attached document.
Read full response

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

22 Feb 2022

The European Recycling Industries’ Confederation (EuRIC) thanks the European Commission for publishing the Call for Evidence for an Impact Assessment with regards to the revision of the Waste Framework Directive (WFD) and is pleased to provide some preliminary feedback essential for the European recycling industry. EuRIC acknowledges the fact that the WFD has played a key role in the development of waste management in the EU. Yet, it is absolutely essential to ensure that any revision of the WFD will factor in the paradigm shift according to which waste is a resource to be recycled and not a risk to be treated. Among EuRIC key recommendations are to speed up harmonisation at EU level of end-of-waste criteria in order to ease market access and reward quality of raw materials from recycling (RMR), two elements which are absolutely essential to accelerate substitution of extracted raw materials and thus reduce GHG emissions and energy consumption. In addition, EuRIC calls the European Commission to set binding recycled content targets for base metals, paper, plastics (including technical plastics from WEEE and ELVs), rubber in tyres and glass in order to pull the demand for RMR in semi-finished products and products and thus boost circular value chains. On EPR Schemes, a one-size-fits-all approach is not suited to specificities of the various waste streams. For the existing EPR Schemes, it is absolutely essential to ensure an effective eco-modulation of fees to connect the dots between product design and recycling as well as to ensure that EPR schemes are not responsible for unfair competition in recycling markets, as currently witnessed and which is a major threat for circular value chains. Please see the attached document for our detailed comments.
Read full response

Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

EuRIC welcomes the draft regulation on recycled plastic materials and articles intended to come into contact with foods, repealing Regulation (EC) No 282/2008. These updated rules can serve as a means to increase plastics recycling capacity across Europe, fostering its competitiveness through the development of new and innovative recycling technologies, to ensure an increase not only in the quantity but also the quality of recycled plastics. Thus, it is also necessary to increase the recycled content in plastic products and packaging, boosting the market for Raw Materials from Recycling (RMR) in Europe and guarantee the security that the plastics recycling value chain needs to make investments. Although this regulation is focused on the decontamination process, EuRIC believes that the definition of pre-processing and especially, post-processing should be further clarified in other to avoid confusion and to be in line with the Waste Framework Directive, as these unit operations constitute the ‘recycling process’, according to Art. 2(17). Making a distinction between the recycling and the converting process is highly needed, since the ‘recycler' applies a decontamination process and the ‘converter’ carries out one or more post-processing unit operations. Moreover, the definition of ‘plastic input’ in Art. 2(7) does not provide clarity between waste and product. In some cases, when end-of-waste criteria are applied, the plastic input is not a waste anymore but a recycled plastic product ready to substitute virgin material. Regarding the requirements for collection and pre-processing (Art.6), EuRIC supports intra-EU sourcing and plastic waste collected outside the European territory provided it meets EU or equivalent standards. Additionally, according to these requirements, a certified quality assurance system must be set up by waste management operators involved in the collection of plastic and pre-processing activities to ensure the quality and traceability of the plastic input. Sufficient time should be granted for those operators to adapt to that requirement and detailed information should be provided for the certification schemes and audits. EuRIC suggests standard ISO 9001, which sets out the criteria for a quality management system and can be certified. EuRIC supports the conditions addressed under Art. 6.2, together with better-quality control in collection and acceptance processes, which will minimize the risk of cross-contamination from waste disposal. As regards the development of novel technologies (Art.10), it does not include the specific criteria to consider the technology as a novel one so it should be modified with clear criteria (e.g., decontamination parameters). In addition, a harmonized method is needed for the monitoring and reporting of contamination level (Art. 13) so the testing of contaminants of plastic input and output batch can lead to comparable results from different recyclers and developers. This should be accompanied by guidelines on how to measure the input batch or which substances can be analysed in which state (bales/flakes), etc. Besides, it does not specify the list of substances or the contamination thresholds (based on EU Reg. 10/2011). Regarding the assessment of novel technologies (Art. 14), the procedure should be streamlined to minimize the risks of investing in the development and operation of a novel technology, since recyclers are obliged to take samples and report to developers. In general, the efforts and investments necessary for testing could discourage the installation of novel technologies: input batch sizes of 30 tonnes and analysis of plastic input and recycled plastic output to ident 20 contaminants are not realistic. EuRIC believes the required processes to assure the quality and safety of recycled plastics are a shared responsibility along the value chain, and thus, a cross-cutting coordination is needed to guarantee the circular economy of the food packaging.
Read full response

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

17 Dec 2021

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of the proposed Regulation on persistent organic pollutants (POPs) which contains – in Annex IV & V - the updated concentration limit values of POPs in waste. More precisely, these limit values are of an utmost importance for recycling facilities as they largely determine the treatment of the waste and, in particular for limits in Annex IV, define whether a waste containing specific POP substances should be disposed of in such a way that the POP content is destroyed or irreversibly transformed or whether it can be subjected to other recovery or disposal operations, in particular recycling. In that regard, EuRIC - after having held discussions with several experts within the plastic recycling industry - would like to express its reservations about the preferred options selected by the European Commission for Annex IV limits, and more precisely for limits concerning PBDEs and PFOA (including its salts and related compounds). EuRIC has therefore identified a number of consequences which will negatively affect the recycling industry, should the proposed LPCL for PBDES (from 1,000 to 500 mg/kg) and PFOA (1mg/kg for PFOA and salts and 40mg/kg for PFOA related compounds) enter into force.
Read full response

Response to Persistent organic pollutants - annex I amendment

3 Dec 2021

The European Recycling Industries’ Confederation (EuRIC) is the umbrella organisation that encompasses a network of European Member States and National recycling associations. It is the link between the recycling industry and the European Union, acting as the platform for co-operation and the exchange of best practices across the industry. EuRIC represents key companies included in the collection, processing, recycling, transport, and trade of various recyclables (metals, paper, plastics, tyres, construction & demolition waste from household or industrial waste, WEEE, ELV, Packaging, etc.) across Europe. Hexachlorobenzene (HCB) was used many years ago as a flame retardant, mainly in rubber but perhaps also in plastics. Similarly with a brominated flame retardant like DecaBDE, also HCB has a melting point far above the melting point of used plastic, like PS and ABS. There is however a big difference in term of density between the two aforementioned substances. While HCB has a density of 1.8±0.1 g/cm3, DecaBDE has a density of 3 g/cm3. This shows why density sorting of HCB containing plastics is more difficult than the for brominated ones. Noteworthy to mention is that the average concentration of flame retardants in plastics required to ensure proper protection is approximately 25 w%. EuRIC – with this reaction – would like to express its concern about the limit value selected (10mg/kg) as preferred option for the Hexachlorobenzene substance which is to be introduced in Annex I of the Regulation on persistent organic pollutants (POPs). The concern is based on the fact that the aforementioned limit value is too low and may have unforeseen consequences and impact on the recycling industry. In rubber recycling, for instance, if such limit value were to enter into force that would mean that the margin of error would automatically be lowered to the maximum extent possible. By taking as an example a flame retardant concentration of 10 w%, we can easily deduce that if one out of 10.000 flakes is incorrectly sorted, the value of 10 mg/kg will be reached. Furthermore, EuRIC calls on the European Commission to consider whether there is currently available a standard for analysing HCB in waste or not. In the scenario that such standard exists, EuRIC would like to state that is of an utmost importance for recycling facilities to know the range that the aforementioned standard has been validated for. Should for example the validation for HCB be valid for a limit value of above 100mg/kg this means that for any value below this validated limit it is impossible for recyclers to prove compliance. Therefore, EuRIC calls on the EU COM to consider increasing the limit value of 10mg/kg to 100mg/kg, as this would undoubtedly ensure more materials coming from recycling injected into the EU market, ultimately promoting a Circular Economy. Furthermore, EuRIC would like to state that this request is even more relevant since the proposed limit value is not accompanied by any scientific evidence and therefore proposes more research to be carried out before introducing such a low limit value – in annex I – for this substance. In the scenario that the EU COM would like to pursue the above-mentioned limit value, EuRIC strongly opposes for this value to be accompanied by requirements on sampling and analysis as concentrations as lows as 10 mg/kg of HCB would require a very costly analysis in order to be detected with good accuracy. In that regard, EuRIC fears that there is no available standard at the moment for analysing HCB in waste and therefore such analysis will only result burdensome to recycling facilities without bringing any added value.
Read full response

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

10 Nov 2021 · Waste shipment legislation

Response to Environmental impact of photovoltaic modules, inverters and systems - Energy Labelling

28 Oct 2021

Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European Recycling Industries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024”, 80% of products’ environmental impact are determined at a design stage. Although the above-mentioned fact is also stated in the new Circular Economy Action Plan (CEAP), the vast majority of products placed on the EU market – and not only – are still designed without any consideration for their end-of-life stage. Design for circularity is of an outmost importance to move towards a more circular economy and needs to be extended to all products’ categories, including photovoltaic modules, inverters and systems. EuRIC thus fully supports the necessary ‘Environmental impact of photovoltaic modules, inverters and systems’ legislative initiative to keep the already exploited resources - used for the manufacturing of photovoltaics modules, inverters and systems - in the market for as long as possible while at the same time significantly reducing the negative environmental impact that the in-question products are generating when are not designed to support and promote sustainability. Please find in the attached document the top priorities identified by EuRIC.
Read full response

Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

The European Recycling Industries’ Confederation (EuRIC) thanks the European Commission for opening this initiative on a clear policy framework on the use of biobased, biodegradable and compostable plastics. EuRIC fully supports the objectives to reduce consumer confusion, and increase environmental protection; however, the initiative neglects one key aspect: the implementation of a true and functioning Circular Economy. A detailed response is provided in the attachment provided. Please take this as EuRIC's main submission to the roadmap. We have further summarised the key points below. Biobased plastics are supported when renewable and sustainable materials are utilised to produce "drop-in" bio-plastics (bio-PE, bio-PET, bio-PP) which can be recycled with the use of current technologies, and where LCA data proves their sustainability. Biodegradable and compostable plastics, however, are currently disruptive within the current framework, and the main incentive for their uptake was for the greenwashing of products. A lack of information on the various types of plastics leads often to improper consumer sorting and collection - which later disrupts recycling practices (leading to the degradation of recycled plastic quality). This is owing to their different composition to conventional plastics. Compostable plastics are disruptive as they rarely meet "in-real-life" composting performance, and therefore are often incinerated or landfilled, and even when composted provide little-to-no nutritional value to compostate. Therefore they are merely a barrier to good composting practices with little-to-no added value.
Read full response

Meeting with Chris Uregian (Cabinet of Vice-President Margaritis Schinas), Maria-Myrto Kanellopoulou (Cabinet of Vice-President Margaritis Schinas)

22 Jun 2021 · Waste Shipment Regulation impact on the recycling sector

Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

17 Jun 2021

The European Recyclers’ Industry Confederation (EuRIC) welcomes this draft Implementing Decision regarding the calculation, verification and reporting of data on the separate collection of waste single-use plastic beverage bottles. Unfortunately we received notice of this consultation late and have not had time to properly consult our membership. Nevertheless, owing to the importance of this Implementing Decision, we would like to be of the up-most service to the process. Therefore, we would kindly request for the European Commission to consult us directly if any further expertise is required on the matter at hand. We will further develop proper information for you in the coming weeks. We apologies for this delay. EuRIC represents the recycling industry at a European level. Gathering the vast majority of national recycling federations from EU/EEA Member States, the Confederation represents about 5.500+ recycling companies – from market leaders to SMEs – generating an aggregated annual turnover of about 95 billion € by treating various waste streams such as household or industrial & commercial waste including ferrous and non-ferrous metals, end-of-life vehicles (ELVs), electronic waste (WEEE), packaging (paper and plastics), end-of-life tyres or textiles. Broadly, EuRIC supports the contents of the Implementing Decision and the calculation methodology for collection rates of waste single-use plastic beverage bottles (as listed in Part F of the Annex to Directive (EU) 2019/904). However, a few clarifications are required, from a first glance. Article 2(8) – It is stated here that the share will be determined based upon “representative sampling and subsequent compositional analysis”. This terminology seems, from an Industrial standpoint, to limit possible digital solutions for determining the calculations. We firmly believe that digital counting must be allowed wherever possible. Article 3(1) – The phrasing of this section is very misleading. Our understanding is that only beverage bottles which will at some point contain a beverage will have the (empty) packaging weighed. If this is the case, we would rephrase the article to: “The weight of single-use bottles placed on the market shall not include the weight of any bottles which were placed on the market without being filled with beverage” OR “The weight of single-use bottles placed on the market shall include only the weight of (empty) bottles that were placed on the market after having been filled with beverage”.
Read full response

Response to Ecodesign and energy labelling working plan 2020-2024

2 Jun 2021

The European Recycling Industries’ Confederation (EuRIC) welcomes the roadmap on eco-design and energy labelling working plan 2020-2024 and its aim to combine the future priorities for the implementation of the Ecodesign Directive 2009/125/EC and Energy Labelling Regulation (EU) 2017/1369. Promoting energy efficiency and setting clear eco-design rules will undoubtedly help Europe to achieve the targets set by the EU Green Deal and the new Circular Economy Action plan. According to these action plans, there is a clear need - now more than ever – for the EU as a whole to start using efficiently its resources. To achieve that, it -through the above referred roadmap – should make sure to keep the already exploited resources in the market for as long as possible by connecting the dots between the design and end-of-life (EoL) phase of products. This is strongly linked and connected with setting up proper eco-design requirements for the product categories under consideration which will ease dismantling and hence recycling practices. As the recycling industry is at the heart of the Circular Economy, it is an absolute must for future legislations to build proper fundamentals which will allow recycling facilities to recover most of the materials discarded by end-users and then be able to find appropriate demand in order to reinject those materials into the market. In that regard, EuRIC believes that some of the requirements included in the preparatory study for end-of-life can be further elaborated and improved. The areas where further improvements can be made are listed in the attached document.
Read full response

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The European Recycling Industries’ Confederation (EuRIC) welcomes this draft delegated regulation under Article 8 of the Taxonomy Regulation (thereafter the ‘delegated regulation’) outlining the methodology of disclosure obligations for large undertakings. We appreciate that this is an important aspect of the overall Sustainable Finance Taxonomy to get correct, to push much needed investments strongly and increasingly towards sustainable economic activities. Nevertheless, it is unclear from this delegated regulation on some of the key details required from our industry to disclose on our sustainable activities. This is caused by several instances of ambiguous legal text, cross-referral between other legal documents, and a lack of clarity on issues of concern. These concerns are principally regarding the timeline and what is precisely required to be disclosed by 2022. The exact list of queries is listed within the attached Position Paper. Furthermore, although we understand the delegated regulation is targeting large undertakings, we deem it extremely important to emphasise that this legislation will cause a ripple further effecting SMEs (many of which, are our members) sharing value-chains with these larger organisations. This is, again, fully explained within our position paper.
Read full response

Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The European Recycling Industries’ Confederation (EuRIC) welcomes the Inception Impact Assessment on the revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals (REACH) and its main objective to transition towards a clean Circular Economy. Bridging the various phases of products’ life cycle in relation to chemicals to achieve safe products and non-toxic material cycles, including through substitution, is of paramount importance to support a safe circular economy, given the lasting problems posed by legacy substances at recycling stage, regardless of the separation and sorting technologies used for material recovery purposes and streams at stake (WEEE, packaging, ELVs, tyres, textiles, batteries, etc.). EuRIC finds the problem the above initiative aims to tackle very relevant not only for downstream users of chemicals but also for companies who recycle – a large number of small, medium and large enterprises scattered across the EU whose role in the Circular Economy journey is considered of an utmost importance. Thus, the top priorities identified by EuRIC – which will further ameliorate the aforementioned legislative framework - are analyzed in detail in the attached document.
Read full response

Meeting with Florika Fink-Hooijer (Director-General Environment)

13 Apr 2021 · Circular Economy Action Plan

Response to Modernising the EU’s batteries legislation

26 Feb 2021

The European Recycling Industries’ Confederation (EuRIC) welcomes the long-awaited proposed Batteries and Waste Batteries Regulation published by the EU Commission on December 10, 2020. It is a fact that improving the design of batteries – making them more sustainable, readily removable and easily recyclable - is a pre-condition to transition towards a circular economy. It is also part of the solution to tackle acute problems faced by recyclers linked to the ever-increasing battery fires during the collection, transport and treatment of the booming end-of-life products containing batteries, which pose major problems. EuRIC sees the Commission’s Proposal as a huge step forward in terms of connecting the dots between the design and end-of-life (EoL) phase of batteries (from design & production to reuse & recycling) while simultaneously minimizing their harmful effects on the environment – and as a consequence on human health. However, some points have been identified by EuRIC for further improvements; where clarifications, changes or additions are needed to establish a well-functioning regulatory framework. The points identified by EuRIC on the different provisions included in the proposed Regulation for Batteries and Waste Batteries are mentioned in detail in the attached document.
Read full response

Response to EU strategy for sustainable textiles

2 Feb 2021

The European Recycling Industries’ Confederation (EuRIC) represents national re-use and recycling federations as well as companies in lieu active throughout Europe in the field of collecting and processing post-consumer textiles (preparing for re-use and recycling) and is very pleased to provide feedback to the roadmap on the EU Strategy for Textiles. EuRIC strongly welcomes the initiative to build a comprehensive framework to boost the European market for circular and sustainable textiles. The European textiles re-use and recycling industry is already strongly committed and a key player to accelerate the transition to a circular economy in textiles. Taking into account the aims of the European Green Deal, the Circular Economy Action Plan as well as the Industrial Strategy, we believe that this initiative will support the efforts of making the whole textile value chain more circular. Additionally, it will support textile collection, preparation for re-use and recycling across Member States in line with the waste hierarchy. EuRIC in particular would like to stress the following measures to boost circularity in textiles: • Extended Producer Responsibility (EPR) scheme Extended producer responsibility can play a major role in promoting circular and sustainable textiles. EuRIC supports the initiation of an EPR scheme for textiles in accordance with the minimum requirements of Article 8a of the Waste Framework Directive to ensure the establishment of a comprehensive system in the EU. Please see attached position paper for further information. • Harmonized European end-of-waste criteria Harmonized European end-of-waste criteria for textiles after collection and sorting that are intended for recovery (i.e., wiper production / mechanical or chemical recycling) are needed to support the marketing of the secondary raw materials. • Ecodesign criteria The shift towards synthetic fibers directly impacts the quality and the end-of-life recyclability, especially if blended with other synthetic or organic fibers. It is therefore of utmost importance to already take the end-of-life of the textile item into account when designing it in the first place. It is important to design textiles in a more durable and resistant way to prolong their life or to increase their recyclability. • Mandatory recycled content targets Recycled content targets for textiles are needed to pull the demand for quality recycled fibers, boost end-markets for separately collected used textiles and invest to scale up textiles’ material recovery. EuRIC suggests that new textile products should contain 10% recycled textile content by 2025 and 25% recycled textile content by 2035 (max. 1/3 pre-consumer and 2/3 post-consumer). • Strong end-markets for second hand textiles In terms of end-markets, depending on Europe’s geographic area, around 70% to 75% of used textiles prepared for reuse are exported outside the EU while a remaining 20% to 25% is marketed domestically. As a result, in the absence of stronger end-markets in Europe, international trade is vital to Europe’s textiles re-use and recycling industry. • Proper labelling Proper labelling of sustainable textiles and apparels is needed to empower consumers’ choices and inform about the products. • Funding opportunities EuRIC calls for funding opportunities in research and development for the various stages of textiles’ re-use and recycling and in projects fostering partnerships across the value chain to enhance textiles’ circularity. For further information, please have a look at EuRIC’s position paper calling for an ambitious Strategy on Textiles: https://www.euric-aisbl.eu/position-papers/item/329-euric-calls-for-an-ambitious-strategy-on-textiles or contact euric@euric-aisbl.eu
Read full response

Response to Environmental impact of mobile phones and tablets - Energy Labelling

27 Jan 2021

Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European Recycling Industries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for the Period 2019 -2024”, 80% of products’ environmental impact are determined at a design stage. Although the above-mentioned fact is also stated in the Circular Economy Action Plan 2.0 (CEAP), the vast majority of products placed on the EU market – and not only – are still designed without any consideration for their end-of-life stage. Design for circularity is therefore of an outmost importance to move towards a more circular economy and needs to be extended to all products’ categories, including mobile phones and tablets. EuRIC thus fully supports the necessary Designing Mobile Phones and Tablets to be Sustainable Legislative Initiative to keep the already exploited resources in the market for as long as possible by connecting the dots between the design and end-of-life (EoL) phase of products. Please find attached below the document containing EuRIC's reaction to the IIA of the Designing mobile phones and tablets to be sustainable initiative.
Read full response

Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

EuRIC strongly welcomes the recognition that the waste management and recycling sector “has a great potential to reduce greenhouse gas emissions in other sectors, particularly through the provision of secondary raw materials to replace virgin raw materials, through replacing fossil-based products, fertiliser and energy, (…)” and the adequate reflection of that fact, reflected in numerous LCA’s , in the “technical screening criteria for waste activities (…) [which] therefore recognise those activities as substantially contributing to climate change mitigation, provided that those activities implement certain best practices for that sector” (recital 20 of Commission delegated regulation supplementing Regulation (EU) 2020/852 of the European Parliament and of the Council by establishing the technical screening criteria for determining the conditions under which an economic activity qualifies as contributing substantially to climate change mitigation or climate change adaptation and for determining whether that economic activity causes no significant harm to any of the other environmental objectives, hereinafter referred to as the Delegated Act). EuRIC comments on specific points are further developed in the document attached.
Read full response

Response to Revision of EU legislation on end-of-life vehicles

19 Nov 2020

EuRIC strongly welcomes the Inception Impact Assessment on the revision of Directive 2000/53/EC on end-of-life vehicles (ELVD) and its main objectives to increase the contribution of the automotive sector to the circular economy and to ensure that the ELVD is adapted to the current and future challenges faced by this sector. As highlighted in the Final Report , 258 million passenger cars were registered in the EU in 2016 out of which 11.21 million light commercial vehicles (category M1) and passenger cars (category N1) were deregistered in 2017. Of these, 6.57 million were reported as ELVs and 0.87 million were reported as exports of used cars to non-EU countries which leaves the whereabouts of 3.77 million vehicles unknown. This makes end-of-life vehicles (ELVs) an important waste stream in terms of generated volumes but also growth rates, embedded valuable materials and illegal flows intra- as well as extra-EU. Consequently, the proper management of ELVs in accordance with the ELVD is of paramount importance to tackle those issues and move towards a circular economy as defined in the European Green Deal and the Circular Economy Action Plan (CEAP). To strengthen circularity in the ELV sector, EuRIC calls for: 1. Improvement of de-registration requirements for vehicles In order to tackle the problem of “missing vehicles” more effectively, EuRIC strongly calls for substantially improving and harmonizing the current de-registration process. Additionally, temporary de-registrations also require attention. For instance, a temporary de-registration should also be accompanied by information about the fate of the vehicle to prevent abuse. 2. Financial incentives to deliver a vehicle to an ATF in exchange for a CoD It is absolutely vital for the ELV recycling sector to ensure that the certificate of destruction (CoD) is properly enforced – incentives play a key role in that respect. Therefore, EuRIC strongly suggests to consider an incentive system based on an insurance premium as being done in the Czech Republic: if the car is not validly de-registered, the insurance cannot be terminated and a penalty has to be imposed. 3. Increasing the responsibility of car manufactures Should an approach based on extended producer responsibility (EPR) be chosen to increase the responsibility of car manufacturers in the end of life stages of a vehicle, EuRIC strongly advocates for the fact that recyclers should be involved in the governance of such a scheme. As laid down in the Final Report, the costs stemming from the ELVD are mainly beared up by Authorized Treatment Facilities (ATFs) (88.2%), and only to 11.4% and 0.4% by the car industry and the Member States respectively. Hence, the participation of recyclers in the governance of EPR schemes will ensure that the costs for ELV treatment are better distributed along the value chain and that recyclers will not have to carry the lion share. 4. Tackling illegal online sales of valuable spare parts from ELVs When spare parts are sold illegally online (scavenging or from depollution made by non-ATFs), it negatively affects compliant ATFs (shredder and car dismantlers) by depriving them from valuable spare parts. It is hence absolutely crucial to oblige e-commerce platforms to require that sellers are ATFs or that the spare parts originate from an ATF by providing a valid ATF registration number and contact details. 5. Setting up requirements for mandatory recycled plastics in new cars EuRIC supports gradual and fully achievable recycled content targets for post-consumer thermoplastics in new cars to be set as follows: 25% by 2025; 30% by 2030 and 35% by 2035. More detailed information about this plea is available on EuRIC website. In addition, recycled content targets can be set for other materials. From a broader perspective, improving the design of cars to improve the re-usability and recyclability is key. For further information, please contact euric@euric-aisbl.eu
Read full response

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

7 Aug 2020

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of an Inception Impact Assessment for the revision of the applicable concentration limit values of persistent organic pollutants (POP) in waste. The necessary phase out of POPs, and the associated review of limit values, is rightfully backed here by an ongoing study taking into account socio-economic parameters. In particular regarding polybrominated diphenyl ethers (PBDEs), EuRIC underlines that considering the impacts of lower POP contents options on the recycling industry, and therefore on the whole society, these concentration limit values should not go below existing thresholds. For the last 20 years, the recycling industry has been developing efficient standardized processes to separate legacy brominated flame retardants – BFRs- from plastics at a 1000-ppm level, eliminating POP-PBDEs from plastics. While restricted BFRs were sometime used in large amounts, up to 237 000 ppm of decaBDE in old TVs and computer monitors, recent evaluations showed concentrations of decaBDE in recycled plastics well below regulatory levels. Moreover, as the manufacturing industry phases out BFRs, their concentration in waste is going down with several years of delay (depending on the product lifetime). The recycling industry is therefore able to manage a gradual elimination of POP-PBDEs. However, too frequent changes in applicable limits can deter the recycling of PBDE-containing plastics as recyclers need legal certainty to invest in depollution processes amortized over several years, especially in an industry sensitive to the frequent downturns of raw material prices. The threshold levels of PBDEs in waste should also consider the applicability by the industry. While recyclers could comply with a 500-ppm UTC (Unintended Trace Contaminants) threshold for recycled granules sold as articles, it is very difficult to comply with less than 1000 ppm threshold for waste plastic flakes. Currently, screening methodologies for bromine (EN 62321-3-1), standardizing PBDEs detection at industrial scale, do not go below 1000-ppm. Similarly, sampling to check compliance of plastic flakes against a 1000-ppm low POP content is also standardized (EN 50625) and allow to discriminate brominated and non-brominated fractions. Lower thresholds would likely make BFRs- containing plastic recycling non feasible. Therefore, the environmental impacts detailed in the Inception Impact Assessment are accurate as a lower POP threshold for PBDEs could harm the circular economy, and result in a “ Loss of raw materials that have to be substituted by primary material”, a negative climate impact associated with incineration and primary raw material use, and a “potential increase in environmental emissions of hazardous substances associated with waste disposal (e.g. via incineration or landfill)”. In that regard, a proper risk-based approach is needed to assess the effects of a lower threshold on the circular economy, and on the attainment of the WEEE directive(2012/19/EC) and ELV directive (2006/53/EC) recycling targets. Regarding the economic impact, EuRIC would like to stress that the economic cost of having less material sent for recycling and more to other costly disposal routes, inter alia hazardous waste incineration, would ultimately be borne by society, via extended producer responsibility schemes. It is very important that this review of Low POP content thresholds consider the impact it could have on a functioning circular economy, in order to strike “the right balance between promoting circular flows of the materials concerned and ensuring a high level of protection of human health and the environment”. In the case of decaBDE, lowering thresholds under the current limit value for PBDEs puts the circular economy at risk.
Read full response

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

23 Jul 2020

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the Inception Impact Assessment on the review of the requirements for packaging and other measures to prevent packaging waste and fully supports the initiative’s aim to tackle the limited competitiveness of secondary materials from recycled packaging relative to virgin feedstock. The review should also ensure to include measures to amend the essential requirements to improve design for reuse and promote high quality recycling, as well as additional measures to reduce packaging waste generation. Therefore, the following key factors should be incorporated as essential requirements for packaging products placed on the market to improve their design: 1) Suitability for automated sorting: It is important to enable a simple separation of individual component parts during the sorting process as well as being compatible with automated material recognition. For example, the size of plastic sleeves and labels used on plastic bottles should be small enough to allow for proper NIR recognition of the bottle itself. 2) Suitability for high quality material recycling: To achieve high quality recycling, several steps need to be taken such as the fact that only minimal additives and colors should be used in the primary polymer item as well as having methods that enable good messaging to consumers, but also protect and provide a ‘careful stewardship’ of the core plastic material. For example, clear plastic yoghurt pots with strippable cardboard wrap-around. Additionally, packaging which are free of hazardous substances should be rewarded since it is instrumental that hazardous substances rendering recycling more difficult should be phased out at design stage. 3) Cross-cutting criteria: A sufficient degree of harmonization across Member States is needed to ensure that pan-European branded items are ‘scored recyclable’ in a similar manner within the whole EU. Additionally, effective waste treatment operations which are coherent with the circular economy should be prioritized. 4) Recycled content: Pulling the demand for recycled plastics in packaging is instrumental to provide the certainty operators need to invest throughout the packaging value chain to increase its circularity. Additionally, it is important to reward the well-documented environmental benefits of packaging recycling. For example in terms of GHG and energy savings that the market fails to reward and which severely impact the economic viability of European recyclers when virgin material prices are low, as currently the case with virgin polymers due to the collapse of crude oil prices.
Read full response

Response to EU rules on transboundary waste shipments – update concerning plastic wastes

22 Jul 2020

The European Recycling Industries’ Confederation (EuRIC) is pleased to submit comments on the draft delegated act implementing the Basel plastic entries into the Waste Shipment Regulation (WSR). EuRIC agrees with and supports the overall rationale of the draft delegated act: • On the one hand, to ship non-green listed plastic wastes under to the procedure of prior written notification and consent to countries outside the European Union and ban the export of certain plastic wastes to third countries, in accordance with the amended Basel Convention; • On the other hand, to maintain a largely similar legal regime for waste shipments within the EU, allowing for the sharing of recycling infrastructures across the EU and the maximization of recycling opportunities. Regarding shipments within the EU, EuRIC calls attention to the classification of WEEE and ELV plastic waste. EuRIC strongly believes that WEEE and ELV plastic waste should remain green-listed for shipments within the EU, to foster a strong domestic recycling industry for these complex plastics and increase their circularity. EuRIC appreciates that under the new legal regime, some clean mixed plastics – as specified in Annex IIIA – will remain green-listed. However, under the current wording of the draft delegated act, mixed WEEE or ELV plastics, which consist to a large part of ABS, PS, PP and PE but also PVC, would not fall under this category. In order to keep WEEE and ELV plastics green-listed for shipments within the EU, EuRIC suggests the following modification of item (3) of the draft delegated act regarding Annex IIIA: include "or listed as polymers of vinyl chloride" at the end of Annex IIIA No. 4(a). Additionally, EuRIC would like to stress that those WEEE and ELV plastics should under no circumstances be classified as hazardous wastes for shipments within the EU according to AC300. A classification as hazardous waste would simply phase out the recycling of WEEE and ELV plastics in Europe, which must under all circumstances be avoided in order to maintain a circular economy for those types of plastics within the EU and safeguard European companies which have globally pioneered the process to recycle complex plastics from these streams. It should be noted that WEEE and ELV plastics recycling companies in Europe which, in an environmentally sound way, produce high-quality plastic recyclates from these streams are not permitted to take hazardous wastes. EuRIC therefore calls for WEEE and ELV mixed plastics to be classified for shipments within the EU: • Either as a green-listed waste under Annex IIIA authorized mixtures; • Or as non-hazardous notifiable plastic waste under EU48. This proposal should be seen under the premise that the notification procedure as laid down in the WSR will be simplified and the concept of pre-consented facilities will become the norm rather than an exception. This be a step towards the much-needed facilitation of notifiable shipments of wastes within the EU. Additionally, there is a strong need for a harmonized and objective interpretation and implementation of “almost free of contamination and other types of waste” as laid down in entries EU3011 as well as B3011. Without a harmonized definition, it would be too risky to ship plastic wastes from one country to another since different interpretations will inevitably lead to different enforcement systems. This could go as far as to make a shipment illegal when crossing borders. To give an indication what “almost free from contamination” means, EuRIC has already drafted specifications for packaging and general plastics (see in attached document) and is in the process of drafting specifications for technical plastics. The specifications’ purpose is to propose an objective, measurable definition of the new EU3011 as well as B3011 entries, valid for shipments within the EU and to non-EU countries.
Read full response

Meeting with Frans Timmermans (Executive Vice-President)

23 Jun 2020 · European Green Deal, circular economy and waste management

Response to Chemicals strategy for sustainability

20 Jun 2020

The European Recycling Industries’ Confederation (EuRIC) welcomes the publication of the roadmap on the Chemical Strategy for Sustainability. EuRIC's feedback to the roadmap is enclosed.
Read full response

Response to EU rules on industrial emissions - revision

21 Apr 2020

The European Recycling Industries’ Confederation – EuRIC - welcomes the publication of an Inception Impact Assessment (IIA) within the framework of the revision of the Industrial Emission Directive. Looking at the different objectives and policy options detailed in it, EuRIC wishes to make the following comments. - BREF Process EuRIC agrees that options to improve the BREF elaboration process have to be explored. The Sevilla process has to be improved in many aspects, among others in terms of representativity, transparency and efficiency. Indeed, data collected, selected and processed throughout the process can lack representativity. The comparability of data from different sources has also to be carefully assessed. Furthermore, the processing of data shared by stakeholders lacks transparency as it has been experienced during the revision of the Waste Treatment BREF. Besides, the background of the stakeholders taking part to the process, as well as the interests they represent, should be clear to every participant. Last but not least, the process remains very time-consuming, and should be improved in that regard. - Contribution to the circular economy and Interaction with decarbonisation of industry Provided that the potential benefits of including circular economy aspects in the scope of the IED are well defined and assessed, EuRIC would also fully support the contribution of IED requirements to stimulate the circular economy. This should be achieved by incentivizing the use of secondary raw materials in industrial processes to substitute, whenever technically feasible primary materials, and save GHG emissions. EuRIC favors a strong European industry that increasingly relies on secondary materials which not only save primary resources (imported for a significant share of them) but also GHG emissions. Several LCA studies showed the significant energy and GHG emissions avoided by the recycling of materials produced in some industrial processes covered by the IED, such as plastics, ferrous and non-ferrous metals, etc. (ADEME, 2017). As an example, the avoided emissions related to the use of ferrous scrap in steel making in 2018 in the EU are roughly equivalent to the greenhouse gas emissions of automobile traffic in France, the United Kingdom and Belgium combined (Fraunhofer IMWS, 2019).   However, EuRIC wishes to underline that the high costs entailed by the adoption of BAT-associated emissions level are not reflected in the wording of the Inception Impact Assessment, especially in the assertion that “Assessments carried out so far show that costs for compliance with the requirements of the IED and BAT conclusions are relatively small”. The implementation of technologies compliant with stricter BAT-AELs after the BREF process hints that those could not have been implemented before at no cost. Besides, to support such a statement, data showing small compliance costs should be made available. Besides, the IIA specifies that installation below the currently applicable thresholds could be included in the IED scope. In our view, and in the light of the economic costs incurred by IED in existing sectors, this scope extension should undergo a thorough socio-economic impact assessment. Sources: ADEME, FEDEREC (2017) Évaluation environnementale du recyclage en France selon la méthodologie de l'analyse de cycle de vie, Rapport final, 178 p. Fraunhofer IMWS (2019) Schrottbonus, Externe Kosten und fairer Wettbewerb in den globalen Wertschöpfungsketten der Stahlherstellung, Fraunhofer-Institut für Mikrostruktur von Werkstoffen und Systemen IMWS, Center for Economics of Materials CEM in Halle (Saale), 52 p.
Read full response

Response to A new Circular Economy Action Plan

20 Jan 2020

EuRIC welcomes the Commission’s renewed ambition to put the Circular Economy (CE) and Climate policy on top of its strategic priorities. Recycling is a job-intensive, resource and climate efficient industry. As highlighted in the Green Deal, “Only 12% of the materials it uses come from recycling”. Since low-hanging fruits have already been picked, it is essential to develop a much-needed EU market for secondary raw materials (SRM) and drastically change policy and regulatory drivers applicable to recycling activities and downstream value chains through: 1. Simpler waste legislation adapted to circular material flows - Simpler and faster waste shipment procedures suited to the business pace of circularity to improve traceability, protect business confidentiality and avoid diverging interpretations among MS; - Harmonized EU end-of-waste (EoW) criteria in particular for recovered paper, for prepared for re-use textiles or tyre-derived rubber materials and mutual recognition of national EoW criteria meeting EU standards by all MS; - Work towards the creation of a new status of “secondary raw materials” in the waste legislation for processed waste meeting industry specifications or quality standards; - Improve the interface between waste & chemicals legislation, which represents a major obstacle to the CE, thanks to a balanced risk-based approach and by phasing out SVHCs at design stage to prevent legacy issues. Information for treatment operators has to be suited to recycling operations. Such information has to be made available on a stream by stream basis and be based on physical or digital channels suited to the needs of each value chain (QR-codes, labelling, etc.) instead of developing the SCIF database little suited to recyclers’ needs so far; - Enforce competition law principles in waste management and recycling to forbid reserved waste markets and cross-subsidization as well as ensure that SRM meeting industry specifications benefit from free and fair trade; - Pragmatic approach to residual waste treatment capacities to ensure adequate capacity needs in the EU for the treatment through waste-to-energy of residual waste with high calorific value from recycling activities and for the mineral fractions through final disposal. 2. Incentives to reward recycling environmental benefits Recycling is key to decarbonize energy-intensive industries. Yet, commodity markets fail to reward recycling environmental benefits in terms of GHG emissions and energy savings. Hence, EuRIC calls for: - Market-based instruments and fiscal based-instruments (reduced VAT) rewarding the use of recycled materials in value chains (metals, papers, plastics, textiles, tyres, etc.); - Mandatory green public procurement (GPP) requirements rewarding circular products using recycled materials and easier to re-use / recycle at end-of-life (EoL) stage; - Binding recycled content targets for streams such as plastics in automotive or electronics, tyres or textiles. 3. Boost products' circular design Eco-design for reuse and recycling is essential to a CE. For instance, the sharp increase of lithium-ion batteries in cheap products causes fires when they reach EoL stage during transport, storage and handling, posing a risk for human health and the environment and damaging recycling facilities. A number of additives found in plastics, sealants in tires or gluing techniques used in electronics render in some instances these products unrecyclable despite the valuable materials they contain. Hence, EuRIC calls for: - Extending eco-design requirements to all product categories and setting minimum requirements to improve products’ recyclability and recycled content on a product by product category; - Systematically linking EoL treatment requirements with product design requirements to bridge the gap between both stages; - Reward mechanisms such as eco-modulation of fees in EPR; - Eco-labelling to empower consumers’ sustainable choices.
Read full response

Response to Commission Regulation amending the CLP Regulation (EC) 1272/2008 and correcting Commission Regulation (EU) 2018/669

8 Feb 2019

The European Recycling Industries’ Confederation – EuRIC AISBL – is an umbrella organization for the recycling industries in Europe. Through its Member Recycling Federations from 20 EU and EFTA countries, EuRIC represents over 5,500 companies, both large companies and SMEs, involved in the recycling and trade of various resource streams; EuRIC welcomes the public consultation on the draft 10th ATP regulation, and wishes to express the following points: EuRIC supports the current classification of Cobalt as carcinogenic 1B, since Co is considered as such by the industry since 2014. We stress the fact that Cobalt is referred as a Carcinogenic of class 1A in recital 4) of draft ATP, which in our sense must be an editorial mistake to be corrected; EuRIC supports The proposal mentioned in recital 4) of the draft ATP to conduct further research on the methodology to assess the carcinogenicity of Cobalt, so as to derive a sound specific concentration limit of Cobalt in alloys. The “T25” methodology, used to assess the carcinogenic potency of a substance, has to be thoroughly reviewed by an expert group. Indeed, rushing to establish a threshold level could have a massive and unjustified impact on the entire EU steel chain, including steel scrap recycling industry and steel manufacturing industry using scrap as an in-feed material. Therefore, EuRIC is concerned by routes of exposure taken into account: cobalt is an industrial chemical and poses a risk mostly under its powder form in the workplaces, where exposure to Co is already controlled. The notation based on all routes of exposure (oral, dermal, inhalation) could lead to a negative perception by the public of alloys containing Cobalt, even though the use of these alloys in everyday life items is safe. EuRIC welcomes the Generic Concentration Limit – GCL - of 0,1% proposed in draft ATP, which is a better option than the previously envisioned Specific Concentration Limit – SCL - of 0,01%. The proposed GCL limits the risk to consider scraps containing Co as an impurity as carcinogenic. However, some applications still contain cobalt above the concentration level of the proposed GCL: - Stainless steel, which contains an average of 0,7 % of Co. It is estimated that between 70% and 92% of end-of-life stainless steel is currently recycled in the EU. A specific concentration limit of 0,1% of Co could lead steel producers to limit the input of steel scrap containing cobalt in their furnaces, reducing the production of steel from steel scrap in Europe; - Key industrial applications, in which Co is intentionally present for its properties (catalytic, wear-resistance, temperature-variation resistance and permanent magnetism…), some of those being strategic for the immediate future, e.g. batteries. It is worth noting that Cobalt is one of the critical raw material according to the European Commission. Thus it is necessary to take into account bioavailability in the current draft ATP, to accurately assess the effect on Cobalt application by taking into account the matrix in which Co is encapsulated.
Read full response

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and FEDEREC - Federation des Entreprises du Recyclage

7 Feb 2019 · Waste Directive

Meeting with Rolf Carsten Bermig (Cabinet of Commissioner Elżbieta Bieńkowska)

21 Jan 2019 · _Circular Economy_Interface between waste, products and chemicals legislation

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

21 Jan 2019 · discussion on interface between chemical, product and waste legislation

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

21 Jan 2019 · Interface between waste, products and chemicals

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and Fédération Nationale des Activités de Dépollution et de l'Environnement

11 Dec 2018 · Single Use Plastics

Response to Evaluation of the Industrial Emissions Directive

30 Nov 2018

EuRIC, the European Recycling Industries’ Confederation, welcomes this Roadmap and the forthcoming review of the Industrial Emissions Directive. As the specific BREF for our industrial sector was recently reviewed (Waste Treatment BREF), we have detailed feedback to provide on the monitoring and reporting of emissions, on the way data is collected and processed to derive the Best Available Techniques Associated Emissions Limits (BAT-AELs), and more generally on the process of elaborating BREFs and BAT Conclusions. We therefore look forward to the public consultation, and to the more targeted consultations that will take place in 2019.
Read full response

Response to Review of ecodesign requirements for household washing machines and washer-driers

21 Nov 2018

Setting requirements for resource efficiency in Ecodesign Regulations is a crucial step forward to ensure a transition towards a more circular economy, and EuRIC strongly supports the inclusion of this type of requirements in Ecodesign Regulations. We noticed, in the case of household washing machines, a lower level of ambition for the resource efficiency requirements in the updated version of the draft Annex compared to the documents sent for Interservice consultation on 31.08.2018. Concerning in particular the “Requirements for dismantling for material recovery and recycling while avoiding pollution” the previous wording mentioned: “Household washing machines and household washer-dryers shall be designed so that the access to and the removal of the following components (when present) is possible without the use of any tool which is not readily available for purchase”. This wording mentioned the need to design the appliance to allow for access and removal of a list of components, and this -crucial- notion of ease of access and removal is not reflected in the new version of the text. Moreover, the new version of the text only mentions the “components referred to in Annex VII to Directive 2012/19/EU” when the previous text also mentioned other components (e.g. piping and related equipment including all hoses, valves and filters) for which design should allow for easier access and removal. EuRIC therefore strongly recommends to revert to the wording used in the version of the Annex that was sent for Interservice consultation on 31.08.2018. Additionally, in both versions of the text, we have noticed that the requirements focus on the possibility to remove a series of components “without the use of any tool which is not readily available for purchase.” This wording implies that the issue lies with the availability of the tool for purchase, when in fact the issue is the multiplication of the tools needed to disassemble different models when each brand uses different fastening techniques, thus considerably lengthening the dismantling time. We also recommend to avoid the term “readily”, which, as we already pointed out, has been identified as “lacking concreteness” in a report from the European Commission on “Regulatory barriers for the Circular Economy – Lessons from ten case studies”. We strongly suggest to revert to the previous wording (draft from 30.10.2017) mentioning “the access to and the extraction of the […] components (when present) must be possible without proprietary or not commonly available tools”.
Read full response

Response to Review of ecodesign requirements for household cold appliances

13 Nov 2018

EuRIC welcomes the increased ambition of the requirements concerning resource efficiency for household fridges, compared to the very first draft presented at the Ecodesign Consultation Forum in December 2017, although the level of ambition for this product category is lower compared to the proposals made for other product categories (e.g. dishwashers and washing machines). EuRIC strongly supports the added requirement to clearly label the appliances containing Vacuum Insulated Panels – this new requirement will enable recyclers to avoid the major disruption of the recycling processes caused by the appliances containing those panels. Compared to the previous drafts shared in July 2018, we noticed that the wording in Annex II. 3 was changed from “manufacturers shall ensure that refrigerating appliances are designed so that the components described in Annex VII of Directive 2012/19/EU can be removed with non-proprietary and commonly available tools “to “manufacturers shall ensure that refrigerating appliances are designed so that the components referred to in Annex VII of Directive 2012/19/EU can be removed without the use of any tool which is not readily available for purchase “. We strongly recommend to revert to the previous wording (from July 2018). The new wording implies that the issue lies with the availability of the tool for purchase, when in fact the issue is the multiplication of the tools needed to disassemble different models when each brand uses different fastening techniques, thus considerably lengthening the dismantling time. We also recommend to avoid the term “readily”, which, as we already pointed out, has been identified as “lacking concreteness” in a report from the European Commission on “Regulatory barriers for the Circular Economy – Lessons from ten case studies”.
Read full response

Response to Review of ecodesign requirements for household dishwashers

12 Nov 2018

Setting requirements for resource efficiency in Ecodesign Regulations is a crucial step forward to ensure a transition towards a more circular economy, and EuRIC strongly supports the inclusion of this type of requirements in Ecodesign Regulations. We noticed, in the case of dishwashers, a lower level of ambition for the “requirements for dismantling for material recovery and recycling while avoiding pollution” in the updated version of the draft Annex compared to the documents presented at the Ecodesign Consultation Forum in December 2018. We strongly suggest to revert to the previous wording mentioning “the access to and the extraction of the […] components” and the possibility to do so “without proprietary and not commonly available tools”. The current wording implies that the issue lies with the availability of the tool for purchase, when in fact the issue is the multiplication of the tools needed to disassemble different models when each brand uses different fastening techniques, thus considerably lengthening the dismantling time. We also recommend to avoid the term “readily”, which, as we already pointed out, as been identified as “lacking concreteness” in a report from the European Commission on “Regulatory barriers for the Circular Economy – Lessons from ten case studies”.
Read full response

Response to Ecodesign requirements for electronic displays and televisions

7 Nov 2018

EuRIC is the European Recycling Industries’ Confederations, representing National recycling federations active in 20 EU and EFTA Member States. Concerning the proposal for an Ecodesign Regulation on displays, EuRIC welcomes the requirements on material efficiency, and specifically the requirements set to promote design features of electronic displays that facilitate their dismantling and recycling at end-of-life. We however note that the use of halogenated flame retardants in plastics from displays causes major issues at the recycling stage. Plastics containing halogenated flame retardants, especially brominated substances, are separated from the rest of the plastics during the recycling process, and need to be disposed of, resulting in a net loss of material. Therefore, we welcome the text included in the Recital 18 of the draft Regulation. However, we noticed that in the Annex of the draft Regulation on displays that was shared by the European Commission on 31 August 2018 there was a clear requirement to ban the use of halogenated flame retardants in the stand and enclosure of electronic displays, which no longer appears in the text of the Annex of the Regulation upon which we are now providing comments. We therefore strongly recommend to amend the proposed text and include the previously proposed sentence indicating that “The use of halogenated flame retardants is not permitted in the enclosure and stand of electronic displays.”.
Read full response

Response to Legislation on end-of-life vehicles - evaluation

30 Oct 2018

The European Recycling Industries’ Confederation (EuRIC) strongly welcomes the publication of the Roadmap to evaluate the Directive 2000/53/EC on end-of-life vehicles (ELV Directive). As a reaction to this roadmap, representing one step ultimately leading to a review of the ELV Directive, EuRIC calls on the European Commission to seize this opportunity for (i) solving the issue with a large number of vehicles of unknown whereabouts in Europe and (ii) making dismantling and recycling of ELV easier by introducing binding eco-design measures. (i) 4 million vehicles of unknown whereabout per year in Europe: The ELV Directive should be used as a tool to solve the issue of missing ELVs in Europe. It is known from the European Commission’s studies that the number of vehicles of unknown whereabouts is about 4 million vehicles per year, compared to around 6 to 7 million ELVs treated in compliance with the ELV Directive. The reasons for missing vehicles might be numerous, such as illegal exports, statistical errors, misuse of the temporary deregistration of vehicles etc. The revision of the ELV Directive is the right opportunity to: - Introduce well-framed incentives for the last holder to deliver a vehicle to authorised treatment facilities and hence, strengthen the certificates of destruction (CoD); - Determine a clear & “easy to implement” distinction between used cars and ELVs, such as those recently introduced by Italy and based on passing a roadworthiness test; - Improve the exchange of information regarding the fate of temporary de-registered vehicles as well as regarding CoD issued in a different Member State; - Oblige the last owner e.g. to annually pay an administrative fee for his deregistered car until he can provide a CoD. Untreated ELVs are hazardous waste, which pose significant risk for the environment. The EU legislation sets out stringent rules for the operators of ELV treatment facilities to ensure compliance at the highest level of environmental protection. Recycling companies made considerable investments to comply with these rules, but the ELVs escape from the system. Setting out a total recovery rate of 95% (apart from the strict environmental rules) is just the first step. To complete the work, recycling industry urges the European Commission to adopt a legislation ensuring that ELVs find their way into authorised treatment facilities. (ii) Polluter pays principle is a pre-requisite for better recycling: The long lifetime of products in the vehicle market means that there is a long delay between the time when a vehicle was produced and the time, when the vehicle will reach its end-of-life. This can make ELVs recycling extremely costly. Hence, polluter pays principle must apply. Due to the long lifetime, the ‘disconnect’ between design & composition of today’s manufactured vehicles and the development of chemicals legislation regulating various substances at the end of their life is substantial. The ever-changing thresholds for an increasing amount of substances under REACH and POPs legislation form a considerable burden for the recycling industry and can endanger the achievement of the total recovery rate of 95%. Whilst the recycling industry is capable of reducing the legacy of substances to the greatest possible extent, it will not be able to eliminate all substances of concern completely. This must be recognized and supported, where necessary, also by introduction of reasonable exemptions for recycling. In addition, binding eco-design measures will ensure that the design stage starts in a proper way, instead of correcting mistakes at the end-of-life stage. Last but not least, post-consumer recycled content would considerably foster the demand for recycled plastics from ELVs in order to convert the linear supply chain to a circular material flow model.
Read full response

Response to Environmental impact of enterprise servers and data storage products

31 Jul 2018

EuRIC welcomes the inclusion of material efficiency requirements in the Annexes of the Regulation for this lot (servers and data storage products). Concerning the material efficiency requirements in Annex II, Section 1.2 : As previously expressed, we support this requirement to ensure that disassembly is not prevent by the fastening techniques. The previous wording, specifically mentioning gluing and welding, was more precisely pointing out to the fastening techniques that are problematic for recyclers and should have been preferred. We also previously mentioned (see our position paper from March 2017 attached) the need to add a provision to make the motherboard, and especially the button cell battery accessible from the outside of the appliance (or at least more accessible) possibly in a similar way as a SIM card in a mobile phone. Recyclers currently need to open each device to retrieve this battery (requirement from the WEEE Directive), an operation which is long and burdensome. Once more, we insist on setting requirements on the design of the appliances mirroring the depollution obligations of the Annex VII of the WEEE Directive (2012/19/EU) Concerning the material efficiency requirements in Annex II, Section 3.3: We welcome the new wording for the information requirement on critical raw materials. The weight range, at component level, is sufficient for the forecasted use that information will have, which is to allow recyclers to anticipate the volumes of such materials in the equipment reaching end-of-life, hence promoting the development of processes to separate these materials once profitable to do so. The precision of the component where the CRMs are located (Cobalt in batteries and Neodymium in HDDs) is also useful as it will help to target the components of interest. We are however questioning the deletion of the requirement on Palladium in the new text.
Read full response

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella)

1 Jun 2017 · Circular Economy

Response to Monitoring Framework for the Circular Economy

3 May 2017

The European Recycling Industries’ Confederation (EuRIC) welcomes the opportunity to comment on the EU initiative “Monitoring Framework for the Circular Economy”. Assessing progress and better understanding are important elements to realise the transition towards a Circular Economy that EuRIC entirely supports. This monitoring framework should focus on true indicators that can objectively assess the progress and avoid any distractions towards monitoring areas very weakly or not related to achieving this transition. EuRIC calls on the European Commission to seize this opportunity to create a monitoring tool which is able to identify the number of shortcomings hindering the transition to a Circular Economy. When developing a monitoring framework, it is important to ensure that it will not result in more administrative burdens for the recycling industry which have already to comply with a lot of reporting obligations, linked for example to recycling targets. The roadmap introduces areas to be subjects of monitoring: “…such as food waste, security of supply for key raw materials, repair and reuse, waste generation, waste management, trade in secondary raw materials in the EU and with non-EU countries, and the use of recycled materials in products.” While the majority of the aforementioned areas are reasonable, it is questionable as to what extend several of the other areas will provide an added value when analysing the progress achieved. The most questionable is the purpose or objective of monitoring the trade in secondary raw materials with non-EU countries. It is indeed true that free and fair trade is instrumental for recyclers because raw materials from recycling are priced and traded globally. The recycling industry is heavily dependent on the well-functioning of the internal and international markets. In particular, since for a number of material streams, such as paper or ferrous metals, the supply of raw materials from recycling structurally exceeds the demand. Moreover, monitoring the imports of primary materials from third countries to Europe, with which raw materials from recycling compete, would be significantly more beneficial to determine whether the manufacturing industry sources its raw materials from virgin sources or from recycling. EuRIC strongly supports monitoring of the use of recycled materials in products as one of the key indicators. It will help to understand whether the EU circular economy package delivers the desired results in practice. Measuring whether the industry uses more recycled materials to manufacture new products on a systematic basis will show how well the loop is being closed. This will contribute to increasing the demand for secondary raw materials, which is one of the objectives identified in the Action Plan for a Circular Economy , acknowledging that “At present, secondary raw materials still account for a small proportion of the materials used in the EU”. Closely connected with this topic, to be included in the monitoring, is the objective of identifying and tackling regulatory distortions stemming from EU legislation which hinder the Circular Economy. To illustrate this, the study on cumulative cost assessment for the steel industry has clearly demonstrated that there is a higher cost burden on downstream users of secondary raw materials. In other words, the cost of EU regulation is much higher for electric arc furnaces using recycled steel scrap (17,41€/t) than for basic oxygen furnaces using mainly primary raw materials (10,66€/t). This despite the huge benefits which using recycled steel scrap brings to the society in terms of energy and CO2 savings. A monitoring framework shall enable to identify and tackle regulatory burdens, such as the above-mentioned example, and ensure that there are adequately addressed. This will guarantee that legislation – regardless of its policy area – fully supports the transition towards a circular economy.
Read full response

Response to Commission Regulation amending Annex III to Directive 2008/98/EC

17 Aug 2016

The European Recycling Industries’ Confederation (EuRIC) is highly concerned that the proposed Commission Regulation amending Annex III to Directive 2008/98/EC as regards the hazardous property HP 14 (ʻEcotoxic’), based on the outcome of “Study to assess the impacts of different classification approaches for hazard property "HP 14" preferring the calculation method 1 for classification purposes, will adversely impact recycling. An approach relying on chemical analysis, as it is the case with method 1, is technically unfit for characterisation of complex solid waste streams, such as fluff-light fraction and dust from shredding of metal containing waste 19 10 03*/19 10 04. The chemical analysis is suited for assessing homogeneous substances and well-defined mixtures commonly found in virgin materials but absolutely not adapted to the characterisation of solid waste which by nature is heterogeneous and complex. Sampling solid waste coupled a chemical lixiviation of the sample to obtain a homogeneous liquid and exhibit its chemical properties would provide only a very poor indication of the hazardous properties of the waste sample analysed: It would neither be representative of complex materials found in solid waste nor would it be indicative of the bioavailability of hazardous substances. However, EuRIC welcomes the introduction of generic cut-off values even if it does not address the limits of relying on a method using a chemical analysis. The Study, used as a basis for the draft Commission Regulation, is based on an extremely limited dataset not allowing to draw conclusions relying on solid scientific evidence. Out of only 11 samples assessed for the pair 19 10 03*/19 10 04, 10 already had a baseline classification as hazardous and only 1 had a baseline classification as non-hazardous (while the majority of Member States currently classify this waste stream as non-hazardous), which makes it easy to assert that the consequences of a reclassification would be minor. The Study explicitly acknowledges “the lack of availability of characterisation data from chemical analysis” in general (p.91, sec. 5.4.1, 1. par.) and the lack of data for fluff and dust from metal shredding (p.15, above the table and p.126, sec. 6.4.5, last par.). Socio-economic impacts resulting from a probable reclassification of fluff-light fraction and dust from metal shredding from currently non-hazardous to hazardous, on the basis of an unfit method, would seriously disrupt if not render impossible recycling of streams reaching high recycling targets and force facilities to temporary or definitively cease operation for no environmental benefits, as they are permitted to receive non-hazardous waste. Applying the method 1 for classification of fluff-light fraction and dust would from a scientific viewpoint be irrational. Given the limitations of the chemical analysis approach, it would be justified to develop a harmonised method which is scientifically fit for purpose of assessing the ecotoxicity of complex solid waste streams instead of relying on a preferred method 1 which is inadequate for assessing HP 14 for complex streams. As long as such a method is not developed, complex solid waste streams such as fluff-light fractions and dust must be exempted from any method based on chemical analysis for assessing HP 14 and regulatory changes to incorporate such a method in the legislation. EuRIC urges the European Commission and the Technical Adaptation Committee to refrain from approving any proposal relying on chemical analysis for the assessment of the ecotoxic property of waste HP 14 applicable to fluff-light fraction and dust until a proper harmonized method fit for the purpose of characterising complex solid waste streams is set up. This response was prepared by EuRIC under a very short period of time given the time and short period left to stakeholders to react to this consultation.
Read full response

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella), Heidi Jern (Cabinet of Vice-President Jyrki Katainen)

25 Feb 2015 · Circular Economy

Meeting with Sarah Nelen (Cabinet of First Vice-President Frans Timmermans)

25 Feb 2015 · Circular Economy

Meeting with Telmo Baltazar (Cabinet of President Jean-Claude Juncker) and European Ferrous Recovery & Recycling Federation and European Metal Trade & Recycling Federation

23 Jan 2015 · Circular Economy