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European Solvent Recycler Group

ESRG

Lobbying of Solvent Recycling Business within in EU-Legislation - in particular in the scope EU Circular Economy and Waste legislation and appropriate national legislations.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

Detailed ESRG-Response = attached Only Summary / ESRG Proposal: In support of this sector to establish: 1. Mechanisms to see the waste hierarchy is better used, justified and enforced. 2. Harmonized end-of-waste criteria at EU level, like existing solutions, based on a study led by the Joint Research Centre, with contributions from the ESRG supporting the three mentioned elements
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

21 Feb 2022

The Europaen Solvent Recycler Group - ESRG - fully supports the waste hierarchy but our experience is that waste generators and producers tend to make their waste management decisions on the cost of treating waste rather than any holistic environmental benefit. This suggests the waste hierarchy is not working efficiently. That position is further not helped in that in respect of post treatment of waste and issues of when a waste ceases to be a waste, i.e. End of Waste, Member State decisions are often not applied in a consistent or transparent manner creating a burden of administrative cost and market distortions'. To correct that situation the Commission might plan to see better hierarchy enforcement procedures, and in respect of End of Waste, either centrally take on the role of agreeing End Of Waste positions, or, create an open register of comparative standards adopted by the individual Member States.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

The Euroepan Solvent Recycler Group - ESRG - are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated Guidance offered to Member States in respect of managing standards for full recoveries derived from wastes and the use of exemptions to support both REACH and in turn CLP. B. Freitag ESRG-Secretariat
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

The European Solvent Recycler Gourp - ESRG - are supportive of the main aims of the proposals. In respect of the Circular Economy, ESRG would like to see updated Guidance offered to Member States in respect of managing standards for full recoveries derived from wastes and the use of exemptions to support both REACH and in turn CLP.
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