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European Union for Responsible Incineration and Treatment of Special Waste

Eurits

Eurits represents more than 90% of the EU's specialist hazardous waste incineration sector, and exists to ensure safe, legal and environmentally sound incineration of hazardous waste (HW).

Lobbying Activity

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

20 Nov 2025 · Meeting on PFAS in Waste

Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

8 Jul 2025

Eurits fully supports the European Commissions climate objectives, including the goal of climate neutrality by 2050, and recognises the EU Emissions Trading System (ETS) as a key instrument for decarbonisation. We also welcome the approach and timeline set out in the most recent ETS revision, which struck a careful balance between ambition and sectoral feasibility. In this context, we urge the Commission not to include Hazardous Waste Incineration (HWI) in the next revision of the ETS. HWI plays a critical role in the circular economy by ensuring the safe and complete destruction of non-recyclable hazardous waste for which no alternative treatment exists, such as substances of concern, persistent organic pollutants (POPs), CFCs, and heavy metal-containing organic waste. This service is essential for the continued, compliant operation of many industrial sectors across Europe. The unique and enabling role of HWI is already recognised in the EU Taxonomy, which classifies hazardous waste incineration as an environmentally sustainable activity a distinction not extended to non-hazardous waste incineration. Hazardous waste incineration should not be included in the EU Emissions Trading System (ETS), and our reasoning is detailed fully in the attached position paper.
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Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall)

16 May 2025 · Circular Economy and Waste Shipment Regulation

Response to Targeted amendment of the European List of Waste as regards waste batteries and wastes from their treatment

8 Nov 2024

Eurits supports the Commissions ongoing actions to improve and revise the European List of Waste (LoW) to reflect advancements in waste treatment processes. However, we believe the proposed amendments represent a missed opportunity to better align Regulation (EU) 2019/1021 on Persistent Organic Pollutants (POPs) with Directive 2008/98/EC on waste and to update the LoW for improved identification, monitoring, and traceability of POP waste. The European List of Waste currently lacks a generic entry for POP waste, meaning that for each new POP added to the POPs Regulation, the LoW must be revised to accurately classify the new waste stream (even if it is only a limited revision). Eurits would therefore propose the following amendment: EU List of Waste (EU) 2019/1021 2. Classification of waste as hazardous: Remove: Wastes containing polychlorinated dibenzo-p-dioxins and dibenzofurans (PCDD/PCDF), DDT (1,1,1-trichloro-2,2- bis (4-chlorophenyl)ethane), chlordane, hexachlorocyclohexanes (including lindane), dieldrin, endrin, heptachlor, hexaclorobenzene, chlordecone, aldrine, pentachlorobenzene, mirex, toxaphene hexabromobiphenyl and/or PCB exceeding the concentration limits indicated in Annex IV to Regulation (EC) No 850/2004 of the European Parliament and of the Council (1) shall be classified as hazardous. Replace with: 'POPs waste' We believe that this amendment would significantly enhance the traceability and regulation of POP waste within the EU waste management framework.
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Response to Initiative on EU taxonomy - environmental objective

3 May 2023

Eurits [the European Union for the Responsible Incineration & Treatment of Special Waste] supports the Commissions work within the EU Taxonomy Delegated Acts and would like to draw your attention to a number of points within Annex III - please see our feedback attached.
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Meeting with Virginijus Sinkevičius (Commissioner) and

11 Apr 2023 · To discuss the role of hazardous waste management in the context of the Circular Economy

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

30 Nov 2022 · Waste Shipment Regulation

Response to EU rules on industrial emissions - revision

23 Jun 2022

Please see our position paper as attached. Our main concerns surround: definitions; setting of permit levels; measurement uncertainty and indirect releases.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

22 Feb 2022

Eurits [the European Union for the Responsible Incineration and Treatment of Special waste] is an association of hazardous waste management companies all of whom operate dedicated high-temperature incinerators for the treatment of hazardous waste as well as a wide variety of recycling and recovery facilities for both hazardous and non-hazardous wastes. Eurits welcomes the European Commission’s initiative to revise the Waste Framework Directive (WFD), particularly as the aims of the initiative align with the European Green Deal and Circular Economy‘s commitments to: • ‘Ensure cleaner secondary materials for businesses’ • ‘Promote safer and cleaner waste streams and ensure high-quality recycling’. The Commission’s proposed revision focuses on municipal waste but misses the opportunities to deal with remaining concerns relating to hazardous waste, specifically around ensuring effective decontamination, preventing dilution/mixing, waste classification and producer responsibility. Several issues were identified in two studies carried out on behalf of DG Environment in 2015 and 2018 regarding: a lack of traceability in terms of accurate data on hazardous waste arisings vs treatment; the importance of classification; and the promotion of the use of shared producer responsibility (instead of delegated producer responsibility) so that waste producers maintain some responsibility for the final treatment of their waste. Please find attached detailed comments.
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Response to Update of concentration limit values of persistent organic pollutants in waste

22 Dec 2021

Eurits [the European Union for the Responsible Incineration and Treatment of Special waste] welcomes the publication of the Commission’s proposed regulation on Persistent Organic Pollutants (POPs) which contains, in Annex IV and V, updated concentration limit values of POPs in waste. Please find attached Eurits' detailed comments. Eurits supports the Commission’s effort to lower the concentration limit values of POPs as a means to achieving the European Green Deal and specifically to contribute to a non-toxic environment. Dealing with POPs effectively is of the utmost importance for the protection of human health and the environment and Eurits’ members play a vital role in this process. Eurits is an association of hazardous waste management companies across the EU. Its membership represents over 90% of the hazardous waste incineration sector in the EU and includes some of the world’s largest waste management companies.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

28 May 2021

Revision of EU legislation on hazard classification, labelling and packaging of chemicals – Impact assessment Introduction of new hazard classes (such as endocrine disruptors) and corresponding criteria: The classification of waste is based on chemicals legislation but should remain separate to the CLP regulation as the outcomes for chemicals and waste are different. Chemicals (particularly hazardous substances) are often restricted in uses and rightly follow a risk-based approach, in contrast when a waste is created the fate is not certain and therefore the classification is based on a hazard-based approach to ensure that the treatment should match the hazardousness of the particular waste. The current situation should be maintained ie where the rules for classifying waste as hazardous, in Annex III of the Waste Framework Directive, are based on the framework of the CLP Regulation but should not be fully aligned with those for the classification of substances and mixtures under the CLP Regulation. Clarify the obligations to classify mixtures and some complex substances: Article I of Regulation 1272/2008 (the CLP regulation) states that “Waste as defined in Directive 2006/12/EC of the European Parliament and of the Council of 5 April 2006 on waste is not a substance, mixture or article within the meaning of Article 2 of this Regulation”. The provisions of the CLP regulation should not directly apply to waste. The end fate of hazardous substances in mixtures and products can be reasonably assessed. However, when a product becomes a waste, it is not possible to be sure of the end fate of the waste. Therefore, the hazardous properties of a waste should be defined based on the intrinsic properties of a waste and without taking into account the end fate of the waste ie it should remain a hazard-based approach rather than a risk-based approach. Changing to a risk-based approach would risk complete loss of control of the fate of hazardous wastes.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Eurits is an association of hazardous waste management companies across the EU. Its membership represents over 90% of the hazardous waste incineration sector in the EU and includes some of the world’s largest waste management companies. Eurits fully supports the ongoing actions towards climate neutrality and welcomes the opportunity to provide its input - Please find our comments in the attached document.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

26 Nov 2020

Eurits is an association of hazardous waste management companies across the EU. Its membership represents over 90% of the hazardous waste incineration sector in the EU and includes some of the world’s largest waste management companies. Eurits fully supports the ongoing actions towards climate neutrality and welcomes the opportunity to provide its input - Please find our comments in the attached document.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

Eurits [The European Union for the Responsible Incineration & Treatment of Special waste] welcomes this opportunity to provide feedback on the European Commission’s roadmap for a Zero Pollution Action Plan. Since its creation, Eurits has had a mission to keep the environment safe and clean. This is the core of its expertise and as such Eurits supports actions to secure cleaner air, water and soil, healthier ecosystems and a healthier living environment for Europeans. Please find our comments in the attached document.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Please find attached the comments from Eurits.
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Response to A new Circular Economy Action Plan

17 Jan 2020

Eurits welcomes the development of a new Circular Economy Action Plan (CEAP). The first Circular Economy Action Plan has created widespread acceptance of the need to move from a linear to a circular economic model and focused on some specific recycling targets and in particular municipal waste. For the new CEAP to take the next steps the focus needs to change from municipal waste [which is only 10-15% of total waste arisings] and recycling rates to other types of waste and how we can improve the quality of recycling. We see the need for 4 main priority areas of activity: - Ensure full and harmonised implementation / compliance with existing waste legislation - Decontamination is a necessary part of the solution to achieve non-toxic material cycles and should be at the heart of the discussions on the new Circular Economy Action Plan and the move towards a zero-pollution ambition for a toxic-free environment to remove/dispose of hazardous components or contaminants from material cycles. We should not accept recirculation of any unwanted hazardous substances lowering the quality of the recycled materials/products. - Non-dilution should be a key principle to avoid dispersion of pollutants. Non-dilution is the other side of decontamination as preventing dilution of waste to ensure that waste is treated properly and stop Substances of Concern being circulated in recycled materials – diluting hazardous substances in recycled materials reduces the trust and value of the recycled materials. - Correct classification of hazardous waste – there is a need for clearer legislation to avoid misclassification of hazardous waste as non-hazardous. Product classification should not be the same as waste classification as the intentions and outcomes are different – for products a risk based approach is appropriate as the classification can also include restrictions on how the product is used, for waste the classification must take into account intrinsic properties of the waste and the fact that final destination of the waste is not certain so therefore a hazard based approach is appropriate. Our arguments are explained in more detail in the attached file.
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Response to Commission Regulation amending Annex III to Directive 2008/98/EC

17 Aug 2016

Eurits welcomes the Commission’s attempts to work on the HP14 issue, however we have some specific concerns on the proposed Regulation which we raised in a previous submission on the study into HP14. We are disappointed that the Commission has not responded to concerns raised about Method 1 or the methodology of the study which was based on a very limited dataset. One of the aims of the amendments is to harmonize CLP and the definition of hazardous waste, however the method proposed by the Commission fails to do this – a product classed as eco-toxic under CLP would require a new assessment when it became waste under the proposed Regulation to determine if it met the HP14 criteria. To require a second classification to be made for the purposes of waste legislation appears a significant burden requiring a high level of justification which has not been given. A simple solution to this would be to amend the proposal to add a second option: so that any product classified as eco-toxic would remain as eco-toxic when that product became a waste without the need for a new classification unless there was a demonstrable change in the hazardous properties when the product became a waste. We need consistency between the various pieces of legislation eg CLP, List of Waste / HW definition, Seveso and to comply with ADR. Additional unnecessary re-assessment of wastes will add further to the legislative burden. In future more M-factors will be available and perhaps an alternative solution would be develop work on how to move towards a CLP-harmonized classification of waste allowing the use of M-factors from a variety of sources. We do not believe that the Commission should rush through this consultation (4 weeks over the summer months is not adequate) without full understanding and an impact assessment of this very technical subject.
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Meeting with Daniel Calleja Crespo (Director-General Environment)

23 Sept 2015 · The role of hazardous waste incineration in the circular economy