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FEAD

FEAD

FEAD is the European federation representing the private waste and resource management industry.

Lobbying Activity

FEAD: Advanced Materials Act must prioritize recyclability and strategic infrastructure

13 Jan 2026
Topic — EU policy initiative aimed at strengthening industrial capacities and strategic autonomy in advanced materials.
Message — FEAD calls for the integration of circular economy principles, specifically design-for-recycling and design-for-disassembly. They argue that recycling facilities should be designated as strategic infrastructure on par with manufacturing sites. Finally, regulatory simplification must include fast-track permitting for waste treatment operators.123
Why — These measures would unlock new investments and ensure a stable market for recycled advanced materials.45
Impact — Primary raw material suppliers may face reduced demand as the industry shifts toward recycled alternatives.6
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FEAD Urges Inclusion of Waste-to-Energy in EU Taxonomy Review

5 Dec 2025
Topic — Updating technical screening criteria for the EU environmental taxonomy delegated acts.
Message — The association demands that energy recovery from non-recyclable waste be recognized as sustainable. They also seek simplified reporting rules for smaller companies and flexible biowaste thresholds. Furthermore, they want technical criteria aligned with existing industrial best practice standards.123
Why — These changes would unlock sustainable investment and reduce administrative compliance burdens for operators.45
Impact — Producers of bioplastics would lose market support if their materials are excluded from targets.6
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Meeting with Francois Wakenhut (Head of Unit Environment)

1 Dec 2025 · Exchange of views on the CEA

Waste industry urges sustainability criteria in state aid rescue rules

14 Nov 2025
Topic — Revision of EU guidelines on state aid for companies in financial difficulty.
Message — The organization requests that sustainability criteria be added to the common interest requirements, specifically covering waste management and recycling sectors. They argue plastic recyclers face unfair competition from third countries threatening their survival.123
Why — This would help struggling recyclers access state aid to survive unfair competition.45
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Waste industry demands dedicated circular economy funding in EU budget

12 Nov 2025
Topic — EU's post-2027 budget and funding programmes for competitiveness and innovation.
Message — FEAD requests a dedicated Circular Economy Toolbox within the European Competitiveness Fund, with explicit eligibility for waste management and recycling infrastructure. They seek blended finance instruments, capital incentives, and mechanisms to correct market distortions between virgin and recycled materials.123
Why — This would secure public funding for recycling infrastructure and reduce market disadvantages against virgin materials.45
Impact — Virgin material producers lose market advantages from price gaps and regulatory imbalances.67
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Response to Circular Economy Act

6 Nov 2025

FEAD, the European Waste Management Association, represents the entire waste and resource recovery sector in Europe, including collection, sorting, recycling, energy and material recovery, and the final disposal. This holistic overview puts FEAD in a unique position to connect product, consumer, waste and industrial policy, ensuring that the circular economy is delivered in practice under the upcoming Circular Economy Act. In our Manifesto we set out our ambitious vision of shifting Europes overall material use towards recycled materials, supplying the economy with recycled materials and renewable energy, while managing waste safely and responsibly. We support the ambition to double the Circular Material Use Rate within the decade, and we propose a binding horizontal target of 25 % by 2030. Achieving these targets requires that the circular economy be viewed through the lens of industry and competitiveness, not only sustainability. As we emphasise, recycling and recovery must become industrial-scale resource streams, capable of supplying high-quality materials back into European production, at competitive price and traceable origin. While boosting CMUR is central, the rollout of robust recovery and final treatment systems for residual waste remains a fundamental part of our activity and must be retained, in line with the waste hierarchy, to safeguard system resilience and environmental protection. In this position paper, FEAD offers comprehensive, practical input to the CEA consultation supported by our 10 Policy Recommendations annexed herein. As the waste management sector, we are ready to partner with European institutions, national governments and industrial actors to turn circular economy objectives into tangible, investable, and scalable outcomes.
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Meeting with Jessika Roswall (Commissioner) and

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

FEAD urges operating aid for recycling to compete with virgin materials

6 Oct 2025
Topic — EU revision of state aid rules for environmentally beneficial economic activities.
Message — FEAD requests new provisions for operating aid to recycling facilities, covering energy cost reductions, price gap subsidies between virgin and recycled materials, and support for waste hierarchy treatments. They argue recyclers face unfair competition from cheaper virgin materials and uncontrolled imports.123
Why — This would reduce their energy costs and bridge price disadvantages against virgin materials.45
Impact — Virgin material producers lose competitive advantage from externalized environmental costs.67
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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.

Waste industry urges CBAM extension to recycled plastics

24 Sept 2025
Topic — EU regulation on calculating embedded emissions under Carbon Border Adjustment Mechanism.
Message — FEAD requests that indirect embedded emissions be included in CBAM for recycled plastics imports to address competitive imbalance with third countries. They emphasize that EU recycling activities must not be included under EU ETS, as this would worsen recyclers' economic situation.123
Why — This would reduce competitive disadvantage from higher EU energy costs under CO2 pricing.45
Impact — Non-EU recyclers lose cost advantage from lower energy prices without carbon constraints.67
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Waste industry urges broader carbon removal certification scope

22 Sept 2025
Topic — EU methodologies for certifying permanent carbon removal activities like DACCS and BioCCS.
Message — The organization requests expanded certification methodologies beyond geological storage to include biogenic emissions captured and stored in long-lasting products. They demand clearer sustainability requirements, arguing the current linkage to Taxonomy Regulation creates unworkable interpretation challenges for waste-to-energy operators.123
Why — This would allow waste-to-energy facilities to participate in carbon removal certification markets.45
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Meeting with Arturo De La Fuente Nuño (Acting Director Eurostat - European statistics)

8 Sept 2025 · Technical meeting: Exchange of views on the Circular Material Use Rate (CMUR) methodology and calculation

European Waste Industry Seeks State Aid Eligibility for Recycling

5 Sept 2025
Topic — EU guidelines on state aid compensation for electricity costs under the ETS.
Message — FEAD requests inclusion of recycling activities (NACE-Code 38.32) in the scope of eligible activities for State aid under the ETS guidelines. They argue recycling faces high energy costs while competing with cheaper virgin and imported materials, creating unfair competition.1234
Why — This would reduce their electricity costs and help them compete with cheaper imported recyclates.56
Impact — Producers of virgin raw materials lose their exclusive access to reduced energy levies.7
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FEAD calls for including waste management in climate resilience

3 Sept 2025
Topic — The initiative sets out an integrated framework to improve European climate resilience.
Message — FEAD requests the mandatory inclusion of disaster waste management in climate adaptation strategies and emergency response frameworks. They also advocate for dedicated financial support within the EU Solidarity Fund to upgrade waste infrastructure.12
Why — The proposal would create new market opportunities for waste management companies and SMEs.3
Impact — Public authorities lose regulatory autonomy as mandatory EU guidelines replace local frameworks.4
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Response to Revision of the 'New Legislative Framework'

2 Sept 2025

FEAD, the European Waste Management Association, welcomes the European Commissions initiative to revise the New Legislative Framework (NLF). This revision offers a unique opportunity to modernise product legislation in line with digitalisation, the circular economy, and the need for regulatory coherence. FEADs key priorities are ensuring that the revised NLF facilitates recycling activities, supports the Single Market for secondary raw materials, and strengthens market surveillance while keeping obligations proportionate.
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Meeting with Christine Singer (Member of the European Parliament)

2 Sept 2025 · Lithium Batteries

FEAD coalition urges stricter rules for chemical plastic recycling

19 Aug 2025
Topic — New EU rules for calculating and reporting recycled content in plastic beverage bottles.
Message — The coalition advocates for prioritizing mechanical recycling and demands strict traceability safeguards for chemical methods. They also call for a 'mirror clause' to ensure imported plastics meet EU environmental and social standards.123
Why — These safeguards would protect the competitiveness of European recyclers against cheaper, lower-standard imports.4
Impact — Chemical recycling companies could face higher reporting burdens and reduced demand for their products.5
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FEAD urges inclusion of private firms in reuse rules

4 Aug 2025
Topic — EU consultation on derogations for the prohibition of destroying unsold apparel and footwear.
Message — FEAD recommends expanding eligibility to include all authorised reuse operators and professional waste management companies. They argue that limiting access to social economy entities creates a barrier to reuse.12
Why — This allows private waste firms to capture market share in product refurbishment.34
Impact — Social economy entities would lose their exclusive right to receive unsold product donations.5
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FEAD urges economic support for critical raw material recovery

25 Jul 2025
Topic — The regulation lists waste streams with high potential for critical raw material recovery.
Message — FEAD requests that national programs prioritize the economic viability of recovery processes and provide financial support to bridge investment gaps. They argue that producers should bear more responsibility for identifying materials and designing products for easier extraction.123
Why — This would protect waste managers from unprofitable sorting mandates while shifting financial burdens to producers.45
Impact — Manufacturers face higher costs from expanded recycling responsibilities and mandatory product design changes.6
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FEAD urges waste code inclusion in unsold product disclosure

10 Jul 2025
Topic — EU rules requiring companies to disclose details about the destruction of unsold consumer products.
Message — The organization proposes including waste codes alongside customs codes to match standard industry practices. They also recommend limiting disclosure requirements to the first waste treatment operation.12
Why — Waste operators avoid unfeasible tracking requirements while ensuring compatibility with current management systems.34
Impact — Regulators lose visibility into the ultimate environmental impact of residues from processed products.5
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Waste industry warns against including incineration in EU ETS without safeguards

8 Jul 2025
Topic — Review of EU emissions trading system scope to potentially include waste incineration.
Message — The organization requests that municipal waste incineration not be included in the EU ETS without complementing measures. They argue operators cannot proactively reduce emissions without carbon capture infrastructure, and a carbon price would only increase treatment costs including for recycling residues.123
Why — This would avoid increased operating costs and protect their ability to treat recycling residues affordably.45
Impact — Recycling industries lose as higher residue treatment costs worsen their existing crisis from competition.67
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FEAD urges incentives for recycled materials in decarbonisation law

8 Jul 2025
Topic — The consultation seeks views on accelerating industrial decarbonisation and stimulating investments in Europe.
Message — The association wants the EU to recognize emissions savings from using recovered materials and energy. They advocate for strict definitions of recycled content and carbon-based sustainability criteria for polymers. They also request faster permitting and better support for waste-to-energy heat networks.123
Why — This approach would increase demand for European recyclates while lowering administrative and regulatory costs.45
Impact — Producers of virgin materials and non-EU importers with lower environmental standards would lose market share.67
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Meeting with Barbara Bonte (Member of the European Parliament)

2 Jul 2025 · Waste management

Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Eero Heinäluoma (Member of the European Parliament)

30 Jun 2025 · Waste Management Sector Issues

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

22 May 2025 · Discuss with interested stakeholders the practical aspects and challenges of ensuring compliance with Art.5(5) of the PPWR (concerning PFAS limits in food-contact packaging)

Meeting with Aurel Ciobanu-Dordea (Director Environment) and Confederation of European Waste-to-Energy Plants and BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V.

22 May 2025 · Exchange of views on the feasibility study to include waste incineration and landfilling in the ETS Directive (greenhouse gas emission allowance trading).

Meeting with Jessika Roswall (Commissioner) and

25 Apr 2025 · Circular Economy Act

Response to Shipments of waste - systems interoperation for electronic submission and exchange of information and documents

2 Apr 2025

FEAD thanks the Commission for the draft document and possibility to provide feedback. FEAD has long promoted safe and efficient waste shipments as indispensable for the circular economy, most notably during the revision process that resulted in the new WSR. In these new rules, FEAD has particularly welcomed the digitalisation of procedures to increase the speed, efficiency, transparency, and traceability. Therefore, when laying down the detailed requirements for the electronic submission and exchange of information and documents, as per the draft implementing regulation at hand, it is of outmost importance that all tools provided in the new WSR to streamline procedures are also rigorously integrated. In relation to the draft regulation, FEAD notes a number points that must be urgently revised, especially to ensure that simplification options under the WSR text are also possible in practice via DIWASS. These remarks align with the overall objective of the EU of reducing administrative burden. Please find FEAD's feedback in the file attached.
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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

Meeting with Aurel Ciobanu-Dordea (Director Environment) and European Recycling Industries' Confederation

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

European waste industry urges clearer OpEx rules for taxonomy reporting

26 Mar 2025
Topic — Amendments to simplify sustainability reporting and reduce compliance costs for EU companies.
Message — FEAD recommends simplifying reporting templates and removing or redefining the OpEx indicator. They also request numerical examples to clarify the interpretation of materiality thresholds.123
Why — Redefining KPIs would make compliance easier within existing company accounting systems.4
Impact — Financial market investors lose access to specific operational expenditure data on sustainability.5
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Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)

18 Mar 2025

FEAD, the European Waste Management Association, welcomes the proposal of the European Commission to propose an unintentional trace contaminant (UTC) limit value for Polychlorinated biphenyls (PCBs) under the Annex I of the POP Regulation. However, the waste management industry questions the availability of standardised analytical methods for testing for the presence of all PCBs in waste matrix, and requests for clarification regarding the application of the derogation for organic pigments and organic dyes to secondary raw materials.
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Waste industry urges EU to curb public sector monopolies

7 Mar 2025
Topic — An evaluation of EU directives governing public procurement and concession contracts.
Message — FEAD requests a mandatory competition test to limit direct awards to public entities. They propose mandatory green procurement rules and requirements for European recycled materials.12
Why — Private waste management firms would regain access to currently monopolized municipal markets.34
Impact — Publicly owned companies and non-EU recyclate producers would face reduced market access.56
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Waste industry FEAD urges mandatory water reuse and polluter-pays

4 Mar 2025
Topic — This consultation addresses a multi-annual plan to ensure water resilience across the EU.
Message — FEAD recommends mandatory water reuse in drought zones and for public irrigation. They support phasing out contaminants early and making industrial polluters pay for treatment.123
Why — New regulations would drive investment into the waste management industry's infrastructure.4
Impact — Industrial polluters would bear the financial burden for cleaning up wastewater contaminants.5
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Meeting with Aurel Ciobanu-Dordea (Director Environment) and European Recycling Industries' Confederation and Plastics Recyclers Europe

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

FEAD urges EU to prioritize recycled materials in single market

31 Jan 2025
Topic — The Commission is consulting on a strategy to develop a more competitive single market.
Message — FEAD suggests incentivising the use of recycled materials by introducing additional mandatory recycled content targets. They recommend mirror clauses for imported materials to protect the European recycling industry. Preferential treatment of public entities over private companies should be excluded to ensure fairness.123
Why — These measures would drive economic growth and strengthen the competitiveness of private waste managers.45
Impact — Public waste operators and virgin material producers would lose their current market and cost advantages.67
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Meeting with Hélder Sousa Silva (Member of the European Parliament)

30 Jan 2025 · Promoting the circular economy by representing Europe’s private resource and waste management industry.

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur) and Decathlon SE

22 Jan 2025 · Waste Frame Directive

Response to Digital Product Passport (DPP) service providers

10 Dec 2024

FEAD, the European Waste Management Association, welcomes the European Commission's proposal for the Digital Product Passport (DPP) under the Ecodesign for Sustainable Products Regulation. As representatives of the waste management private sector, we recognise the DPP as a key tool to promote transparency across product value chains, support sustainability objectives and enable the transition to a circular economy. However, FEAD notes that significant challenges remain with regard to the practical implementation and usefulness of the DPP for the waste management sector. While its ambition to provide granular data is commendable, lessons from existing tools such as the SCIP database show that complexity and limited usability can hinder its effectiveness for recyclers. Ensuring that the DPP provides actionable, accessible and standardised information is crucial to maximising its benefits while minimising the administrative burden. Given the wide scope of the DPP, covering more and more product categories, FEAD has proposed a list of guiding principles to ensure that the DPP can be used effectively and smoothly by the waste management sector, to optimise its implementation and leverage its potential to advance Europes circular economy goals.
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Meeting with Karin Karlsbro (Member of the European Parliament, Shadow rapporteur)

13 Nov 2024 · Plastpellets

FEAD demands 24-month transition for hazardous battery waste classification

8 Nov 2024
Topic — Revision of the European List of Waste to address evolving battery chemistries.
Message — FEAD calls for a 24-month transition period for implementing new waste codes. They also propose merging overlapping battery classifications to avoid operational confusion and high costs.12
Why — This would provide more time for complex waste permit amendments and necessary infrastructure investments.34
Impact — Regulators lose granular data tracking of specific battery chemistries through merged waste codes.5
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Waste manager association FEAD warns of excessive reporting burdens

7 Nov 2024
Topic — The proposal expands the Union database to cover traceability for fuel production materials.
Message — FEAD requests integrating national reporting systems with the Union database to stop duplication. They propose extending reporting deadlines to 30 days and demand less severe penalties.123
Why — These changes would lower compliance costs and ensure businesses avoid sudden operational suspensions.4
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Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

5 Nov 2024 · Waste Framework Directive

Waste managers urge clearer EU battery recycling calculation rules

18 Oct 2024
Topic — European Commission methodology for calculating and verifying battery recycling efficiency and material recovery rates.
Message — FEAD suggests refining definitions of black mass and first recycler to avoid ambiguity. They urge the Commission to establish clear criteria for including specific elements in calculations.12
Why — Clear criteria provide legal certainty and prevent competitors from using incomparable recycling efficiency rates.34
Impact — Some operators lose the ability to meet targets without developing solutions for difficult-to-recover elements.5
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Meeting with Pascal Arimont (Member of the European Parliament) and European Recycling Industries' Confederation and

15 Oct 2024 · Circular Economy and waste management

Meeting with Benedetta Scuderi (Member of the European Parliament)

2 Oct 2024 · New mandate

Meeting with Sara Matthieu (Member of the European Parliament) and Denuo vzw/asbl

26 Sept 2024 · Circular Economy in next mandate

European waste industry urges flexible biomass monitoring over monthly mandates

29 Jul 2024
Topic — EU regulation updating greenhouse gas monitoring rules for emissions trading system.
Message — FEAD opposes mandatory monthly biomass fraction measurements in waste-to-energy plant flue gases. They want Member States to maintain flexibility in monitoring approaches, such as France's fossil factor method or Germany's thermal capacity ratio, arguing these are sufficient and cost-effective.12
Why — This would save the sector millions in compliance costs and avoid fiscal pressure on households.34
Impact — Climate accountability loses precision as less frequent monitoring may underreport fossil carbon emissions from waste incineration.56
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Waste Industry Calls for Producer Responsibility in Carbon Capture Rules

16 Jul 2024
Topic — EU rules on when captured CO2 is permanently bound in products.
Message — FEAD requests that producers, not waste operators, be held responsible for ensuring captured CO2 doesn't re-enter the atmosphere. They want upstream accounting of emissions when products are placed on market, and broader recognition of carbon offsetting beyond ETS sectors including avoided emissions from recycling.123
Why — This would shift climate compliance costs away from waste operators who cannot control incoming waste streams.45
Impact — Product manufacturers face increased responsibility and costs for managing end-of-life carbon emissions.6
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Response to Environmental Implementation Review 2025

5 Jul 2024

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe endorses the Environmental Implementation Review foreseen in 2025. FEAD recognises that a proper and effective implementation of EU environmental legislation is the cornerstone for reaching the objectives of the EU Green Deal. A lack of or incorrect implementation of EU environmental legislation has been and still is a major problem that jeopardises the EUs climate and environmental goals. Therefore, hereafter, we identify some areas in which a proper implementation and enforcement is particularly lacking. Please find the rest of FEAD's feedback attached.
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste (2)

3 Jul 2024

FEAD, the European Waste Management Association, has repeatedly called for facilitated intra-EU shipments with a dedicated e-waste entry. Both, the particularities of the nature of our single market and the high environmental and social standards we enjoy in the EU must be considered and should enable, within the EU, a differentiated regime from the international landscape. The EU single market is essential for the circular economy. A complex waste flow like e-waste, which is treated in highly specialised plants, requires enormous investments (several billion euros) and the corresponding economies of scale. The recycling of e-waste and the recovery of critical raw materials is today high on the political agenda, but also needs a strong demand. Therefore, processes suitable for the recovery of these materials are not developed in all EU countries. In fact, the market counts with a few actors that have been already active for years with comforting benefits and results. At OECD level, we count with relevant operators in few countries: Germany, Sweden and Belgium, in Europe, one in South Korea, four in Japan and one in Canada. Stimulated by EU policies, the recovery of critical raw materials is expected to increase in the coming years and with it, the needed shipments. Facilitated intra-EU shipments would strengthen recycling within the EU. Please see more details in the position paper attached.
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Response to EU implementation of recent amendments to the Annexes of the Basel Convention regarding trade in e-waste

3 Jul 2024

FEAD, the European Waste Management Association, has repeatedly called for facilitated intra-EU shipments with a dedicated e-waste entry. Both, the particularities of the nature of our single market and the high environmental and social standards we enjoy in the EU must be considered and should enable, within the EU, a differentiated regime from the international landscape. The EU single market is essential for the circular economy. A complex waste flow like e-waste, which is treated in highly specialised plants, requires enormous investments (several billion euros) and the corresponding economies of scale. The recycling of e-waste and the recovery of critical raw materials is today high on the political agenda, but also needs a strong demand. Therefore, processes suitable for the recovery of these materials are not developed in all EU countries. In fact, the market counts with a few actors that have been already active for years with comforting benefits and results. At OECD level, we count with relevant operators in few countries: Germany, Sweden and Belgium, in Europe, one in South Korea, four in Japan and one in Canada. Stimulated by EU policies, the recovery of critical raw materials is expected to increase in the coming years and with it, the needed shipments. Facilitated intra-EU shipments would strengthen recycling within the EU. Please see more details in the position paper attached.
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Response to Update of State aid procedural rules, considering the EU’s international commitments, recent practice and case law

27 Jun 2024

To encourage further private sector investment in the circular economy, FEAD has long called upon policymakers to ensure the full implementation of a European internal market for waste. This includes enforcing Single Market rules on State aid, in particular with regard to public undertakings. In this context, FEAD welcomes the Commission's initiative to ensure access to justice in environmental matters related to State aid and strongly stresses that the planned procedure must not jeopardise or compromise the anonymity of complainants. In addition, FEAD notes the following points in relation to State aid measures: 1. State aid allocation should follow a special procedure to ensure market competition 2. Implementation of effective mechanisms to control State aid utilisation 3. Alignment of State aid decision procedures with EU legislation 4. Redefining State aid measures Please find more information in the position paper attached.
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Response to Waste shipments - information on certificates on interim recovery and disposals and non-interim recovery and disposals

28 May 2024

FEAD feedback on the draft certificate to confirm the completion of a subsequent interim or non-interim recovery or disposal treatment operation according to Art. 15(5) WSR FEAD thanks the Commission for the quick preparation of the draft Delegated Regulation to the new Waste Shipment Regulation, which determines the information to be provided in the certificate confirming the completion of a subsequent interim or non-interim recovery or disposal operation according to Art. 15(5) WSR. FEAD notes the following points: 1. Such certifications will be an enormous administrative burden for operators if foreseen to be completed for each shipment. One must imagine the amount of paperwork for treating, for example, e-waste from which 10 or 20 different fractions, iron, aluminium, copper, plastics, boards, brass, etc., are recovered. It must be clarified that the certification can cover more than one shipment as box 2 seems to indicate. For this, more than one date needs to be allowed in box 5 (on quantities received). 2. The amount of recovered or disposed waste can be difficult to identify because facilities are receiving waste from different sources and no plant treats waste in single/differentiated batches or lots accordingly. It must be clarified how/based on what data the information requested in box 7 (quantities treated) is to be provided (e.g., an estimation or an average rate). FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fuelling 5 billion of investments into the economy every year. For more information, please contact: FEAD Secretariat info@fead.be
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Response to Application of the ‘do no significant harm’ principle to the Social Climate Fund and its possible future extension

28 May 2024

FEAD position paper call for evidence on the application of the "do no significant harm" principle to the Social Climate Fund and policy reflections for its future extension under the next Multiannual Financial Framework FEAD takes the opportunity of this call for evidence to comment on the need to clarify Article 17(1)(d) of the Taxonomy Regulation (TR) in combination with Article 13(1)(j) with regard to the incineration of non-hazardous waste. The Taxonomy Regulation provides that an activity qualifies as substantially contributing to the transition to a circular economy, including waste prevention, re-use and recycling, where that activity minimises the incineration of waste and avoids the disposal of waste, including landfilling, in accordance with the principles of the waste hierarchy (Art. 13(1)(j)). Later, the text also describes activities significantly harming the circular economy (Art. 17(1)(d)) as those leading to a significant increase in the generation, incineration or disposal of waste, with the exception of non-recyclable hazardous waste. The term waste incineration is not defined in the Taxonomy Regulation, and the Regulation does not distinguish between waste incineration for recovery and waste incineration for disposal. However, a clear difference exists between recovery (R1 waste-to- energy) and disposal (other incineration), and they fall under different sections of the waste hierarchy. Please find the rest of FEAD's feedback in the attached file.
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FEAD seeks legal clarity for recovered nitrogen manure products

17 May 2024
Topic — The European Commission is amending rules for processing livestock manure into fertilizers.
Message — FEAD requests a clear legal status for RENURE products within existing fertilizer and animal by-product regulations. They advocate for these recovered nutrients to replace chemical fertilizers and exceed standard nitrogen application limits.12
Why — Clearer rules would help waste companies commercialize processed manure as high-value mineral fertilizers.3
Impact — Conventional chemical fertilizer producers face competition from recovered nutrients replacing their products.4
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Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

FEAD, the European Federation for Waste Management and Environmental Services, representing the private sector waste and resource management industry across Europe, welcomes the Commission's initiative to increase quality control under Regulation (EU) No 10/2011 and Regulation (EC) No 2023/2006 on plastic food-contact materials. However, FEAD points out that the text version requires minor amendments for greater clarity. FEAD underlines that plastic recyclates fall within the scope of Regulation (EU) No 2022/1616 where the incidental contamination of polymers is already regulated. We understand that plastic recyclates do not fall within the scope of Articles 3a and 8 of the amended Regulation (EU) No 10/2011 and therefore ask for clarification in this respect.
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Waste industry urges BPA exemptions for recycled materials

8 Mar 2024
Topic — The consultation addresses restrictions on bisphenol A and other bisphenols in food contact materials.
Message — FEAD requests an explicit exemption for unintentional BPA use in recycled materials. Recyclers should not be required to eliminate BPA through mandatory supplier changes. They advocate for regulating BPA precursors earlier in the packaging supply chain.123
Why — This prevents technical barriers that would otherwise disrupt the recycling of waste materials.4
Impact — Public health interests could suffer from the continued presence of bisphenols in recyclates.5
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Response to Technical specifications for the preparation of risk management plans to ensure the safe reuse of treated waste water in

8 Feb 2024

FEAD Feedback to the Draft Delegated Act on risk management in water reuse in agriculture FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, welcomes the Commissions Delegated Regulation on risk management in water reuse in agriculture. This draft Delegated Act, to a certain extent, encompasses the conflicting goals of zero pollution and the transition to a circular economy, mentioning both the Circular Economy Action Plan and the revision of the Urban Wastewater Treatment Directive 91/271/EEC (UWWTD), as part of the Zero Pollution Action Plan. Therefore, technical specifications of key elements of risk management are paramount to ensure comprehensive protection of human, animal, and soil health. Identification of potential hazards and hazardous events FEAD appreciates that the Commission emphasizes the importance of the issues related to water, namely that climate change leads to water resources being increasingly under pressure, and water stress and droughts having become customary across the EU. A comprehensive risk management in water reuse in agriculture must also imperatively tackle these issues. With this background, the responsible national authorities should manage the two aspects described above to create a harmonized framework that ensures human and animal health protection on one side, and combatting the effect of the climate crisis, such as drought, on the other. FEAD supports the identification of potential hazards and hazardous events in the Annex to the Draft Regulation, covering the possible dangers to public health and the environment in a comprehensive way, also including pollutants that are not yet regulated (point 5 of the abovementioned section) in point 3 of Annex II to Regulation (EU) 2020/741 on minimum requirements for water reuse. Production of reclaimed water On the description of the process to produce reclaimed water, FEAD believes it is appropriate to emphasize that the parameters for the characterization of the quality of the water should be set after consultation with the operators of the wastewater treatment plants, and all data must be made available to the operators. Assessment of risks to the environment and to human and animal health FEAD believes that it should be clarified that not all the risk matrices mentioned in the risk assessment to the environment and to human and animal health (Annex page 12) listed in paragraph 6 are to be considered for risk assessment, but only one of them is to be chosen. Additional or stricter requirements for water quality and monitoring and preventive measures FEAD stresses that it is highly important that reclaimed water coming from wastewater treatment plants is used in agriculture, respecting the requirements to ensure the protection of human and animal health, and of our soils. At the same time, it must be ensured that the reuse of reclaimed water stemming from wastewater treatment plants is enabled in the best possible way. Where the purpose of reuse in agriculture cannot be satisfied because the reclaimed water does not comply with the requirements, e.g. it is contaminated or it exceeds thresholds in value, environmentally friendly water cycles must still be adopted. Water reuse systems and the storage of rainwater constitute an important contribution to tackling the problem of increased periods of drought, therefore water coming from these systems should be reused in areas particularly affected by drought, as well as for the irrigation of city green. Consequently, in the Annex of the Delegated Act identifying additional advanced treatments is mentioned as preventive measure that may be used to prevent or eliminate risks to health or the environment or to reduce them to an acceptable level. FEAD believes that this obligation is quite vague. Please, find the all feedback in the attachment.
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Response to 8th Environment Action Programme – Mid-term Review

26 Jan 2024

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, welcomes the Commissions mid-term review of the 8th Environment Action Programme (8EAP), which established as a supportive tool to speed up the transition to a climate-neutral, sustainable, non-toxic, resource-efficient, renewable energy based, resilient and competitive circular economy. FEAD sustains the importance and the value of the Monitoring report on progress towards the 8th EAP objectives for the year 2023, published by the European Environment Agency (EEA) that focuses on: 1. the progress achieved and the outlook towards meeting the 8th EAPs thematic priority objectives for 2030; 2. the progress made in setting up and fully using the enabling conditions described in Article 3 of Decision (EU) 2022/591; 3. the progress made in establishing a robust monitoring framework capable of assessing systemic change. Circular material use rate in Europe The Circular Material Use Rate (CMUR) indicates the circularity of materials in the economy and refers to the share of the total amount of material used in the economy that is accounted for by recycled waste. In 2021, the CMUR was evaluated at 11.7%, which represented a decrease of 1.1 percentage points compared to 2020. In order to double the CMUR, the EU would need to reach a rate close to 25% by 2030, meaning a 15-fold increase in the average EU CMUR growth rate of the previous decade. This rather slow progress, together with projections for increased material demand in the EU by 2030, signify that currently the EU is not on track to double the circular material use rate by 2030. Clearly, a step change needs to occur. FEAD urges policymakers to close the legislative loop for recyclates. The demand side and uptake of European recycled material is essential for the waste management industry to play a role in contributing to the overall targets as set by Europe. FEAD fully supports the European Unions ambition to double its Circular Material Use Rate (CMUR) between 2020 and 2030, because increasing the use of secondary materials would reduce the extraction of primary raw materials and related adverse environmental impacts. Indeed, FEADs mission is to supply the European economy with secondary raw materials and energy, while managing waste in a safe and environmentally responsible way. FEADs vision is to shift Europes overall material use towards recycled materials through industrial excellence in waste management. Our goal is to boost the EUs domestic capacity to supply its industry with high quality raw materials from recycling. Therefore, we need to urgently accelerate the uptake of secondary raw materials into the economy, and to do this, we strongly support the European Unions ambition to double its Circular Material Use Rate (CMUR) in this decade. Our target is to achieve a 75% target for the recycling of all waste (not only municipal) in the EU by 2035. By setting such an ambitious target of recycling 75% of all waste, FEAD is signaling to policymakers and the whole circular economy value chain that concerted and ambitious action is required to boost the uptake of secondary raw materials into the economy. With the right policy and regulatory framework, our sector can ensure that products, components and materials that become waste are effectively recycled. However, for the share of materials that do not meet the quality requirements for recycling, or where recycling does not deliver the best overall environmental performance, other solutions exist for waste management. In particular, recovering the energy contained in the waste complements recycling as a means to achieve the EUs climate goals of becoming climate neutral by 2050. To achieve ambitious targets, FEAD has identified the following asks and actions: PLEASE, FIND OUR COMPLETE FEEDBACK IN THE PFD FILE ATTACHED.
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Response to Measures to reduce microplastic pollution

17 Jan 2024

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe supports the Commissions Proposal for a Regulation to prevent plastic pellet losses and to reduce microplastic pollution as a supportive tool to reach the objectives of the European Green Deal and to reinforce overarching strategies such as the Plastics Strategy, the Circular Economy Action Plan and the Zero Pollution Action Plan. As indicated by the Commission in its proposal, plastic pellet losses are, together with paints, tires, textiles, geotextiles, and detergent capsules, sources of unintentional microplastic releases in the environment. This initiative should raise awareness and streamline handling of plastic pellets, from the prevention to the containment and clean-up, when necessary. The presence of plastic pellets losses at all supply chain stages, from production to processing, transport and waste management operations can lead to adverse impacts on the environment, climate, potentially human health, and economy. FEAD believes that the measures referred to in the proposal are rightly aimed at limiting the loss of plastic pellets to as little as possible. Nevertheless, FEAD also highlights that recycling plants in Europe already work to ensure the management of microplastics in the safest way possible. For example, there is already detailed national legislation in some Members States and there are already standards and voluntary schemes developed. Obligations regarding the handling of plastics pellets FEAD supports the introduction of mandatory risk assessment plans to be carried out by the economic operators for each installation (Article 4 of the proposal), following the elements detailed in Annex I. Nevertheless, we stress the importance of the Commissions proposal to take into account the nature and size of the installations as well as the scale of their operations. This refers, particularly, to the equipment and procedures listed in Annex I, paragraphs 7 and 8, which must stay as an indicative list to be considered when establishing the risk assessment plan. As there are no one-size-fits-all solutions, the most appropriate equipment and/or procedures will depend on the characteristics of each plant and must be defined by experts and professionals according to their technical feasibility. Therefore, none should be made compulsory within the course of the ongoing legislative process. For example, paragraph 8 in Annex I, requires the description of the procedures in place to prevent, contain and clean up spills and losses. Among others, economic operators shall consider limits on the volumes of pellets transported in certain packaging (e.g., pellets must be packaged and sealed in 25 kg sacks and loaded no more than 1 tonne per pallet). When assessing this measure, operators will also consider that the eventual limit of 1 tonne per pallet will imply using more packaging, increasing thus the packaging waste produced as well as increased fuel consumption and transport-related emissions, as the quantity of material transported on individual vehicles would be significantly reduced. FEAD reiterates its support to the aim of this proposal, focused on helping preserve ecosystems and biodiversity, decrease potential health impacts and benefit local economic activities. Establishing a detailed risk assessment plan for each installation is essential especially to evaluate the weaknesses in handling plastic pellets. With the illustration of the example above, FEAD also stresses the importance of the approach taken in the Commissions proposal, according to which economic operators will ultimately define the most appropriate measure according to the nature and size of the installation. Please find the rest of our feedback in the attached file.
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Response to Persistent organic pollutants - hexabromocyclododecane (HBCDD)

26 Dec 2023

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Commissions Delegated Regulation draft on the persistent organic pollutant hexabromocyclododecane (HBCDD). Hexabromocyclododecane belongs to a group of brominated flame retardants whose use is not currently permitted except for HBCDD in EPS articles already in buildings before February 2018 and HBCDD in XPS articles already in use in buildings before June 2016. It has been mostly used in polystyrene insulation materials (EPS) and extruded polystyrene (XPS), in textiles, packaging materials (EPS), such as back-coatings of curtains and upholstery fabrics or in plastic housings or high-impact polystyrene (HIPS) for electrical and electronic applications. HBCDD also occurs in recycled plastics and plastic products in concentrations from a few mg/kg up to more than one thousand mg/kg. FEAD totally understands and supports the Commissions concern about the undesirable presence of the restricted brominated flame retardants in children's toys, food contact articles and polystyrene packaging in new applications of recycled polymeric material. Therefore, we welcome both measures proposed and amending Part A of Annex I of the POPs Regulation, firstly on the general Unintentional Trace Contaminant (UTC) value lowered from 100 mg/kg to 75 mg/kg and secondly on maintaining the value of recycled polystyrene at 100 mg/kg in the production of EPS and XPS insulation material for use in buildings or civil engineering works which will be subjected to revision by 1 January 2026. We believe that taking into account the use of recycled polystyrene in EPS and XPS is useful to let our sector gradually adapt to the proposed limits. Our sector handles materials that might contain legacy substances and the most cost-effective way to get rid of those substances is to phase them out as soon as possible. In the meantime, we need visibility and predictability to choose the best treatment option and ensure safe material loops in accordance with regulatory thresholds. It is, therefore, important to maintain this approach: future revisions should strike the right balance between fostering a more circular economy and protecting human health. FEAD Secretariat info@fead.be
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Waste industry group FEAD urges faster car recycling rules

4 Dec 2023
Topic — The European Union is revising regulations for car design, collection, and recycling.
Message — FEAD requests reducing the transition period for vehicle types to three years. They also advocate for setting clear collection targets for end-of-life vehicles. The group wants flexible dismantling rules based on market demand and feasibility.123
Why — Flexible rules and better access to materials would boost their commercial profitability.45
Impact — Car manufacturers may face higher fees to fund increased recycling and dismantling costs.6
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Meeting with Maroš Šefčovič (Executive Vice-President) and

30 Nov 2023 · Clean Transition Dialogue on Energy Intensive Industries

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

22 Nov 2023

FEAD is fully committed to the objectives of the European Green Deal and the Circular Economy Action Plan as essential tools for providing the adequate stimuli to our economy while pushing forward EU Climate goals through the circular economy. As stated by the Commissions proposal, the textiles and food sectors represent top resource intensive sectors causing significant negative environmental externalities, where financing and technological gaps impede progress towards the transition to a circular economy and decarbonisation. These two sectors are the first and the fourth most resource intensive sectors respectively and have not yet fully adhered to the EU waste management hierarchy. Stimulating, for example, better sorting of textile waste for reuse and recycling across the EU is essential to create a circular economy for this sector and to limit its negative environmental impacts. It should be stated though, that the Waste Framework Directive (WFD) itself is not the most appropriate instrument to regulate single waste streams, and that separate pieces of legislation have been used before for packaging, end-of-life vehicles, or waste electrical and electronic equipment (WEEE). Please find the full feedback attached as a file.
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Waste industry calls for flexible EU soil health assessments

3 Nov 2023
Topic — EU proposal to define healthy soil conditions and provide for its sustainable restoration.
Message — FEAD opposes the strict all in or out principle for soil health classification. They want national authorities to use overall assessments and faster timelines to promote composting. They also request that soil health registers remain confidential.123
Why — Flexibility avoids strict classification while promotion of compost expands their market reach.45
Impact — Citizens and environmental groups lose access to public data on contaminated land sites.6
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Response to Revision of EU rules on textile labelling

29 Sept 2023

FEAD supports the revision of EU rules on textile labelling to ensure the correct information of consumers. The waste management sector needs information on the waste received, but a label at product level will have little added value for waste managers working with big and bulky flows and applying automatic (sorting) processes. It will however help consumers to choose more sustainable products (recyclable products that include recycled materials) and to discard (sort) them properly at the end of their life, which is positive for our industry. When the waste reaches the plants, it is subject to automatic sorting processes, primarily mechanical, physical, and optic scan processes. In the case of textiles, automatic sorting will need to do an optic scan on fibre content in any case. In this respect, while it is relevant to have information available, this information on a label on the product will hardly reach the waste management sector in a way that it can be used according to the processes mentioned before. Therefore, a label or product passport at product level has little added value at this stage of the waste management. Nevertheless, such a label or product passport in form of QR-code, or similar, could still have a positive impact for the sector as it will improve the separate collection at source (by the consumer). Considering that the availability of information is still important (especially for source segregation), it needs to be ensured that the label/product passport actually reaches the end of life of the product and the waste managers. If it would be a QR-code or written information on the existing textile cloth or fabric price and material tag, it will be detached before actual usage of the good. Therefore, the information should be undetachable from the good and made from the same materials as the good itself to avoid further mixing of materials. The information to be provided to consumers should focus on relevant data that enables a smooth circular process of the garment. Consistency across legislation should be guaranteed (Textile Labelling Regulation and Ecodesign Regulation). In the case of textiles, information on materials used, material components, presence of substances of concern, and the possibility of remanufacturing and recycling (design for recycling) is important for sorting and recycling activities, including source segregation. In addition, the following information will enable sustainable choices for consumers: recycled content; possibility of recovery of materials; environmental impacts, including carbon and environmental footprint; energy use or energy efficiency. A relevant challenge will be to ensure the reliability/accuracy of the data used in the process / passport. A possibility could be to add this as a quality requirement to standardised processes. FEAD and its members are ready to enter into dialogues with the institutions and all relevant stakeholders to explain the needs of our industry and improve the labelling, sustainability and circularity of textiles.
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European Waste Association Seeks Flexibility on Emissions Monitoring Rules

23 Aug 2023
Topic — EU ETS directive updates on monitoring and reporting greenhouse gas emissions.
Message — FEAD requests more flexible uncertainty standards for Waste-to-Energy plants and a transitionary period using only standard emission factors. They want monthly sampling instead of continuous monitoring and the ability to group waste into homogeneous categories for reporting.1234
Why — This would substantially reduce analysis, sampling, and compliance costs for waste operators.56
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Response to European Critical Raw Materials Act

29 Jun 2023

FEAD welcomes the Commissions proposal for a Critical Raw Materials Regulation (CRM) as an important step towards clearly acknowledging the role of circularity, recycling and recovering of materials in the diversification of supply sources and in reducing the EUs dependencies. In addition, by recycling CRMs, the EU can conserve natural resources, and minimise the environmental impacts of mining and extraction. Recycling and efficient waste management are critical components of the circular economy. FEAD believes that the EU must take a holistic approach to promoting recycling and efficient waste management. This includes investing in technological innovation, research and development, and the implementation of effective regulatory frameworks to ensure that the recycling of CRMs is safe, efficient, and sustainable. Therefore, FEAD advocates for concrete measures on the financing of strategic projects from the existing EU funding instruments, such as the Innovation Fund, Horizon Europe, or Life. As the development of new technologies is urgently needed, the existing funds should already be used to finance strategic projects. Looking into the future, dedicated funds for the financing of strategic projects must constantly be in place, as the demand for strategic raw materials will steadily increase. A dedicated fund can be created to this end, which should not exclude financing opportunities from existing instruments, at least in the transition period until the creation of a dedicated fund or system. Such a dedicated fund for CRM should be considered in the negotiations of the next Multiannual Financial Framework for the European Union. The criteria to obtain the funds must be clear and objective, and the procedures must be streamlined. The funding system must be transparent and efficient. In addition, green public procurement is a powerful tool to boost the circular economy and green innovation. As determined by the Commissions Communication of 15 May 2023 on a revised monitoring framework for the circular economy (COM(2023) 306 final), the EU spends around 14% of GDP (around EUR 2 trillion per year) on the purchase of services and goods through public procurement. Therefore, its role should be strengthened under the national measures on circularity (Art. 25(1)(c)) to promote the market for secondary raw materials and stimulate investment in recycling capacities. FEAD welcomes the proposal to streamline permitting procedures for Strategic Projects involving recycling, but these permit granting processes should not exceed 8 months. In addition, the Regulation must ensure that national authorities request all additional information for processing an application at once, and only once, to avoid unnecessary delays. FEAD has repeatedly called for sufficient incentives in the waste management legislation to improve the circularity of critical raw materials and for the development of a strong market in secondary raw materials. New technologies and developments regarding the recycling of critical raw materials urgently need to be supported. Hence, FEAD supports the benchmark set in the Commissions proposal to achieve a recycling capacity that can produce at least 15% of the Union's annual consumption of strategic raw materials by 2030. At the same time, FEAD stresses that recycling capacities and infrastructure are not homogeneous across materials and, as financial support is uncertain at present, it is not appropriate, at this stage, to introduce additional material specific targets (e.g., +7.5% of (recycled) volume for each strategic raw material). The EU should therefore adhere, for the time being, to an ambitious overall benchmark until there is more clarity about the recycling technologies and capacities for the individual strategic raw materials.
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Meeting with Tom Vandenkendelaere (Member of the European Parliament, Shadow rapporteur) and Denuo vzw/asbl

9 May 2023 · Packaging & packaging waste: glass recycling

Waste association FEAD urges inclusion of energy recovery in taxonomy

3 May 2023
Topic — EU consultation on technical screening criteria for the environmental taxonomy regulation.
Message — FEAD requests the inclusion of waste-to-energy recovery and standalone sorting operations in the taxonomy. They also advocate for lowering unachievable recycling targets in construction projects. Finally, they seek longer transition periods for vehicle emission standards.123
Why — Inclusion would unlock green investment for incineration plants and reduce regulatory compliance costs.45
Impact — Environmental groups lose more ambitious recycling goals and stricter pollution control timelines.6
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Waste managers back mandatory recycled content in packaging rules

24 Apr 2023
Topic — EU review of packaging rules to improve recycling and reduce waste.
Message — The industry requests mandatory recycled content targets and prioritization of mechanical recycling. They strongly oppose granting the beverage industry priority access to recycled materials.123
Why — Mandatory targets for recycled materials would boost demand and drive industry investment.4
Impact — Beverage producers lose the chance to monopolize recycled plastics and exclude other sectors.5
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FEAD urges carbon removal certification for waste recycling technologies

23 Mar 2023
Topic — Proposed EU regulation establishing a certification framework for high-quality carbon removals
Message — The framework must include carbon capture and utilisation technologies as removal activities. Certification should cover carbon from waste and products with short lifespans. Organic recovery from biowaste must be explicitly recognized as carbon removal.123
Why — This would ensure financial incentives and investment security for waste management infrastructure.45
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Waste association FEAD supports polluter-pays rules for wastewater

14 Mar 2023
Topic — Updating EU rules to better protect health and environment from wastewater.
Message — FEAD supports the polluter-pays principle to ensure product manufacturers cover the costs of removing micropollutants. They request that animal medicines and microplastics be included in these new responsibility schemes.123
Why — Funding from manufacturers would offset the high costs of installing new equipment.45
Impact — Pharmaceutical and chemical producers would face new fees for their environmental impact.67
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Meeting with Frédérique Ries (Member of the European Parliament, Rapporteur)

28 Feb 2023 · PPWR

Meeting with Luisa Regimenti (Member of the European Parliament, Shadow rapporteur) and Nestlé S.A. and

21 Feb 2023 · PPWR

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

9 Dec 2022

FEAD welcomes the Commissions fitness check aimed at assessing whether EU and national policies ensure polluters bear the cost of measures to prevent, control and remedy pollution. The efficient application of the PPP is of key importance, as it should be the starting point of prevention and depollution. With the EU legislator working at full capacity on the implementation of the Green Deal, the envisaged evaluation of the Polluter Pays Principle should also take into account the future legislative landscape (new and revised legislation) on its potential to comply with the PPP expectations. Please find the complete feedback in the attached position paper.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

7 Dec 2022 · Strategy for Sustainable and Circular Textiles

Response to European Critical Raw Materials Act

25 Nov 2022

The coronavirus pandemic and its economic aftermath along with the current energy crisis resulting from EUs dependency on Russian fossil fuels have only increased the urgency to ensure the security of supply of raw materials to the EU and its strategical independence, as well as to reduce the impacts on the environment due to increased use of CRM in the global economy. Considering the situation, FEAD believes that the recycling potential must be fully exploited in EU policies, and hence welcomes the Commissions stressing the importance of circular economy regarding the supply of critical raw materials to the Union. Consequently, FEAD calls for the inclusion of strong recycling elements that could contribute to addressing those issues. Waste management companies enable the transition to a circular economy by producing material resources from waste which can be re-injected back into the economy. Therefore, to secure a sustainable supply of CRMs, FEAD strongly recommends their recycling. Even though today recycling is not a significant potential source for recovery for all CRMs, studies have shown that the industry has enormous potential to increase the blocs strategic autonomy. FEAD draws attention to the illegal waste shipment of waste containing CRMs to third countries. Every year, millions of tonnes of valuable raw materials disappear from the European markets. In particular, 23 out of the 30 CRMs are regularly contained in WEEE, whose illegal collection and recycling is estimated at 33% across the EU. To this end, FEAD calls for the enforcement of the existing waste shipment rules through improved controls and checks, while ensuring open markets. Improved waste shipments within the EU will serve the objective of facilitating the recycling of CRMs within the EU. FEAD strongly advocated for political actions that level the playing field between primary raw materials and secondary raw materials to ensure the competitiveness of the latter by recognising its positive impacts on climate and circularity, and by internalising the negative external costs of the extraction of raw materials. The environmental added value of collection, sorting, processing, and use of recycled raw materials must be maintained from the initial recycling raw material to the production of end products. As an example of possible incentives, FEAD suggests the idea of the provision of credits for CO2 certificates for recyclers along the whole supply chain. Please see FEAD's full feedback in the document attached.
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the evaluation of the WEEE Directive and supports the objective of the European Green Deal and the new Circular Economy Action Plan. The WEEE management sector is crucial towards sustainability, and even more so today, where recent events are highlighting the strengths and weaknesses of the world's state when it comes to raw materials and supply. WEEE is one of the fastest-growing waste streams which, furthermore, contains precious and critical raw materials, the recovery of which is crucial for a more circular economy and potentially also for EU open strategic autonomy. FEAD knows how delicate and important the role of the waste management industry is in order to achieve ambitious goals and meet the challenges of the present and the future. Therefore, to contribute to the public consultation aiming at evaluating the WEEE Directive, FEAD sets out below its observations, comments and proposals. The current WEEE Directive, and its highly variable implementation in each Member State, often with poor enforcement and the absence of a level-playing field, is not at present providing the ideal regulatory context for sustainable WEEE management health and the environment. One of the major issues raised during the consultation with our members is the need for more harmonisation in Europe. The current WEEE Directive leaves room for different interpretations by individual Member States on how to transpose the legislation at their national level. As a result, the obligations and conditions recyclers face in each Member State vary, contributing to an uneven playing field in a variety of points. Product design is also a key aspect, and it should be directly linked to the ability to carry out proper recycling at its end-of-life. At present recyclers face a number of prominent issues which obstruct adequate processing and thus the fulfilment of expected recycling and recovery targets. With reference to this aspect, consistency with other legislations is crucial to improve the efficacy of the provisions on WEEE and reach the highest recyclability. Another major aspect in which shortcomings and deficits that need to be improved are noted is collection. The improvement and regulation of particular details could help Member States and companies to reach the Europeans collection targets, but also and above all to improve the re-use and recycling of WEEE. WEEE treatment standards are needed to ensure a level playing field within and among Member States and to increase the environmental benefits through a high-quality recycling. Recovery targets regulated in Article 11 of the current WEEE Directive should be more tailored to specific product types and should grant flexibility around the methodologies implemented to reach and promote greater recovery of key CRMs and a higher capture and removal of toxic and hazardous substances and fractions. The entire position of FEAD with more details can be read in the attached document.
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Response to Sustainable Products Initiative

22 Jun 2022

FEAD fully supports the Commission’s Sustainable Products Initiative and its main objectives of reducing the negative life cycle environmental impacts of products, and the improvement of the internal market through a harmonised ecodesign approach. A holistic approach to sustainability through mandatory ecodesign and strong ecodesign requirements is essential as it allows to integrate environmental sustainability criteria in the whole value chain of a product, promoting closed circular life cycles. FEAD notes the following points and highlights that recycling activities should be more clearly addressed in this initiative: ­- Recycling should be clearly mentioned in the definition of “life cycle” ­- Ease of recovery of energy from products should be considered together with material recovery in Article 5(1)(l) as an ecodesign requirement -­ Recycling and disposal should be considered in relation to the information to be provided on products containing substances of concern (Article 7(5)) ­- Recycling and disposal should be specifically and consistently listed among the actors to access the products’ information (Article 8) ­- The waste management sector should be expressly included among the “interested parties involved with the product” that are to be part of the “Ecodesign Forum” (Article 17). For more detailed feedback, please see the attached document.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

The Commission has opened a public consultation on the call for evidence for the review of the Restriction of the use of hazardous substances in electronics (RoHS Directive). This initiative intends to update among others, the provision and procedures on granting/ renewing/ revoking exemptions to substance restrictions as well as the process of reviewing the list of restricted substances. One of the main aims of the review should be the consistency of the preferred option with other pieces of legislation aiming to restrict hazardous substances, e.g. the POPs Regulation or REACH Regulation, as well as the European objectives of a high-quality recycling. Which are crucial to develop a circular economy. FEAD would also like to remind that the chemicals strategy, where the European Commission agreed to look at how to simplify and strengthen the legal framework, foresees a move towards ‘one substance – one assessment’. The review of the Directive is one of the key pillars of an “EU toxic-free environment”, which has to take into consideration all circular economy aspects. In addition to environmental and economic impacts, the impacts on simplification and/or administrative burden/good implementation are particularly noteworthy. The envisaged changes aim to ensure EU has the right regulatory framework to guarantee the protection of health (public health, security at work in the concerned industries, including waste management ones, by reducing the exposure to hazardous chemicals) and environment. While also maintaining the harmonised application of the rules for hazardous substance restrictions in EEE, and reducing administrative costs and burden for Member States, economic operators, and the Commission. What particularly matters to waste management companies is transparency and traceability. No pollutants in the products means no pollutants in the recycling chain, which would achieve the main goal of the review, a toxic-free environment. It could e.g., mean the inclusion of standardization of tests in recycling or also demand a higher transparency in the supply chain. Read FEAD's full statement attached.
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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

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the draft regulation in its intention to promote the development of new recycling technologies and to harmonise the scope and controls on all stages of plastic recycling, facilitating recycled Food Contact Material (FCM) to be placed on the market. However, FEAD believes that the draft does not really meet the announced objectives of the Commission to ‘secure a high level of protection of human health’ as it rather focuses on decontamination methods (which technology/process can decontaminate) instead of considering the final decontamination performance (migration threshold, etc.). Having a tool capable of decontaminating is indisputably necessary but far from sufficient; everything will depend on how the tool is used and maintained. Relevant is the outcome and the residual contamination in the recycled product. A regulation based on performance would allow to achieve both, the protection of human health (i.e., what performance must the secondary raw material have in terms of contamination, which contaminants and what maximum percentage and the technical requirements of further users) and the technical requirements of the secondary raw material. In a nutshell, the draft Regulation provides detailed prescriptions on the definition of decontamination technologies but lacks performance details in terms of contaminants, thresholds, methodology and frequency. The decontamination process is only a mean but not the final goal. Please, find our full position paper attached.
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Response to Update of concentration limit values of persistent organic pollutants in waste

23 Dec 2021

The Commission has proposed amendments to Annexes IV and V to Regulation (EU) 2019/1021 of the European Parliament and of the Council on persistent organic pollutants. This initiative intends to update, for certain substances and groups of substances, the concentration limits set in Annexes IV and V of the POPs Regulation, which determine how waste containing POPs is treated, and particularly if it can be recycled, destroyed, or irreversibly transformed. Protecting human health and the environment from the harmful effects of POPs is the objective of this revision. The challenging question is finding the best policy and time frame option, while ensuring a consistent regulatory framework for EU policy goals. Attempting to eliminate POP substances from the production to end-of-life phase, while at the same time increasing circularity/recycling and reducing greenhouse gas emissions, generates some contradicting rules. Diverging views are raised among FEAD members, based on different choices depending upon the country, and even within some countries, on how to reach the best environmental result with regards to PBDE and HCDD (brominated flame retardants). In some EU countries, a major problem is perceived if large quantities of waste no longer go in the recycling channels., with more performant sorting, screening, tracing, and decontaminating needed to recycle with lower thresholds. Detectablity thresholds would be a critical problem. If waste containing PBDE and HCDD were to be excluded from recycling, then all other WEEE (and other, such as automotive waste) activities would also be compromised, and so would be future investments. This would aggravate serious leaks from POPs and non-POPs in WEEE recycling circuits. Additionally, the CO2 saving potential of 4 tonnes per tonne of recycled plastic compared to virgin plastic would remain untapped. In some other EU countries, some FEAD members advocate for strengthening the zero-pollution based approach, whereby recycling should only happen after full separation/sorting of POPs/non POPs waste. This process requires full traceability, separation, checks, and decontamination. If not achievable, the alternative to zero-pollution is incineration in dedicated installations. To conclude we return to the introduction point: finding the right balance between eliminating POP substances from the environment, and the appropriate thresholds and timeframe, while at the same time, increasing circularity and recycling. FEAD is aware of the environmental challenges posed by POPs and asks the EU legislator to tackle the industrial dimension of this issue. New thresholds pose a problem, especially in EU member states where the technology or where the needed capacities do not exist, because our industry needs enough time to deploy these essential capacities.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

FEAD welcomes the European Commission’s proposal for reviewing the 2018 Renewable Energy Directive (REDIII) and adjusting its rules to the latest EU climate ambitions for 2030. Therein, FEAD supports the unchanged definition of ‘waste heat’, considering that the activities of hazardous and non-hazardous waste installations are producing waste heat, when recovered by efficient district heating and cooling systems. Nevertheless, FEAD encourages the legislator to extend the definition of ‘waste heat and cold’ under the RED also to other uses, apart from district heating or cooling systems. FEAD further encourages the EU legislator to promote the recovery of waste heat by ensuring that Member States support it in the same way as renewable energy in heating and cooling. In this line, the 49 % target of share of energy from renewable sources in buildings by 2030 in the proposed Article 15a RED should also ensure that the use of all waste heat promoted, whatever its origin. This would be fully consistent with the revised definition of ‘efficient district heating and cooling systems’ in the new Art. 24 of the Energy Efficiency Directive recast. Private waste management companies have a positive role to play on the renewable energy production, in particular as regards thermal energy. For this reason, FEAD welcomes the explicit recognition of waste-to-energy activities in the proposed new Article 3(3)(a)(ii) RED, with biodegradable waste as a renewable energy source, including the necessary observance of the waste hierarchy and separate collection obligations as a requirement for its support by the Member States. At this point and for the sake of consistency within the EU climate policy in this respect, we would like to reiterate the importance of the inclusion of such waste-to-energy activities also in the EU Taxonomy as an activity substantially contributing to (a transition to) a circular economy. FEAD also welcomes the fact that electricity, heating and cooling produced from municipal solid waste is not subject to greenhouse gas emissions saving criteria under Art. 29(1)(10) RED. However, for the sake of consistency and clarity, this exclusion should not be limited to municipal solid waste only, since there are different interpretations across the Member States about this terminology. In fact, the calculation methods in Art. 31(1) RED for the emissions saving under Art. 29(1)(10) RED are not intended for the direct production of electricity, heating and cooling from waste, but for the use of biofuel, bioliquids and biomass fuels. Otherwise, new calculation methods should be developed to calculate the greenhouse gas emissions savings e.g., from waste wood directly used to generate energy, heating or cooling. In any case, to guarantee legal security, the greenhouse gas emission savings under Art. 29(10)(d) should continue to apply only to installations starting operation from 1 January 2021. Finally, FEAD considers it is important to preserve the current definition of ‘biomass’ under Art. 2(24) RED. Renewable and low-carbon fuels should cover the biodegradable fraction of Solid Recovered Fuel (SRF) or Refuse Derived Fuel (RDF), which have a virtuous role to play, being composed from more than 70% of biogenic content according to a recent study from the French Energy and Environment Agency . In this line, the definition of ‘renewable fuels of non-biological origin’ should also include biomass coming from waste, in accordance with its carbon neutrality and the fact that it does not involve the adverse effect of deforestation, but rather promotes circularity.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As previously stated, FEAD welcomes the legislative package proposed, which delivers the crucially needed changes to achieve a fair, competitive and green transformation. With regards to the Energy Taxation Directive (ETD), FEAD supports the fact that, under Article 16 of the proposed recast ETD, both electricity and products from biomass can be considered by Member States for tax limitations and/or exemptions. FEAD considers it important to preserve the current definition of ‘biomass’ under Art. 2(24) RED. Renewable and low-carbon fuels should cover the biodegradable fraction of Solid Recovered Fuel (SRF) or Refuse Derived Fuel (RDF), which have a virtuous role to play, being composed from more than 70% of biogenic content according to a recent study from the French Energy and Environment Agency(1). However, a legal definition of ‘sustainable biomass’ is needed. To ensure clarity, the biodegradable fraction of waste, including municipal, industrial and commercial waste, should be considered for taxation purposes in consistency with the RED, and considering its carbon neutrality, as ‘sustainable biomass’ in any case. Generally speaking, biofuels should be taxed according to its carbon footprint as carbon neutral fuels, meaning zero taxation. Pursuant to the present proposal, low-carbon fuels resulting from waste should be positively treated in the EU energy market compared to fossil fuels, as they avoid the consumption of fuels with a higher carbon footprint. (1) https://librairie.ademe.fr/energies-renouvelables-reseaux-et-stockage/4007-determination-des-contenus-biogene-et-fossile-des-ordures-menageres-residuelles-et-d-un-csr-a-partir-d-une-analyse-14c-du-co2-des-gaz-de-post-combustion.html Determination of the biogenic and fossil contents of residual household waste and of SRF, based on a 14C analysis of the CO2 of post-combustion gases – November 2020.
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FEAD urges CBAM to close recycled material price gap

18 Nov 2021
Topic — The European Commission is consulting on a mechanism to price carbon on imported goods.
Message — FEAD supports the mechanism as a tool to prevent carbon leakage and promote recycling. They request the policy help close the price gap between recycled and virgin resources. Additionally, they propose a carbon label to highlight the low emissions of recycled products.12
Why — This mechanism would increase demand for recycled goods by making them more competitive against imports.3
Impact — Producers of virgin materials would lose their competitive price advantage over recycled alternatives.4
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As previously stated, FEAD welcomes the legislative package proposed, which delivers the crucially needed changes to achieve a fair, competitive and green transformation. In relation to the Energy Efficiency Directive (EED recast), FEAD welcomes the alignment of the energy efficiency targets with the 2030 EU climate ambitions and supports the definition of ‘efficient district heating and cooling system’ in the new Art. 24 of the EED recast, which confirms the positive status of waste heat in the energy mix of efficient district heating and cooling systems in the future.
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

8 Nov 2021

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the opportunity to comment on the “Fit for 55” Package proposal by the European Commission. As an introductory remark, FEAD highlights that the waste management sector, as a whole, is not only a key enabler of the Circular economy, by giving a second life to resources from waste, but is also an essential actor in the reduction of CO2 emissions, avoiding emissions from manufacturing and energy activities by allowing them to use materials and energy derived from waste. With regards to the revised EU Emission Trading System (EU ETS) and Effort Sharing Regulation (ESR), FEAD sees the increased effort to reduce emissions of the whole waste management sector as an engagement we are ready to continue to take under the Effort Sharing Regulation, with a significantly higher level of CO2 constraint. The ESR is a more appropriate tool for the sector compared to the EU ETS, although we see some different approaches in MS. The whole waste management sector accounts for numerous SMEs for which the ETS was not designed in consideration of its high administrative burden. This is also the case for waste-to-energy activities, under which there is a vast number of small sized plants using solid recovered fuels (SRF). Co-incinerators (manufacturing or energy sector), if > 20MW, are currently included in the ETS while municipal incinerators are not. The logics behind this is that the latter emit CO2 depending upon the carbon content of the waste they receive, and, as R1 qualified, avoid the use of fossil fuels for producing heat/electricity. In this context, FEAD would like to remind the very small part of the Waste Management in GHG emissions accounting for 3% of the total EU emissions in 2017, and for 1,5% as far as energy from waste is concerned. Furthermore, FEAD would like to highlight three key messages: • First, the waste management sector avoids GHG emissions, in wider proportions than it emits (secondary raw materials and energy recovery, biological recovery), directly contributing to the decarbonisation. Especially, the recovery or the recycling process from waste avoids the emissions that would have otherwise been used in extracting and manufacturing raw materials. As a matter of fact, the carbon footprint of recycled PET is 90 % less than its virgin counterpart, for textiles it is 98%, for steal up to 85%, aluminium 92%, paper 18%. Waste-to-Energy avoids the use of fossil fuels (at least in a transition period where the RES penetration is still weak) by producing heat and electricity with waste-based energy that is RES for approximately half of municipal waste. • Furthermore, regarding GHG emissions, the whole waste management sector should be addressed in a single piece of legislation. Waste management has for main purpose to treat waste while ensuring sanitary and environmentally sound management by minimising its potential impacts on soil, air, water and, ultimately, human health. These healthy and sanitary goals should always prevail over further climate targets even if the waste sector shall continue its previous efforts which have enabled to decrease by 42% its emissions between 1995 and 2017. • Finally, we are concerned that the additional effort of the new ESR proposal (from - 30 to - 40% CO2 reduction, baseline 2005) can lead to a lack of level playing field by a heterogeneous implementation between Member States of this new target, with measures such as taxation (Scandinavia) or other tools having proven problematic. This would cause competition distortion, which has to be avoided. In a nutshell, a strengthened ESR is the right holistic tool to reduce waste related GHG emissions while maximising the full potential of avoided emissions. Ensuring a fair competition at the European level between Member States must remain a key goal.
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Waste Industry Urges EU to Keep Emission Rules Under ESR

8 Nov 2021
Topic — EU proposal to scale up emission reductions and review the Emissions Trading System.
Message — FEAD wants the waste sector to remain under the Effort Sharing Regulation rather than the EU ETS. They argue the ESR is more appropriate and that the sector is ready to meet stricter emission targets under ESR.123
Why — This would avoid high administrative burden and potential costs from the ETS for their many small and medium-sized member companies.45
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

FEAD, the European Waste Management Association, supports the aim of the initiative to establishing a clear definition and overarching principles applying to both biobased plastics (BBP) and biodegradable and compostable plastics (BDCP) considering the circular economy and waste hierarchy principles. It is important to make a clear distinction between bio-based, biodegradable and compostable plastics, recognising that some bio-based plastics are not compostable, and some compostable plastics are not bio-based, and that not all biodegradable plastics are truly and safely compostable. The roadmap addresses the sustainability of the biological feedstock used to produce BBP, that can help reduce the life-cycle environmental impacts of plastics by using biological feedstock instead of fossil fuels. FEAD wants to highlight this. BBP and BDCP has no EU sustainability criteria nor any appropriate standards that are supported by sound scientific testing, meaning that a variety of formulations and lack of regulations do not guarantee environmental and market performances. Another problem the initiative aims to tackle and also welcomed by FEAD, is the effective biodegradation of BDCP and their role in a circular economy. So far, no standard exists for biodegradable plastics in other media such as the marine environment. Biodegradable and compostable plastics only bring environmental benefits when there is a clear co-benefit: separating more bio-waste from residual waste and when they do not degrade the quality of organic waste. Given these points there should be an assessment framework with clear criteria that assesses in which applications the use of biodegradable and compostable plastics is indeed beneficial to the environment. In other cases, the use of biodegradable and compostable plastics should be avoided. FEAD welcomes also the aim of the initiative to clarify measurement method and labelling of BBP as well as the role of testing, labelling, certification to ensure effective biodegradation, alignment with existing disposal infrastructure, and avoiding consumer confusion for BDCP. We also agree with the Commission that without EU action, the identified environmental and market problems would worsen. Consequences for the environment would aggravate, as the number of not fully sustainable alternatives would increase in the absence of clear and verifiable sustainability requirements. Alternatives to conventional fossil-based plastics could offer environmental benefits. However, this is on the condition that they have been developed in compliance with EN standards, that they are clearly bringing environmental benefits and that there is a collection and treatment infrastructure in place to manage them. As this is often not the case for biodegradable and compostable plastics, promotion and marketing of biodegradable and compostable plastics at this stage is premature. Recycling of biobased plastics should therefore be favored over biodegradation, which only provides sustainable benefits in very specific applications. In respect with the waste hierarchy, recycling is even better than recovery. Please find the detailed feedback from FEAD attached.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Revision of EU legislation on hazard classification, labelling and packaging of chemicals which aims at protecting people and the environment better against hazardous chemicals and at encouraging innovation for the development of safer alternatives. In the Green Deal, the European Commission targets two essential goals in the handling of substances and materials known as “non-toxic environment” and “circular economy”. There are numerous interfaces in product, waste and chemicals legislation in these two areas. The CLP Regulation does not distinguish between substances coming from virgin material or those from recovered material. The same obligations of notification, labelling and packaging apply from the moment a substance ceases to be ‘waste’ until it becomes waste again. The main challenge when a new cycle starts is to ensure that a hazardous chemical present in recovered materials is identified as such. From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs: Information flow Information is needed by waste management companies on the hazardous properties of the substances contained. Moreover, if waste is intended to be recycled into secondary raw materials, a holistic view is needed. However, this is obstructed by a loss of information along the path from chemical to product to waste. With regard to post-consumer waste, in most cases composition can only be determined by means of extensive analyses and can vary considerably from batch to batch (e.g. mixtures of waste wood, mixed construction waste). Since such extensive analyses are very costly, the correct classification and subsequent treatment of such waste can mostly be achieved by collecting all available information. • The transfer of information from waste producer to waste processor is indispensable for correct classification in accordance with the EWC and further treatment of the waste. Even without this information, existing waste legislation requires classification according to the (assumed) substance-inherent hazard characteristics. Conclusions The new Circular Economy Action Plan set ambitious recycling targets, and to this extent FEAD asks the Commission to strike the right balance between these ambitious recycling targets and the phasing out of hazardous substances.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals which aims at protecting people and the environment with regard to hazardous chemicals, and at encouraging innovation for the development of safer alternatives. From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs: Substances of Very High Concern The Candidate List of substances of very high concern now contains 211 chemicals that are considered as potentially or effectively harming people or the environment. With increased scientific information on chemicals available, the number of SVHCs and substances subject to authorisation will only continue to grow. The waste and resources management industry is committed to treating waste in an environmentally sound manner, avoiding legacy substances and decontaminating waste. This includes not only the application of Best Available Techniques to abate air and water pollution from waste treatment activities, but also possibly the phasing out of hazardous substances in recyclates. A number of processes have been developed by the private waste management sector in order to ensure eliminating certain substances which have an effect on human health and on the environment. While fully supporting the Commission's goal of better protecting citizens and the environment from hazardous chemicals and strengthening the internal market, bans on substances must not be based solely on intrinsic substance properties. The risk-based approach based on a sound scientific basis allows for adequate risk management and should be maintained. It is crucial for ensuring material efficiency, energy efficiency and the reduction of GHG emissions within the circular economy in due respect of environmental and health considerations. Conclusions FEAD asks the Commission to better align the potential of circularity with the fact that products which have undergone EoW procedures may contain substances or mixtures covered by CLP or legacy, restricted, banned hazardous substances.
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Response to Protecting the environment in the EU’s seas and oceans

6 May 2021

FEAD’s full feedback on the Roadmap is attached. FEAD welcomes the review process of the Marine Strategy Framework Directive (MSFD), yet we find that the Directive needs more coherence with the Single-Use Plastics (SUP) Directive and in general with all the EU Waste Legislation, as well as a stronger focus on the very first step to avoid marine pollution, which is waste collection. The European private waste management sector, represented by FEAD, has a clear understanding of the environmental, health, and economic impacts of marine pollution, especially due to plastics, microplastics, and nano-plastics. We strongly advocate for having a regulatory framework at the EU level resulting in the sound management of the plastic waste generated. 1. Waste collection, recycling, recovery Excessive plastic needs to be replaced by a circular model, whereby plastics that have already been introduced in the economy, remain in there through recycling and recovery. A stronger focus needs to be given to plastic that finds its way out of the waste treatment process. That is the case especially for single-use plastics, which is a major factor in the amount and growth of microplastics. To prevent leakage of plastic waste and consequently of microplastics we absolutely need better and stronger collection, separation, and recycling rates and systems. A shock on demand for plastic recyclates is one of the primary conditions for enhancing recycling. This can be achieved by regulatory tools, i.e., mandatory recycled content rules and mandatory Green Public Procurement rules, and also by new investments along the plastic waste value chain. The significance and effectiveness of mandatory recycled contents are illustrated in the SUP Directive. 2. A comprehensive plan for micro-plastics It is indispensable to have a clear understanding and distinction between biodegradable and bio-based plastics. Most plastics do not degrade but end up in smaller pieces, i.e., microplastics and nano-plastics. The efficient way to tackle microplastics and nano-plastics is through a comprehensive plan. With regards to the contamination of marine organisms by small plastic particles and their chemicals which, despite all measures taken to avoid plastic waste, may still end in oceans, we underline the importance of eco-design, to avoid the use of hazardous substances from the very start of the product value chain. A recent study commissioned by EP PETI Committee and entitled “The environmental impacts of plastics and micro-plastics use, waste and pollution: EU and national measures”, finds that “in Europe, € 630 million are spent every year to clean plastic waste from coasts and beaches while the failure to recycle costs the European economy € 105 billion”. This money should be used to strengthen proactively the waste management activities, especially when exporting plastic waste to third countries tends to be out of the picture. 3. Intra-EU plastic waste shipments more than ever needed Safe and efficient intra-EU plastic waste shipments are crucial for the circular economy and respectively for preventing leakages to the environment. No EU country has the full plastic waste management and recycling chain on their territory, not even the larger and more industrialised Member States. Exports are crucial in the logistic chain of waste management and recycling, to ensure all the needed steps in the recycling value chain can be operated across the EU without unnecessary administrative burden, delays, costs that would result from the extension of the notification-based procedure for shipments, instead of the green-listed one that was in force until the end of 2020. The EU must also intensify the efforts against illegal exports and waste crime, including illegal waste handling. 4. Enhancing international cooperation The EU should enhance the international cooperation and coordinated action in delivering the international commitments to protecting the marine environment an
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

FEAD welcomes the proposal. Our main comments to it: -Lack of a mandatory deposit refund system Incorrectly disposed Li batteries pose a high risk to people and the environment. It is necessary to return 100% Li batteries from a wide variety of waste streams to the battery collection.This can only be achieved through a mandatory return for particularly critical material flows, in addition to a high collection rate for all device batteries. -Mandatory recycled content We welcome the introduction of an EU-wide roll out of mandatory recycled content. However, the effective functioning of a circular economy requires mandatory recycled content to apply to all kind of batteries, including portable batteries, as well as higher levels of recycled content in new batteries FEAD calls for an earlier determination of the methodology for the calculation and verification of recycled content to be able to adapt recovery processes accordingly - Increased recycling and recovery targets We welcome ambitious recycling efficiency and material recovery targets. On the proposal, we consider that targets for recycling efficiency are very high and may be difficult to achieve. Their achievement depends upon the rules for calculation and verification. On their determination, FEAD stresses that a differentiated approach is needed between portable batteries and all other categories of batteries, and also different chemical types of batteries FEAD reminds that it is also necessary to establish a performant data gathering including quality of recycling to create a level-playing field among recyclers in Europe. Low carbon footprint recovery processes should be supported -Ensuring higher collection FEAD welcomes the increase of portable battery collection targets. However, for achieving proper handling and correct disposal of batteries, higher collection targets of 80% for all types of batteries are needed, excepting for automotive batteries for which collection targets of 100% should apply. In a context of a constantly growing market for batteries powering light means of transport, FEAD urges the European legislator to include those batteries into the same collection targets as portable batteries as soon as possible -Eco-design, marking and hazardous substances EEE that can be operated on batteries must be designed in such a way that waste from them can be removed easily without tools by end users only, discharged without prior pack-disassembly and can ensure easy access to a hole for the fire-hose Uniform marking of devices helps consumers use and handle correctly the devices and accumulators, to safely remove batteries and to ensure a proper disposal. On labelling, FEAD supports the setting up of colour coding for batteries to facilitate their sorting and collection -EPR schemes FEAD stresses the necessity to take into consideration the existing and successful B2B schemes/contracts that provide for collection, sorting, treatment and recycling. The extension of EPR schemes remain a tool for waste flows that are more difficult to capture, for instance originating from HHs. Collecting and recycling industrial batteries should remain under open market rules, which have proven to be efficient in delivering optimized investments and services -Enforcing the control of illegal movements of battery waste FEAD calls for an effective control and enforcement mechanism for the exports of used batteries to avoid illegal shipments -Responsibility for sales via online marketplaces FEAD welcomes the requirements for distributors to provide end-of-life information on batteries through their online marketplaces. But this does not solve the problem of uncovered costs of the EPR scheme on batteries. To address this free-rider problem, level playing field must be restored between online marketplaces and stationary retailers in EU. The same rules must apply to producers, distributors, online marketplaces or fulfilment companies as to stationary retailers Full position attached
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Response to EU strategy for sustainable textiles

2 Feb 2021

FEAD, the European Waste Management Association, welcomes the European Commission’s initiative on sustainable textiles. In the last 15 years, production and per capita sales of clothing have approximately doubled while clothes utilization has declined. As of its current state, the textile sector, despite its efforts, entails significant environmental costs, without internalising the external costs created to the environment and to society. Thus, margins for improvement exist, especially for what concerns the end of life of clothes; across the industry, only 13% of the total material input is, in some way, recycled after clothing use From a waste management perspective we would like to stress the following needs: Ecodesign measures There is a need to transform the way clothes are designed, sold and used to break free from their increasingly disposable nature. Garments have to be durable, reusable and recyclable Moreover, there are acknowledged hazardous substances in textiles that must be phased out In order to improve recyclability of garments, the following general rules should be kept in mind: -phase out substances of very high concern and microplastics -reduce the use of composite fibers to an absolute minimum -use recyclable polymers or natural fibers as much as possible -the parts made from different materials should be removable Boost the European textiles’ industry We recognize a huge need to boost the textile industry within the EU in order to increase environmental and economic sustainability and self‐sufficiency There is also the need to build up a stable and competitive market for recycled materials in Europe through an EU‐wide introduction of mandatory recycled content rules in products, as well as sustainable ecodesign measures Mandatory recycled content rules Mandatory recycled content in products is essential for the creation of a stable and competitive market for recycled raw materials in Europe. The mandatory integration of recycled content in textiles/clothes will boost the recycling market in Europe, foster investments in innovative recycling technologies and decrease the environmental footprint of textiles In order to guarantee a level‐playing field, minimal recycled content should also be mandatory for imported textiles EPR schemes FEAD welcomes EPR scheme on textiles keeping in mind the following rules: -the fees applied to products should be modulated according to environmental criteria -if Member States are to implement separate collection systems with ambitious recycling targets, there is a need for good data to calculate recycling quotas -there is a need to subsidise beacon projects for textiles recycling In the context of setting up EPR schemes, due consideration should be taken of existing performant B2B contracts between producers and the waste management sector Green Public Procurement Green Public Procurement in textiles (such as uniforms, workwear, towels, linen, etc.) can be improved in selection criteria of public procurement processes. When assessing ability to perform a contract, contracting authorities should take into account specific properties related to environmental aspects. This includes, for example, recyclability or recycled content of procured textiles Enforcing the control of illegal movements of textile waste The EU should set up an effective control mechanism for the exports of used textiles, in order to avoid illegal shipments and to ensure proper environmentally sound recycling/recovery processes outside EU Set EU reuse and recycling targets Set EU harmonised minimum re-use and recycling targets Harmonised end-of-waste criteria Harmonised EoW criteria at EU level are needed both after recycling and preparation for reuse in order to support the development and marketing of secondary raw materials or products Reaching the end-of-waste status leads to a higher market acceptance at EU and global level of the treated material compared to when it is still labelled as waste
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Response to Environmental impact of mobile phones and tablets - Energy Labelling

27 Jan 2021

FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. Private waste management companies operate in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. FEAD welcomes the European Commission’s proposal for a Commission implementing Regulation on Ecodesign for mobile phones and tablets, fully in line with the Green Deal and the new Circular Economy Action Plan. From a waste management perspective, FEAD deems this proposal in the right course of action to achieve the circular economy with more and more ambitious targets in terms of quantity and quality, and we would like to highlight the following needs: • Ecodesign While designing mobile phones and tablets, their end of life should be kept in mind: they must be durable, reparable, dismantlable and recyclable. The average lifespan of a smartphone is two-three years and the reasons for the early replacement of the device we live with all day, are different: fashion, the rapid evolution of technology (everything gets old in a short time) and industrial logic. Nowadays repairing smartphones and tablets in case of breakdown is almost impossible because companies design them inaccessible. They are not designed to be repairable, with unobtainable spare parts and without manuals that favor any intervention. Regarding recyclability of mobile phones and tablets, in order to improve it, the following general rules should be kept in mind: • phase out substances of very high concern; • try to substitute as much as possible critical raw materials; • make parts easy dismantlable trying to use less glue as possible and more joints; Incorrect disposal and untargeted collection of batteries and accumulators pose a high risk to people and the environment through fire incidents in waste sorting systems. Mobile phones and tablets using batteries or accumulators must be designed in such a way that batteries’ waste derived from them can be removed easily by any end consumer, discharged without prior pack-disassembly and ensure easy access to a hole for the fire-hose as fires are the main problems of mobile batteries’ waste.   • Marking Uniform marking of devices is also crucial to help consumers use and handle correctly the devices, to safely remove components and to ensure a proper and ecologically sound disposal. • Hazardous substances We recommend the restriction in the use of hazardous substances in mobile phones and tablets to protect human health and the environment and to reduce the presence of such substances in waste, allowing for a safe recycling at reasonable costs. • Recycled content Supplies of rare elements used in the manufacturing of mobile phones, tablets and PCs are at risk of exhaustion because older devices are not being recycled and elements such as indium, yttrium or tantalum could run out within a century as stocks deplete. Therefore recyclability and market of recyclates must be boosted within the sector. It is estimated that for one million cell phones that are recycled, 16,000 kg of copper, 350 kg of silver, 34 kg of gold and 14 kg of palladium can be recovered. Mandatory recycled content in products is essential for the creation of a stable and competitive market for recycled raw materials in Europe. The mandatory integration of recycled content in mobile phones and tablets will boost the recycling market in Europe, foster investments in innovative recycling technologies and decrease the environmental footprint of the product. In order to guarantee a level‐playing field, minimal recycled content should also be mandatory for imported goods. • Enforcing the control of illegal movements of mobile phones and tablets’ waste FEAD calls for an effective control and enforcement mechanism for the exports of used mobile phones and tablets to avoid illegal shipments and to ensure environmentally sound treatments.
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Response to 8th Environment Action Programme

31 Dec 2020

Please, find FEAD’s full feedback attached. FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. FEAD welcomes the European Commission’s proposal for a Decision for the 8th Environment Action Programme (EAP). We deem that the 8th EAP should be an effective and high-level strategic tool guiding environmental policy to accelerate the EU’s transition to a climate-neutral, resource-efficient clean and circular economy in a just and inclusive way and achieve the environmental objectives of the UN SDGs, the Paris Climate Agreement (COP21, 2015), and the European Green Deal (EGD). The Proposal highlights among others the important role that the European Environment Agency (EEA) and the European Chemicals Agency (ECHA) ought to play in the implementation of the new EAP. Thus, the EU Chemicals Strategy for Sustainability and the Zero Pollution ambition will be at the heart of the Programme. The European private waste management sector, represented by FEAD, will play a significant role in realising those strategies and in achieving the objectives laid down in Article 2 of the proposed decision. A prerequisite for achieving any targets is the valuation of natural resources, based on the valuation of their non-recoverability and the damage, caused by their exploitation. In that sense, the need for increased efficiency of materials and recirculation of high-quality materials is vital, thereby making the circular economy’s role in the reduction of GHG emissions from raw material extraction, from products’ manufacture and use, and from other economic activities, and in minimising resource consumption crucial. The circular economy itself is embedded in waste management activities, meaning that the waste management sector and the circular economy’s contribution to the “green transition” go hand in hand. Currently, half of greenhouse emissions result from resource extraction and processing. Strong recycling policies leading to significant savings in resources and energy, while avoiding CO2 emissions, can make a significant difference along the product value chain. However, to fully achieve the sustainability of products and services, ambitious and environmentally sound waste management practices must be fostered. We now expect the EU to set up the needed conditions allowing the waste management industry to act as their key ally in the ambitious environmental and climate goals of the EGD and the EU Climate Law. Waste management activities are at a crossroads with several challenges that the 8th EAP must respond to: • Making the best use of all resources, by optimising the material recovery of recyclable/recoverable waste as well as the energy recovery of non-recyclable waste; • Facilitating recycling, or even making it feasible, through binding rules on eco-design, including phasing out of Substances of Very High Concern (SVHCs). To improve the protection of human health and the environment from the risks that can be posed by chemicals, the EC needs to strike the right balance between recycling/recovery policy as proposed by the new Circular Economy Action Plan and the aims of chemicals/products legislation. • Acknowledging the positive role recycling and material recovery activities play in avoiding CO2 emissions from the manufacturing sector, and recognising that the entire waste management chain results in avoiding more CO2 than it emits; • Boosting recycling markets and granting a competitive advantage to recycled/recovered materials, with higher taxation of the CO2 and the energy content of fossil fuels. FEAD is committed to the objectives of the European Green Deal and considers the above-mentioned aspects apt for providing the adequate stimuli both for addressing GHG emissions and enhancing of the circular economy in Europe.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

FEAD – the European Waste Management Association – stresses the importance of considering the views of the private waste management sector as a significant contributor to the transition towards circular economy and climate neutrality. Our full contribution and amendment proposal are in the attachment to this contribution. From a legislative point of view, we expected the second delegated act on activities substantially contributing to circular economy to cover our activities, instead of the current under consultation, which covers activities substantially contributing to climate mitigation and adaption. This is clearly stated in Regulation 2020/852 in its art. 13 (rationale explained in the attachment). Concerning preparatory work, FEAD stresses the need to properly consult the waste management sector for activities whose classification will strongly impact our operations across Europe. - On R1 waste-to-energy activities, FEAD has been continuously advocating for the inclusion of waste-to-energy activities as substantially contributing to the transition towards a more circular and climate neutral economy. While we understand that the second delegated act foreseen under Directive (EU) 2020/852 art. 12(c) and 13(c) will cover activities contributing to circular economy, we regret to see that the inclusion of waste-to-energy activities, complying with the R1 criterion , are still left out. We would like to remind the Commission that recovering the energy from non-recyclable non-recoverable waste should be regarded as an environmentally sustainable economic activity. In particular: -R1 waste-to-energy installations allow net reduction of CO2 emissions by generating heat/electricity, which would be otherwise produced by fossil fuels’ sources. Existing waste incineration BREFs ensure these activities operate under the safest levels of emissions. -A recent study (see attachment), projecting scenarios of ambitious targets for municipal waste for 2035, illustrates that the EU will face a capacity gap of approximately 41 Mt for the treatment of residual (non-recyclable) waste. - As conditions, selective collection and sorting schemes for waste undergoing a waste-to-energy solution, as well as sound national waste management plans, should be mentioned as technical criteria able to ensure that waste-to-energy activities contribute to the objectives of the taxonomy. Concerning Annex I: - On point 5.6 and 5.7 on "anaerobic digestion of sewage sludge and bio-waste", the Do no significant harm criteria on climate change mitigation “(1) a monitoring plan is in place for methane leakage at the facility” should clearly mention that such monitoring plans must be suitable to minimise the methane leakage from the facility. More information on this point in the attachment. - on point 5.9 on "material recovery from NHW", it should be clearly specified that both “entire facilities as well as dedicated production lines for the sorting and processing of separately collected NHW streams in secondary raw materials " should be covered by this section. More information attached. -On point 5.10 on "landfill gas capture and utilisation", the scope of the activity covered should be extended to legacy landfills and to closed landfill cells in operational landfills. It is key to consider “closed landfill cells” as already specified in screening criteria 2, in line with the operational functioning of landfills. FEAD insists on the absolute necessity for landfills either in operation or closed, to be equipped with landfill gas capture to reduce landfills’ GHG impact. FEAD proposal for amendment and related rationale is attached. - On point 3.16 on "manufacture of plastics in primary form" the criterion (b) on chemical recycling is not formulated in a way that allows to prove substantial contribution to pollution prevention and circular economy. FEAD amendment proposal and related rationale is attached.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

10 Dec 2020

Please, find attached FEAD’s full feedback to the EC Roadmap on State aid. FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. Private waste management companies operate in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. FEAD welcomes the initiative for the revision of the Energy and Environmental Aid Guidelines (EEAG). Following up on our feedback to the fitness check of the General Block Exemption Regulation (GBER), De minimis Regulation, Regional aid Guidelines, Research, Development and Innovation (RDI) Risk finance, and the EEAG, in 2019, we point out once again that we advocate for the increase of the notification threshold, while ensuring that state aid covers all activities of the circular economy. In particular: 1) Notification thresholds The notification threshold of 15M Euros per environmental protection investment project as laid down by the General Block Exemption Regulation should be increased (article 4 of the GBER). Indeed, regarding recent developments of waste management investments, the notification procedure has become burdensome, as it fails to consider new challenges faced every day by the waste management industry: - Bigger installations to be considered. For instance, sorting plants tends to be bigger, in order to generate economies of scale. - The technologies used in our facilities are more expensive (optical systems, digital systems, sorting technologies, etc.) - Multiple waste management facilities may combine different activities in one site (sorting, composting, recycling installations, waste recovery installations, etc.) - Construction costs are higher (nowadays construction of sorting plants is far more expensive than in the past) since the last revision of the GBER (2014). Recommendation: An increase of the threshold should be considered and analysed. 2) State aid should cover all chains of the circular economy Reaching the ambitious recycling targets will mean further and consequential investment in waste management facilities. Public support in investments in selective collection and in recycling facilities is particularly needed, in order to help the recycling chain and its outcome, the secondary raw materials, to be competitive against virgin materials, and in recovery installations. Each type of waste must be treated according to the Waste Hierarchy. Prevention, Re-use, or Recycling of waste is, by order of priority, the way forward to achieve a circular economy. All activities of the circular economy should be eligible for state aid when aligned with the waste hierarchy. As the recycling chain results in a certain amount of residual waste which cannot be recycled after collection and sorting, or as there are waste flows that are initially not recyclable (e.g. waste containing substances of concern), the energy content of such non-recyclable waste or residues can be used in Waste-to-Energy processes, including Solid Recovered Fuels (SRF). Regarding Waste-to-Energy, heat recovery from non-recyclable waste should remain eligible for state aid Recommendation: The following should remain eligible for state aid: • all waste management activities, when aligned with the waste hierarchy, as stated in chapter 3.3.5 of the EEAG, whether material-based (e.g. recycling, composting) or energy-based (R1 Waste-to-Energy installations, SRF sector, methanisation), • energy from renewable sources using waste, including waste heat, as input fuel, provided that it is in line with the principle of waste hierarchy (paragraph 118 of the EEAG); • anticipating adaptation of waste management installations to new legal technical requirements (e.g. new BREFs). State aid can make a positive contribution to environmental protection in all the above cases.
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FEAD urges EU to keep waste-to-energy out of ETS

26 Nov 2020
Topic — The European Commission is reviewing the EU Emissions Trading System to increase greenhouse gas reductions.
Message — The organization insists that Waste-to-Energy installations must not be encompassed by the EU ETS. Instead, the whole waste management sector should be addressed in a single piece of legislation, the Effort Sharing Regulation.12
Why — The organization avoids higher operational costs and the burden of potential double taxation on waste tonnages.3
Impact — Recyclers would suffer from higher costs for treating their residual non-recyclable waste materials.4
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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

FEAD, the European Waste Management Association, represents the private waste and resource management industry across Europe. Private waste management companies operate in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. Waste management causes a significant reduction of CO2 emissions by producing secondary raw materials used in manufacturing that helps to minimise resource consumption, and by utilising the energy content of residual, non-recyclable waste to produce heat/electricity. The recovery/recycling process from waste avoids the emissions that would have otherwise been used in extracting and manufacturing raw materials. Waste-to-energy processes avoid the use of fossil fuels and thus significant CO2 emissions, and ultimately, using environmentally sound disposal ensures the safe treatment of residues that cannot be otherwise recycled or recovered. Currently, half of greenhouse emissions result from resource extraction and processing . Strong recycling policies leading to significant savings in resources and energy, while avoiding CO2 emissions, can make a significant difference along a product value chain. Favouring recycled materials over raw materials is the best way to do this. As a matter of fact, the carbon footprint of recycled PET is 90 % less than its virgin counterpart, for textiles it is 98%, for steal up to 85%, aluminium 92%, paper 18% . As a major accessory for ambitious recycling targets, Waste-to-Energy has a part to play by avoiding CO2 emissions for non-recyclable and residual waste. The entire waste management chain avoids emissions in much larger quantities than it produces. A more ambitious regulatory framework to boost recycling and recovery, as proposed by the EU Green Deal, would foster a positive contribution by this sector and help deliver the decarbonisation of the European Union and create a more circular economy. As far as CO2 emissions are concerned, it is crucial to address the waste management sector as a whole, to reflect the need for an integrated approach-based waste management, to fully take into consideration the waste hierarchy, and to privilege the most efficient regulatory instruments to address the still untapped potential of recycling and recovery. The Effort Sharing Regulation (ESR), which currently covers the whole waste management sector, will require increased CO2 emission reduction. Achieved by a set of relevant national measures incentivising waste treatments high up the Waste Hierarchy: regulations, taxation, and public support for investment in selective collection, recycling facilities, and recovery of residual waste. Achieving the ESR goals in our sector implies Member States to take all the needed measures to fully implement the Waste Hierarchy, with strong measures needed in countries where landfilling is by far still the most important waste treatment route even for recyclable and recoverable waste. The successive actions needed in the waste management chain are integrated to each other. Consistent national policies must address it as a whole, and this is why our sector should remain under the ESR.
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Response to Revision of EU legislation on end-of-life vehicles

18 Nov 2020

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the Revision of Directive 2000/53/EC on End-of-Life Vehicles as part of the new CEAP and the Green Deal. Historically, the vehicle composition is changed and is shifted towards light materials such aluminum and polymeric constituents to make the vehicles lighter and therefore less energy consuming and less polluting. One of the main problems in the recycling chain of the automotive is the ASR. Higher efficiency in ASR recovery is needed, in addition to material recycling of collectable components and metals. Also, it is estimated that a significant number of ELVs from EU countries are exported as second-hand cars towards non-EU countries causing massive negative impacts on health and environment due to inappropriate disposal. In order to increase the environmentally sound recycling of the ELVs, FEAD would like to stress the following needs: 1) Establish harmonized rules on de-registration The collection of ELV can be improved through a harmonized European legal framework with the following measures: • Create incentives to deliver a vehicle to authorized treatment facilities which deliver a Certificate of Destruction • implement a harmonized and easy vehicle registration and de-registration system within the EU through the constitution of a common European vehicle register, • define the minimum requirements and elements of such register, • make a clear distinction between used cars and ELVs, • enforce legislation to avoid illegal online and retailing sales, • define specific requirements for online and retailing sellers, • increase inspection of ATF (Authorized Testing Facilities) 2) Enhance vehicles eco-design The ELV directive has generated numerous efforts to encourage eco-design but more efforts are still needed, for example: • reducing the number of different polymers present in a vehicle. The presence of many different polymers is a serious challenge to recycling • the presence of resins, additives and fillers such as glass fibre, carbon fibre and glass beads makes the plastics difficult, if not impossible, to recycle. Substitution with recyclable materials should be explored • Favour easy dismantling of the automotive parts to increase reuse and recycling • favour recovery of plastics and other materials from ASR • provide incentives, such as mandatory recycled content, to encourage an increased demand of recycled plastics in the automotive sector 3) Improve extended producer responsibility for vehicles One of the main issues in the removal of car components is the economical sustainability of the action. Solutions for a better dismantling and an increase in recycling rates require to: • clarify that car manufacturers bear the responsibility and the costs for the waste stage of a car’s life cycle • provide incentives on proper dismantling and depollution through EPR schemes • provide a list of the available components in ELVs at the moment of their deregistration from the appropriate registers. • boost the market of secondary raw materials, through mandatory recycled contents in the automotive sector. 4) Invest in innovative technologies Optimizing post-shredder technology (PST) which allows to recover plastic materials is needed and should be boosted by economic incentives in order to increase the recycling rates of ASR. 5) Improve Information flow All the involved stakeholders have to cooperate and exchange relevant information, the producer will provide the dismantling information and the content of Substances of Concern for each new type of new vehicle put on the market. Taking into account that the average lifespan of a car in use is roughly between 12 and 15 years, legacy substances will also be a main issue. An updated is needed by the producers as a new substance becomes of concern. Furthermore FEAD calls for a coherence in the EU concerned legislation. Please find attached the full reply.
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Response to Sustainable Products Initiative

30 Oct 2020

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative on sustainable products under the European Green Deal and the new Circular Economy Action Plan (CEAP). Private waste management companies are major operators in this service, operating in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. FEAD considers that the EC initiative together with the initiative on empowering consumers for the green transition and the initiative on the substantiation of environmental claims using product and organisational environmental footprint methods are in the right direction towards accomplishing climate neutrality and resource efficiency, and realising the circular economy in the European Union, while allowing for synergies between sectors, enabling new investments, and creating economic growth and jobs, in line with the European Green Deal. Sustainable products by definition are an integral part of the circular economy, which is embedded in waste management activities. The waste management sector and the circular economy’s contribution to the green transition are crucial as GHG emissions from raw material extraction and from products’ manufacture need to be reduced and resource consumption needs to be minimised. Proper waste management and use of recycled materials in products bring in many cases significant CO2 emissions reduction, products’ footprints improvement and materials’ efficiency, and the potential for recirculation of high-quality secondary raw materials in the market. The following key elements must be taken into consideration by the EC and the EU legislator in designing the new framework for sustainable products: 1) Better information flows on materials. 2) Labelling: The Commission should introduce a European recycling label. A proper eco-label should reflect the avoided CO2 emissions at the manufacturing stage, and more generally, the CO2 performances when using the product. 3) Mandatory eco-design: All products need to be designed, manufactured, and used in a way that ensures the sustainable use of natural resources and reinforces the recycling and/or reuse of parts or materials, while taking into consideration the need to enhance their sustainability performance. 4) Mandatory recycled content in the products: particularly in packaging, automotive, construction, paper, EEE and textile sectors. Mandatory recycled content is an instrument that will enable the full realisation of the circular economy in the Union and a tool to that will intensify the use of recyclates, by shifting the market demand towards secondary raw materials. 5) Mandatory green public procurement rules. 6) A hierarchy for raw materials. 7) Financial or fiscal tools (e.g. reduced VAT or “CO2 bonus”): reduced levies for sustainable products incorporating recycled content, reflecting savings of CO2-emissions. 8) Development of valid Green Claims. 9) Isolation and filling material affecting the plastic waste stream. 10) Energy Efficiency: There is a real necessity to improve the circular economy and in so doing, the energy efficiency and the decarbonization of the Union would also increase. Recovering the energy content of waste is an essential complement of material recovery and the circular economy. Besides, the European Commission has recognised the potential and need for energy recovery from waste. 11) Incorporating environmental costs into the economy. 12) Strict rules for products failures, products with short life-span and greenwashing. 13) Better enforcement of the environmental rules adopted. FEAD is committed to the objectives of the European Green Deal and considers the above-mentioned measures apt for providing adequate stimuli both for addressing GHG emissions and for enhancing of the circular economy in Europe.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

26 Oct 2020

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the EU Action Plan Towards a Zero Pollution Ambition which aims at securing clean air, water and soil, healthy ecosystems and a healthy living environment for Europeans. From a waste management perspective, in order to secure a safer environment, we would like to stress the following needs of the waste management sector: -More information When treating waste, the operators may face a lack of information about the composition of the waste received. This is particularly critical for hazardous waste. Such info is essential for several reasons: compliance with the acceptance criteria in the facilities and, where applicable, the compliance with legislative requirements such as POP Regulation or Seveso requirements on site, verification of the chemical compatibility to prevent any risk of accident and protection of employees and citizens -Need for guidance Together with the need for more information we call for the creation of a realistic guidance on what could be found in different waste streams and how to treat them in a safe and environmentally sound manner -Get rid of Substances of Very High Concern in products This topic is fundamental and in order to improve the quality of recyclates as well as the safety of the workers and the environment we should, as much as possible, get rid of substances of very high concern in the products. If substitutes are unavoidable we then claim for more information on products and on how to remove and treat those substances in a safe and environmentally sound manner -Mandatory eco-design We call for a true dismantlability and recyclability of products through mandatory standards for designing products, phasing out substances of very high concern and POPs. A robust eco-design policy will be also a key tool for the prevention of the generation of waste -Enforcement of EU legislation While ambitious targets push for more recycling in terms of quantity, a qualitative approach is also needed, as recyclers are investing in downstream parts of the value chain. This investment will only be made possible by the proper implementation and enforcement of the existing international and European legislation (REACH, RoHS, POPs) at all stages and by all actors, with a specific attention to imported goods -Legacy substances Because legacy substances are a barrier to recycling we call for a specific decision-making methodology to support decisions on the decontamination and the recyclability of waste containing substances of concern - Incentives should be provided for specific decontamination in view of recycling. As already said, information regarding the presence of substances of concern is missing in most cases, thus there is no sufficient market for innovation and investment in dedicated recycling facilities. Public support should be considered to foster new investments related to separation and decontamination, allowing for more recycling. - Consumers’ information Information to consumers related to products’ environmental footprint, to products’ recycled content, to correct disposal and effective recycling, are measures aiming at empowering the consumers and making them attentive to pollution impacts -New pieces of legislation for products could lead to: a better knowledge of the products’ contents a better segregation between uncontaminated parts and contaminated parts the production of risk free recyclates and a strong European secondary raw material market a certain increase of the contaminated plastic waste fractions to be disposed of and therefore a decrease in recycling rates an increase in recyclates prices In order to improve the protection of health and environment from the risks that can be posed by pollution, the EC needs to strike the right balance between the economical and the environmental sustainability of the products which we acknowledge to be one of most challenging issues nowadays
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

21 Oct 2020

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the revision of the Industrial pollution – European Pollutant Release and Transfer Register as an initiative part of the European Green Deal, the new Circular Economy Action Plan and the recently published Commission Staff Working Document Evaluation of the Industrial Emissions Directive. In general, the overall structure of the E-PRTR appears to function well. However, FEAD would like to provide the following comments related to the aspects identified as in need to be supported by policy options: 1 Aspect 2 - Inclusion of additional sectors: there are some important sectors currently not very strongly regulated. Certainly, there is room for improvement. However, it will be a challenge to tackle the majority of the diffuse emissions from these sectors and bring them in a balanced way with the channelled emissions from most industries. 2 Aspect 3 - Inclusion of additional pollutants: of course additional pollutants can be taken into account but only if the assessment shows evidence that these pollutants are really relevant (avoid “nice to have” substances), otherwise they will be contrary to the aim for increased efficiency and timeliness under Aspect 5 FEAD is committed to the objectives of the European Green Deal and considers the above-mentioned measures apt for providing the adequate stimuli both for addressing GHG emissions and enhancing of the circular economy in Europe.
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Response to Empowering the consumer for the green transition

1 Sept 2020

Please, find attached FEAD’s full feedback to the EC Roadmap on Empowering the Consumer for the Green Transition FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the European Commission’s initiative to empower the consumer for the green transition. Private waste management companies are major operators in this service, operating in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. FEAD considers that a new stand-alone consumer protection instrument (option 2 of the Inception Impact Assessment of the Roadmap) is the appropriate mean of achieving a uniform regulatory framework with regards to products’ sustainability and consumer protection, in line with the European Green Deal and the new Circular Economy Action Plan. Consumers should be provided with valid information on how products are designed, manufactured, and used, how they ensure the sustainable use of natural resources and their recycling and/or reuse characteristics. In particular, a recycling label or product pass should inform consumers about both (i) whether and if so to which extent a product can be recycled (i.e., design for recycling), and (ii) when possible, the extent of recycled material in a product. The waste management sector and the circular economy’s contribution to the green transition are crucial as GHG emissions from raw material extraction and from products’ manufacture need to be reduced and resource consumption needs to be minimised. Proper waste management and use of recycled materials in products bring in many cases significant CO2 emissions reduction, and consumers need to be aware of the products’ footprints, the materials’ efficiency, and the potential for recirculation of high-quality materials in the market. FEAD believes that product (eco-)labels, in particular related to recycling, would foster change in consumer choices and behavior, resulting in achieving the untapped potential to reduce greenhouse gas emissions thanks to more recycling. Consumers should be provided with the tools to shift towards green products and business. An inventory of avoided CO2 emissions of frequently used products should be made, considering the amount of the materials, and the recycling process for each material, to select the products/waste to be tackled first. Finally, a proper eco-label should reflect the avoided CO2 emissions at the manufacturing stage, and more generally, the CO2 performances when using the product. Based on the above, the following key elements must be taken into consideration by the EC and the EU legislator in designing a new framework to push consumers towards the green transition: • facilitation of consumers’ choice: enhanced eco-labelling focusing on recycling to reflect the actual recyclability of products and the presence of (including the percentage of) recycled content (Recycling Label); • mandatory recycled content in the products; • mandatory eco-design; • mandatory green public procurement rules; • a hierarchy for raw materials, giving priority to recycled materials and promoting the fair and sustainable supply of raw materials from global markets, also reflected in the labels; • financial or fiscal tools (e.g. reduced VAT or “CO2 bonus”); • Development of valid Green Claims; • incorporating environmental costs into the economy; • strict rules for products failures, products with short life-span and greenwashing; and • better enforcement of the rules adopted. FEAD totally supports the EU idea of developing a uniform and binding regulatory framework, in order to empower consumers. Consumers, with their power of choice, can be the engine of the environmental revolution.
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

FEAD, the European Federation for Waste Management and Environmental Services, welcomes the European Commission’s initiative to substantiate green claims in order to empower the consumer and business partners for the green transition. Private waste management companies are major operators in this service, operating in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. FEAD considers that when Product Environmental Footprint Category Rules (PEFCRs) or Organisation Environmental Footprint Sector Rules (OEFSRs) have been adopted, green claims should be substantiated on that basis (option 3, of the Inception Impact Assessment of the legislative proposal). However, option 3 should be amended in that respect that the use of green claims is not compulsory. In general, both consumers and business partners should be provided with valid information on how products are designed, manufactured, and used, how they ensure the sustainable use of natural resources and their recycling and/or reuse characteristics. In particular, a recycling label or product pass should inform consumers and business partners about both (i) the extent of recycling material in a product and (ii) whether and if so to which extent a product can be recycled (i.e., design for recycling) and (ii) when possible, the extent of recycled material in a product. We agree with the base line identifying imperfect information as problem: Indeed, market actors do not have access to simplified, immediate and trustworthy information on environmental performance of products. However, we do not regard the current structure of EU Ecolabel and equivalent national/regional schemes (e.g. Nordic Swan, Blue Angel, etc.) as specific enough to inform about (i) the extent of recycling material in a product and (ii) whether and if so to which extent a product can be recycled (i.e., design for recycling). We appreciate that sub-options of the Inception Impact Assessment will consider potential communication requirements in business-to-consumer and business-to-business settings, including a minimum information content, or a common EU format (e.g. an EU label/ logo). We believe that a trustworthy EU Recycling Label can deliver reliable and accurate information. The waste management sector and the circular economy’s contribution to the green transition is crucial as GHG emissions from raw material extraction and from products’ manufacture need to be reduced and resource consumption needs to be minimized. Proper waste management and use of recycled materials in products brings in many cases significant CO2 emissions reduction, and consumers need to be aware of the products’ footprints, the materials’ efficiency, and the potential for recirculation of high-quality materials in the market. FEAD believes that product (eco-)labels, in particular recycling labels, could result in change in consumer choices and behavior, which could lead to the highest potential to reduce greenhouse gas emissions. Based on the above, the following key elements must be taken into consideration: • facilitation of consumers’ choice: enhanced eco-labelling focusing on recycling to reflect the recyclability of products and the presence of (including, where possible, the percentage of) recycled content (EU Recycling Label) • Development of valid Green Claims which can be used in promotion towards consumers if specific scientific ecological criteria (e.g. specific amount of recycled content in a product) are met in order to avoid misleading green washing • incorporating environmental costs into the economy • strict rules for products failures, products with short life-span and greenwashing; and • better enforcement of the rules adopted FEAD totally supports EU idea of legislation on substantiating green claims avoiding misleading information of consumers or business partners. Consumers and business partners, with their power of choice, can be the engine of the environmental revolution
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

25 Aug 2020

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, welcomes the new roadmap initiative on the evaluation of the Sewage Sludge Directive (SDD). FEAD is aware of the caution to be taken when talking about this topic due to the necessary attention for human health and environment. Sludges are rich in nutrients such as nitrogen and phosphorous and contain valuable organic matter that is useful when soils are depleted or subject to erosion and can limit or avoid the use of chemical fertilizers. Treated sludge as per Directive 86/278/EEC of 12 June 1986 are defined as “sludges which have undergone biological, chemical or heat treatment, long-term storage or any other appropriate process so as significantly to reduce its fermentability and the health hazards resulting from its use is defined as having undergone”. Sludges originate from the process of treatment of wastewater which should provide a characterization of the sludge in terms of heavy metals, pollutants and possible presence of pathogenic organisms. We must therefore ensure that no health or environmental risks are taken. In order to avoid sanitary/pathogenic issues, precautionary measures need to be put in place: for example, the distribution of sludge for the growth of fruits and vegetables must occur 10 months prior to harvesting, same limitation should be observed for 5 weeks prior to grazing. These measures (already implemented in some EU Countries), can grant the absence of issues rated to the distribution of sludge. However, the revised directive should set a hierarchy of desired uses for sludge that encourages preferential use in soil restoration rather than food/feed producing land. Strict limits should be envisaged as sludges in agriculture involves people’s health: so, testing should include, besides excluding the presence of pathogens and heavy metals, radioelements (in cases sludges come from healthcare facilities), microplastics and POPs. These elements were not taken into consideration in the previous directive. Nutrient assessment is also essential to be undertaken, in order to properly make use of sludges, so if they do not improve the quality of soil, energy recovery should be foreseen. In conclusion, if the above-mentioned conditions of soil/health and groundwater protection are not met, Waste to Energy solution with phosphorous recovery should be the only way to dispose the sewage sludges.
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Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

FEAD, the European Federation for Waste Management and Environmental Services, welcomes amendments to the annexes of Regulation (EU) 2019/1021 on POPs, aiming to achieve a toxic-free environment. FEAD believes that addressing and revising new values for different substances is crucial in order to limit the presence of certain POP substances in waste and in material that could be recovered through it. As FEAD’s members deal with all types of POPs concerned by the amendments, we believe that more comprehensive information should be provided by manufacturers, in order for the waste management industry to treat waste in a way that preserves individuals’ health as well as biodiversity In particular, FEAD would like to stress the following elements: • Good practices should be increased and promoted, in order to enable the limitation of POPs as fast as possible • To achieve this objective, the waste management sector needs more information on POPs’ presence in different products, in order to adapt treatment accordingly. Information from manufacturers must follow during the life cycle of materials until waste phase to ensure the separation of recyclable and non-recyclable wastes Concerned substances are present in many products used and disposed of in our daily lives. This lack of information from the manufacturers’ side creates significant difficulties in waste treatment processes For many years, our sector has been demanding a true improvement of the information on products. To date, we have not observed enough changes. We think this is a crucial step. It is also a first step to ensure the phasing out of as many hazardous substances (SVHC/POP) as possible in the manufacturing processes, also for imported goods • Legacy substances: A great concern is expressed for durable goods which do not become waste immediately, but only after 5, 10 or more years, and waste managers do not have suitable information about these products. Information on a product should also be updated during the whole life-span of it • New pieces of legislation for products could lead to: a better knowledge of the POPs contents a better segregation between uncontaminated parts and POP containing parts the production of risk free recyclates a certain increase of the contaminated plastic waste fractions to be disposed of and therefore a decrease in recycling rates an increase in recyclates prices • Incentives should be provided for specific decontamination in view of recycling. Information regarding the presence of POP is missing in most cases, thus there is no sufficient market for innovation and investment in dedicated recycling facilities. Public support should also be considered to foster new investments related to separation and decontamination, allowing for more recycling • To properly detect and treat products containing harmful substances, the waste management sector calls for harmonisation at EU level in the existing analysis methods as well as a broadened scope of the SCIP database, to include POPs other than SVHCs, if the SCIP is considered as the main source of information from producers to waste management sector • Regarding the idea mentioned in the roadmap that “potential increase in environmental emissions of hazardous substances associated with waste disposal (e.g. via incineration or landfill)” we would like to stress that a proper hazardous waste management does not lead to environmental emissions which could cause hazard to people or environment. State-of-the-art hazardous waste treatment installations are safe, continuously monitored and properly controlled in all steps Finally, FEAD highlights that EU policies for a “toxic free environment”, and for more recycling, often result in contradictory regulatory directions. In the worst case, none of the objectives are reached, while waste operators are put in a situation where rules are not predictable, nor always practicable. Proper implementation of existing rules should be a priority on the agenda
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

6 Aug 2020

Please, find attached FEAD’s full feedback to the EC Roadmap on Packaging Waste. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the EC initiative on the review of the requirements for packaging and on other measures to prevent packaging waste and considers it of the utmost importance in achieving a fully circular economy in the EU. FEAD key messages include: • Improvement of design for re-use and recycling • Strong pull measures for recycling: mandatory recycled contents, green public procurement • Promotion of high-quality recycling through public support for selective collection schemes and investment for sorting • Consideration given to the need for residual waste treatment. Selective collection of packaging still mixes a variety of packagings and materials (e.g different types of bottles for beverages/food packaging, food/non-food plastics collected together) which are not all recyclable and need treatment. • Consideration on how to enable an increased content of recycled materials in food contact material • Strengthening of the enforcement towards meeting the above A. Review of the Requirements for Packaging With regards to the Review of the Requirements for Packaging, we have identified the following criteria to be considered in reviewing and revising the essential requirements for packaging. These criteria have been subdivided into three distinct sections, namely: (1) Product Design, (2) Market Issues, and (3) Issues with Current Technology. Please, see the attached for a more extensive analysis of these sections. B. Measures to prevent packaging waste Measures to prevent packaging waste go hand-in-hand with the overall enhancement of recycling and waste prevention, which can be strengthened by: • mandatory eco-design: a true dismantlability and recyclability of products through targets and use of mandatory standards for products, reducing or phasing out chemical substances and preventing waste. A robust eco-design policy will be a key tool for the prevention of the generation of waste; • improving collection rates by all means that request the MS to put in place appropriate schemes (door-to door collection, civic amenities, deposit and return schemes, etc..) at local and national level (i.e. for e-waste in order to boost recycling rates); • open markets: household waste to remain accessible to private waste management, also industrial and commercial waste to stay within a fully open market. EPR schemes have to remain a tool for improving collection and recycling of some more difficult flows such as household waste but should not be substituted to performant B2B contracts, reflecting the polluter pays principle; • recognising the need for increased EU funds for investment in infrastructures to scale up the volume and quality of recyclates; • duly taking into consideration the need for resources and means to promote and protect re-use industry and means to support the “right to repair, refurb, durability, and the second life of products”; • phasing out all substances of concern; • adopting a balanced approach to waste with chemical substances by encouraging clear rules that give legal certainty to waste operators, and allow an appropriate balance between high recycling rates, and quality recycling.
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Response to EU Methane Strategy

5 Aug 2020

Please find attached FEAD’s full feedback to the EC Roadmap on the EU Methane Strategy. FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe, welcomes the new EC initiative on the EU Methane Strategy, as one of the instruments of the European Green Deal. Private waste management companies are major operators in this service, operating in 60% of municipal waste markets in Europe, and in 75% of industrial and commercial waste. We understand that the EU Methane Strategy should work together with other legislative tools, notably the Circular Economy Action Plan (CEAP), in order to yield higher decrease of GHG emissions, and in particular methane emissions, while improving the circular economy in the Union. This should also result in making waste management sector a key one in the path to EU economy decarbonisation, in promoting synergies between sectors, in enabling new investments and creating economic growth and jobs. Waste management activities have a key role to play in this regard and there are still challenges that must be overcome with regard to methane emissions. FEAD key messages include: • Ensuring better data collection in order to identify more precisely the main areas of action for the methane reduction • Strenghen synergies between sectors, including biogas production that can reduce methane emissions from manure, valorise waste streams and contribute to decarbonize the energy system by the production of biogas • Ensuring the implementation of existing rules on landfilling and separate collection of biowaste in a homogeneous way in all EU Member States • Introducing high composting targets in order to ensure more resource efficiency and recovery of biowaste • Assessing the impact of an EU-wide ban on landfilling of recyclable and recoverable waste (not selectively collected, not sorted or not treated municipal waste) in order to take subsequent necessary and appropriate legislative action in line with the principles of circular economy According to the EC Roadmap, the main identified sources of methane stemming from the EU waste management sector are (1) the uncontrolled emissions of landfill gas in landfill sites; (2) the treatment of sewage sludge; and (3) leaks from biogas plants due to poor design or maintenance. At the same time however, the waste management sector contributes largely to limiting GHG emissions. Significant EU funds have to be redirected to boost investments in selective collection and proper treatment. A stronger push will be needed especially in those Member States undergoing a severe recession, while experiencing insufficient methane avoidance/recovery performances, such as large-scale landfilling. FEAD is committed to the objectives of the Green Deal and considers the above-mentioned measures apt for providing the adequate stimuli both for addressing GHG and particularly methane emissions in the Union activities, and for the overall recovery of the EU economy and the enhancement of the circular economy in Europe.
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Response to Modernising the EU’s batteries legislation

3 Jul 2020

FEAD welcomes the EU initiative of modernizing the EU rules on Batteries in line with the Green Deal and other sustainability-related policies like the new CEAP. From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs: • Update and harmonization of definitions It is essential to have a harmonized legal framework on definitions at EU level: on definitions of batteries, an actualisation is necessary in order to integrate new types of batteries. The current differentiation according to industrial or portable batteries is not practicable and a distinction between the different chemical-types of batteries would be more accurate. There is also a need to align the definitions among the WfD list of waste, the Batteries directive and the Waste Shipment Regulation. • Boost European batteries’ industry We recognize a huge need to boost the batteries industry within EU in order to increase environmental, economic sustainability and self-sufficiency. There is also the need to build up a stable and competitive market for recycled materials in Europe. This can best be achieved by an EU-wide introduction of mandatory recycled content in products, as well as sustainable ecodesign for batteries and labelling requirements for a better return flow of materials. • Mandatory Recycled Content Mandatory recycled content in products is essential for the creation of a stable and competitive market for recycled raw materials in EU. The mandatory integration of recycled content in batteries will boost the recycling market in Europe, foster investments in innovative recycling technologies and decrease the environmental footprint of batteries. Mandatory recycled content will also help to ensure the strategic availability of critical raw materials in Europe. In order to guarantee a level-playing field, minimal recycled content should also be mandatory for imported batteries. • Ecodesign Electrical and electronic equipment that can be operated wholly or partly on batteries or accumulators must be designed in such a way that waste batteries and accumulators can be removed easily. Uniform marking of devices containing high-energy accumulators by producers should be made compulsory. Consumers should also be instructed on the correct handling of the devices and accumulators concerned already at purchase and later upon disposal. • Increased collection In order to avoid fires in the processing plants mainly caused by mis-disposal, it is necessary to considerably improve the return flow of batteries. To achieve higher collection rates, FEAD requests an increase of the current collection targets of 45% to 80% for all types of batteries, excluding for automotive batteries for which targets of 100% should apply. In order to guarantee a higher return flow of batteries, FEAD also claims for the introduction of an EU-wide harmonized deposit and refund system on batteries. • EPR schemes FEAD calls for the extension of extended producer responsibility beyond the current scope of portable batteries to all different types of batteries. In the same time, FEAD stresses the necessity to duly take into consideration the existing and successful B2B schemes/contracts that provide for collection, sorting, treatment and recycling. • Enforcing the control of illegal movements of battery waste The EU should set up an effective control mechanism for the exports of used batteries in order to avoid illegal shipments and to ensure proper environmentally sound recycling/recovery processes outside EU. • Increase the recycling targets on batteries The current general target recycling rate of 50% is too low for industrial Li-ion batteries. There should be a separate and higher target rate for Li-ion batteries in the near future. Low carbon footprint recovery processes should be supported.
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Response to Chemicals strategy for sustainability

19 Jun 2020

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Chemicals Strategy for Sustainability which aims at protecting people and the environment better against hazardous chemicals and at encouraging innovation for the development of safer alternatives. From a waste management perspective, in order to improve the circular economy which requires more and more ambitious targets in terms of quantity and quality, we would like to stress the following needs: • More information When treating waste, the operators may face a lack of information about the composition of the waste received. This is particularly critical for hazardous waste. Such information is essential for several reasons: compliance with the acceptance criteria in the facilities and, where applicable, the compliance with legislative requirements such as POP Regulation or Seveso requirements on site, verification of the chemical compatibility to prevent any risk of accident and protection of employees in terms of health and safety. • Need for guidance Together with the need for more information we call for the creation of a realistic guidance on what could be found in different waste streams and how to treat them in a safe and environmentally sound manner • Decrease of the use of Substances of Very High Concern This topic is fundamental and in order to improve the quality of recyclates as well as the safety of the workers and the environment we should, as much as possible, get rid of substances of very high concern in the products. If substitutes are unavoidable we then claim for more information on products and on how to remove and treat those substances in a safe and environmentally sound manner. • Mandatory eco-design We call for a true dismantlability and recyclability of products through mandatory standards for designing products, reducing or phasing out substances of very high concern. A robust eco-design policy will be also a key tool for the prevention of the generation of waste. • Enforcement and implementation of EU legislation While ambitious targets push for more recycling in terms of quantity, a qualitative approach is also needed, as recyclers are investing in downstream parts of the value chain. This investment will only be made possible by the proper implementation and enforcement of the existing international and European legislation (REACH, RoHS, POPs) at all stages and by all actors, with a specific attention to imported goods. • Legacy substances Because legacy substances are a barrier to recycling we call for a specific decision-making methodology to support decisions on the recyclability of waste containing substances of concern. In order to improve the protection of human health and the environment from the risks that can be posed by chemicals, the Commission needs to strike the right balance between recycling/recovery policy as proposed by the new Circular Economy Action Plan and the aims of chemicals/products legislation.
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Response to Commission Communication – "Renovation wave" initiative for the building sector

8 Jun 2020

FEAD, the European Federation for Waste Management and Environmental Services, representing the private waste and resource management industry across Europe welcomes the Renovation Wave initiative for public and private buildings from a waste management perspective. By improving the circular economy practices in the construction sector, we can achieve increased quality and quantity of recycling and reuse of construction and demolition materials. However, fully embracing the circular economy requires even more ambitious and sound waste management practices. The proposed Roadmap should encompass a full chapter on making the sector more circular, by using recycled construction products with the lowest carbon footprint. Construction and demolition waste management is considered crucial as GHG emissions from raw material extraction, from products’ manufacture, and from construction and renovation of buildings need to be reduced and resource consumption needs to be minimised. An inventory should be made on priority construction products, taking into consideration the avoided CO2 emissions, the amount of the materials, and the recycling process for each material, to select the products/waste to be tackled first. The construction and renovation of buildings require significant amounts of energy and raw materials, that is why the EU legislator should take strong measures to increase the efficiency in the use of these resources by improving the following factors: 1) Promotion of the use of recyclates The nature of the waste produced, and therefore its quality, is closely related to the type of work. In addition, mandatory recycled content in a number of construction products should be privileged, in particular for plastic pipes and inert materials. Selective collection schemes should be broadly imposed and enforced. They exist in a few MS, but not in all. On the other hand, ERP schemes should not be considered the way forward, as they are not the best way to promote recycling and re-use of construction/demolition waste, while B-to-B contracts are economically more efficient and environmentally performant. 2) Better information on the materials Higher trust of the quality of recyclates requires better information on the composition of materials used in existing buildings, standardization of secondary raw materials, and sharing of the information among all the relevant stakeholders. 3) Setting up integrated waste management strategies The use of recyclates in a more systematic and closed-loop way for building construction or renovation should be promoted. 4) Overcoming uncompetitive pricing for recyclates Any activities and use of materials with low-energy content, i.e. secondary raw materials, should be positively treated in the EU market compared to those manufactured products with a much higher energy content. 5) Levies Member States or regions may consider providing price incentives to use recycled materials if they bring the desired benefits to the environment. 6) Landfill reduction Landfilling should be restricted to non-recyclable inert waste that can’t be disposed of in another way. 7) Clear end-of-waste criteria The definition of precise, clear, and harmonized end-of-waste criteria at EU level would encourage the production of secondary raw materials and would reward those who invest in high-quality recycled products. 8) Green Public Procurement Authorities at all levels can provide incentives for promoting the use of construction and demolition recycled materials in public building renovation. 9) Energy-efficient renovation A focus on the energy renovation of buildings in the EU is also significant. Overall, the above-mentioned factors are suitable for all types of buildings both public and private. There is a real necessity to improve the circular economy in the construction sector as it represents a huge fraction of waste within the EU.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

FEAD does not call for a revision of the IED (Industrial Emissions Directive), and is convinced that climate ambitions, as well as circular economy benefits, should be addressed elsewhere. IED’s philosophy relies on site specific permitting. It is not suited for an overarching approach. Using the IED as a regulation for climate and circularity goals would be a risks of cost inefficiency and additional regulatory complexity. We already expressed these issues in the consultation of 13/09/2019: 1. FEAD acknowledges the environmental benefits resulting from the modernisation of the former IPPC directive, and the progress made in the elaboration of the BAT conclusions and BREFs. However, we express doubts on the process of choice of the BATs, and on whether the BREFs consider the compliance and operational costs. We fear that the uncertainties in existing measurement protocols (available SRM) do not allow for monitoring of emissions. EU standards at levels requested by some BREFs should be set up, and referred to, in the BREFs 2. FEAD did not agree on the opinion that IED “should remain relevant to rapidly adapt to a zero-carbon economy by 2050”. FEAD recalls that the IED should not be the instrument to reduce CO2 emissions in the industry. BREFs already cover energy efficiency in most sectors, and, for waste management, there is no leeway for reducing CO2 emissions since they directly depend on the carbon content of waste. FEAD understands the revision of the IED, if decided, would target three objectives: improve the BREF elaboration process, explore the potential for the IED to further contribute to the circular economy, and interact with the decarbonisation of industry. We question these objectives in the IED context: the BREF elaboration process should remain technically, not politically driven. We do not clearly understand which pollutants should be put under review, since the evaluation shows quite positive conclusions. Finally, decarbonisation and circular economy are already covered by other regulatory instruments. In case the revision process of the IED would be decided, the following points should be addressed: 1. Improve the overall consistency of the Directive. Articles related to a given activity should be moved to the Annex for that particular industry. For instance, in Chapter 1 (Common Provisions), Art 3 (15), page L334/23, the definition of ‘operator’ is restricted to a small number of industries, compared to the list of Annex I. 2. Before starting the review of a BREF, an assessment should be based on the 4 Key Environmental Issues (1-environmental relevance of a pollutant, 2-impact of the activity by the particular industry on total pollution in the EU, 3-identify new techniques that may lead to significant reduction of emissions, 4-check opportunities and mainly feasibility for significant improvement of BAT-AEL ranges) 3. Consider to possibly adapt the fixed 8-years timing for the BREF review process, depending on the sector, justified by environmental (pollution), economic (quick or slow development) or technical (evolution of the techniques) reasons 4. In the BREFs, the uncertainty of measurement techniques for low emission levels should be tackled. FEAD demands measurement techniques to be standardised at CEN-CENELEC, and these standards to be referred to in the BREFs. This is needed for implementation of some BREFs/BAT conclusions, more urgently than the IED revision. 5. Industry must remain well represented within the TWG. Participants must be able to provide tangible proofs of the technical feasibility of their proposals. 6. There may be activities currently out of the IED scope that cause pollution and to which the IED could be extended. FEAD calls for a renewed attention to costs and competitiveness, in the context of the post Covid-19 economic recession, while waste treatment activities comply with the highest environment requirements compared to other industries.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

FEAD, the European Federation for private waste and resource management, supports the revision of the Energy Taxation Directive (ETD), as one of the instruments of the European Green Deal. A well-designed ETD should work together with the Circular Economy Action Plan and boost the circular economy in Europe. Waste management activities are at the crossroads of several key challenges; the revised ETD can help give the right response by making fossil fuel energy prices higher. The revision of the ETD should consider the following: 1) Pursuant to the ETD, any activities and use of materials with low-energy content should be positively treated in the EU market compared to those manufactured products with a higher energy content. That would be the case with a revised ETD resulting in a higher taxation of the CO2 content of primary energy. Glass, metal, plastic, and paper recyclates would gain competitiveness in the market, creating a higher demand for them. A bigger market for secondary raw materials would result in “green” jobs and growth. 2) Solid Recovered Fuel (SRF): waste that cannot be recycled (residues of plastic, paper, cardboard wood, tyres etc) can be used to produce high-quality, standardised alternative fuels. First, the fossil part of the SRF should be subject to a low taxation rate regarding its CO2 content. This would reflect that SRF is a virtuous use of residues that would otherwise be lost if incinerated without energy recovery or landfilled. SRF allows to avoid the use of fossil fuels for the purposes of its users, and therefore avoids CO2 emissions. Second, the biomass-based SRF components should not be taxed at all. The resulting competitive advantage would compensate for SRF costs that render such fuels more expensive than oil-based ones. Avoiding double taxation of SRF and W-t-E (see below) solutions also under the ETS, should be ensured. SFR constitutes a crucial link in the recycling chain and the circular economy, by giving to residues an economic value. 3) Waste-to-Energy (W-t-E): R1 waste-to-energy installations allow to recover the energy content of bulky non-recyclable waste. Heat from W-t-E installations account for around 50% approximately (with slightly different percentages in each Member State), due to the organic waste share in municipal waste that ends up in R1 installations. It is consequently considered renewable energy (biomass) under the Directive on Renewable Energy 2018-2001. A revised ETD should, similarly to SRF, result in acknowledging the renewable energy status of biowaste as a fuel, and the positive role of W-t-E in avoiding the use of fossil fuels when producing heat/electricity. 4) Waste heat recovery: the new EU taxation rules on fossil fuels should promote the recovery of waste heat. Waste heat as defined in the Renewable Energy Directive 2018/2001 can become subject to another process to provide clean energy, or it can be used by other economic operators in their commercial or industrial activities, or even to cover domestic electricity demand of end-users. As the heat was initially produced with CO2 taxed primary energy sources (unless renewable), there is no point in taxing it a second time as recovered waste heat (as is the case for the fossil part of waste in W-t-E and SRF). 5) Biomass and waste: the current article 16 of the ETD should not be reduced, in particular with regards to biomass as defined in the Renewable Energy Directive 2018/2001 (“the biodegradable fraction of products, waste and residues from agriculture (including vegetal and animal substances), forestry and related industries, as well as the biodegradable fraction of industrial and municipal waste”). Reducing massive landfilling should be accompanied by measures allowing to minimise its impact on the environment. Landfill biogas recovery allows to capture methane emissions from landfilling and produce heat or electricity. This should remain under the taxation rates of renewable energy.
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Response to Carbon Border Adjustment Mechanism

1 Apr 2020

FEAD – the European Federation for Waste Management and Environmental Services, supporting and promoting circular economy in the EU, is in favour of a carbon border adjustment mechanism (CBAM), as complementary to the EU ETS and the overall EU environmental legislation. In its Roadmap, the EC explains that the CBAM should tackle the problem of loss of competitiveness of European businesses due to EU regulations aiming at integrating the costs of CO2 emissions. FEAD would like to express that it should also help address the price gap between products containing recycled materials and those based on virgin material. A CBAM would support regulatory measures aiming at incorporating recyclates into products, and, more generally, the waste recycling chain. 1. A CBAM mechanism should take into consideration the energy content of imported products and put them on an equal footing with manufactured goods produced by industries subject to ETS. It would consequently cover imported products based on glass, cement, ceramic, paper, steel, aluminium, insofar as the “carbon leakage” mechanism does not fully compensate the CO2 costs for all sectors covered by the ETS. 2. The CBAM should also take into consideration the material content of imported products and aim at putting on the same competitiveness level products that incorporate recyclates and products that originate from virgin materials. 3. A CO2 compensation mechanism at the boarders should go hand in hand with EU policies based on mandatory recycled contents, such as the Directive 2019/904 on Single Use Plastics. The Circular Economy Action Plan (CEAP) adopted on 11.03.2020 puts clearly in the agenda that mandatory recycled content should be extended to other products, such as packaging, construction products, automotive. However, such EU regulations aiming at making the economy more circular result in increased costs in the whole product life cycle. That is why a CBAM should have under its scope the products that are covered, within EU, by mandatory recycled contents. That would be an essential tool against eco-dumping, and a necessary complement to mandatory recycled contents policies. In addition, a CBAM would facilitate closing the loop within the EU economy by sourcing more waste as material resources for industrial production. Furthermore, a CBAM would allow EU industries to compete on an equal footing with competitors from third countries which do not regulate their industries’ carbon emissions, nor regulate the whole material products’ life cycle by requesting the incorporation of recyclates in manufactured goods. 4. Regarding green manufacturing, as part of CEAP’s eco-labelling scheme, the Commission should envisage a carbon label on products that are manufactured or sold within the Union, reflecting their CO2 intensity and showing their performance. 5. Undoubtedly, the implementation of a CBAM would face numerous practical, economic and legal challenges and constraints, the latter with regards to International Trade Law and especially with ensuring the mechanism is WTO-compatible, thus the mechanism needs to be applied to third countries without prejudice to the non-discrimination principle. The key is to structure any accompanying measure as a straightforward extension of the domestic climate policy to imports. The CBAM should be deployed gradually, starting with pilot sectors. 6. In order to achieve a functioning and successful CBAM, FEAD believes that further cost-benefit analyses and impact assessments are needed, especially with regards to comparing the carbon footprint of products with recycled content and products with virgin materials. A cost-benefit analysis of the mechanism is also required, based on detailed implementation aspects and related costs. In-depth analyses should be conducted with regards to the practical feasibility of the mechanism, the legal aspects involved, the compatibility of the mechanism with the EU ETS scheme and with WTO rules.
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Response to A new Circular Economy Action Plan

17 Jan 2020

FEAD, the European Federation for Waste Management and Environmental Services, represents the private waste and resource management industry across Europe. FEAD would like to stress the following key elements ahead of the new Circular Economy Action Plan: - Strong EU market signals: • mandatory recycled content in the products: particularly in packaging, automotive, construction, EEE and textile sectors; • mandatory green public procurement rules to include recyclable products or products incorporating recycled content; • create a hierarchy for raw materials, giving priority to secondary ones; • financial or fiscal tools (e.g. reduced VAT): reduce the price of products incorporating recycled content; • facilitate consumers’ choice: eco-labelling to reflect the recyclability of products and the presence of recycled content; • key role for exports of sorted waste or recyclates, within or outside the EU to facilitate recycling within the best available facilities; • For WEEE, mandatory standards required in waste management industry to ensure output fractions/components are of suitable quality/safe to put back into manufacturing; • how to create a market for secondary raw materials coming from the recycling of textiles and WEEE. - Facilitate recycling and promoting waste prevention by: • mandatory eco-design: a true dismantlability and recyclability of products through targets and use of mandatory standards for products, reducing or phasing out chemical substances and preventing waste. A robust eco-design policy will be a key tool for the prevention of the generation of waste; • improving collection rates by all means that request the MS to put in place appropriate schemes (door-to door collection, civic amenities, deposit and return schemes, e.t.c.) at local and national level (i.e. for e-waste in order to boost recycling rates); • open markets: household waste to remain accessible to private waste management, also industrial and commercial waste to stay within a fully open market. EPR schemes have to remain a tool for improving collection and recycling of some more difficult flows such as household waste but should not be substituted to performant B2B contracts, reflecting the polluter pays principle; • recognising the need for infrastructures to scale up the volume and quality of recyclates, particularly in the WEEE sector; • duly taking into consideration the need for resources and means to promote and protect re-use industry and means to support the “right to repair, refurb, durability, and the second life of products”; • phasing out all substances of concern, particularly in EEE • adopting a balanced approach to waste with chemical substances by encouraging clear rules that allow an appropriate balance between high recycling rates, and quality recycling. - Incentivise cuts in CO2 emissions from the waste management chain, by: • incorporating environmental costs into the economy; • setting up an independent calculator for avoided CO2 emissions; • recognising the supportive role of energy recovery from waste in the recycling chain and promoting selective collection by considering the energy recovery of residues after recycling as a positive factor. The new Circular Economy Action Plan, as foreseen in the Waste Framework Directive, should also be the start of an ambitious EU policy for developing the recycling of industrial and commercial waste. While encouraging a stronger policy in favour of the circular economy, FEAD highlights that the Commission should make the implementation of the existing Directives and targets related to waste management a priority. In this regard, FEAD expresses concern about the new recycling targets accompanied by new calculation methods which will significantly decrease the measured performance.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

18 Dec 2019 · circular economy and waste policies

Meeting with Elina Melngaile (Cabinet of Vice-President Valdis Dombrovskis) and Confederation of European Waste-to-Energy Plants

29 Oct 2019 · waste management policy, circle economy, EU taxonomy

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

11 Oct 2019 · discussion on EU waste policies

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

11 Oct 2019 · discussion on circular economy and waste policies

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella)

31 Jan 2019 · Plastic Recycling

Response to Reducing marine litter: action on single use plastics and fishing gear

5 Jul 2018

FEAD welcomes the publication of the Commission’s proposal related to single-use plastics, aimed at reducing their impact on the environment. Our industry sees it as another step towards a more circular economy. The private waste and resources management industry together with the recycling industry play a key role in making this progress by collecting, sorting, processing waste and, finally, providing high quality recycled materials for Europe’s manufacturers and consumers. But an even stronger leadership from EU policy makers is needed to provide the right legal framework and market signals. The necessary investments for a more circular economy, creating many more jobs in Europe while making our economy more resilient and resource efficient, will be done by our companies only if there is enough legal and economic certainty. Consequently, FEAD members deeply regret that the text wrongly sees Extended Producer Responsibility (EPR) schemes as one of the main instruments to tackle issues stemming from single-use plastics and failed to embed a commitment towards legally binding proposals on recycled content in selected products. Indeed, large investments will be needed to keep innovating and expanding the separate collection, sorting and recycling capacity at EU level (4 times more compared with 2015, as estimated by the Commission). Our industry is prepared to make further investments if there are legislative measures ensuring economic visibility on a significant uptake of plastic recyclates. Most “green” markets” need strong pull measures to take off, to this extent recycling plastics is not an exception. In addition, mandatory recycled content would not only contribute to pull the demand for recycled plastics but will also contribute to reward plastics recycling environmental benefits in terms of CO2 and energy savings that the market currently fails to internalize. A strong demand for recycled plastics will only result from concrete binding rules, accompanied by economic measures to bridge the price gap detrimental to plastics from recyclates. Raising the collection performance of plastic bottles through deposit schemes or extended producer responsibility (ERP) is very important, but it will not be sufficient to create a solid European demand for recycled materials. Therefore, we urge the EU co-legislator to make sure that the finally adopted Directive foresees a proposal on binding recycled content at first for plastic bottles with regards to the targets already set in the Packaging and Packaging Waste Directive.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

4 Jun 2018

FEAD welcomes the publication of the EC Roadmap "Towards an EU Product Policy Framework". The private waste and resources management industry would like to stress the following points: • We need to focus more on the very first step in the value chain and intensify our cooperation with designers and manufacturers to ensure that products are designed to prevent waste and to be easily reused, dismantled and recycled. (80% of the environmental impact of products is determined at their design stage). On top of Eco Design we also need to increase the use of recyclates in new products, and to move to real “Circular Design”. For instance, we could implement economic instruments to incentivize Circular Design with bonus and malus systems within Extended Producer Responsibility schemes. • We need to introduce harmonized eco-labelling rules to incorporate indications of recycled content and recyclability. An EU consumer should know if a product is recyclable or not, or even better if it contains recycled materials. • Legislation promoting minimal recycled content in certain products should also be introduced. California did so by imposing a minimum of 25% post-consumer recycled content. There are no reasons why at EU level such measures could not be adopted. • Green public procurement must be intensified and the use of recycled content actively promoted in various public tenders, at EU, Member state, or local authority levels. • Fiscal incentives to boost demand could also be considered, like lower VAT rates on recycled materials or a CO2 carbon tax. E.g. each time one ton of plastic is recycled, Europe is saving 2 tonnes of CO2 versus virgin plastic. Externalities associated with the extraction and processing of virgin raw materials should also be factored into their price. So recycling, if massively promoted, would be a strong contributor to combat Global Warming. • FEAD members face problems resulting from the lack of information. Indeed, the waste materials that recyclers have to deal with are by their nature heterogeneous. Recyclers often have insufficient information on the substances and the content of the input waste material they treat. It is therefore crucial that information is provided and efficiently shared with all the actors along the different stages of the value chain, especially between product manufacturers who know the content of the substances they incorporate in their products, and recyclers. • As long as hazardous substances can be placed on the market legally by manufacturers of virgin raw materials, recycling companies will at some point in time have to deal with those “legacy substances”. The long term policy goal should be to achieve toxic/ risk free material cycles, but this should start at the initial design stage, where products enter the material cycle for the first time.The European Commission is planning to work on a general framework / common methodology to “determine the overall costs and benefits for society, and to assess how to strike a right balance between quantity and quality recycling”. Although an overall methodology is desirable from a long-term perspective, the urgency of the issue requires a short term/ interim solution for recyclers dealing with these substances of concern. If not, competent authorities will soon face a dilemma and leave market players with no visibility over potential outlets and investments. In the short term, FEAD therefore calls for the adoption of a practicable case-by-case approach based on a proper risk assessment and restricted to certain uses. The overall aim should be high quality recycling, in line with the waste hierarchy. We trust that you will take our comments into account,
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Response to Commission Regulation amending Annex III to Directive 2008/98/EC

12 Aug 2016

FEAD is concerned that the European Commission’s proposal ‘amending Annex III to Directive 200/98/EC of the European Parliament and the Council as regards the hazardous property HP 14 (‘Ecotoxic’)’ is based on limited dataset, especially since it provides a new calculation method (Method 1 from the “Study to assess the impacts of different classification approaches for hazard property "HP 14" on selected waste streams” including cut of values) that was not assessed in the study. We do not think that sufficient evidence has been obtained to adequately assess potential impacts or to make such significant changes to the current methods for classifying HP 14. We believe it is positive that the European Commission decided use method (from the “Study to assess the impacts of different classification approaches for hazard property "HP 14") including cut off values. Indeed, cut off values prevent the unreasonable situation that the more substances operators determine analytically, the bigger the value they will get from the sum itself. We therefore agree that concentration of compounds below the cut-off values should therefore not be included in the HP 14 assessment equation as this will lead to results which do not reflect the real hazard. However, from first calculations done by our members, we realised that the chosen method will not remediate to our main concern which is that bottom ash from the incineration of non-hazardous waste and aggregates from construction and demolition waste, which are currently treated as non-hazardous waste, would be classified as ecotoxic and hence as hazardous. If the concerned waste streams are classified as hazardous, recycling them will become more burdensome. This is in our view not justified by the environmental risk: large volumes of incineration bottom ash and aggregates from construction and demolition waste have been recycled for decades without any recorded harmful effects on humans or the environment, and the classification methodology should reflect such reality. Classifying these wastes as hazardous would render hazardous waste landfill virtually the only option for dealing with it. Therefore, we recommend that the Commission opt for a calculation method which is both practical and shows high concordance with current waste classification. The chosen method should keep the status quo as regards the classification of waste as hazardous or non-hazardous. Changing the current classification of waste based on what we consider an inadequate methodology could strongly discourage recycling and would be a step back in terms of resources management and Circular Economy, involving additional costs which are disproportionate to the envisaged benefits for human health and the environment. We would also like to receive some clarification regarding the frequency of the assessment. Currently, waste management companies analyse the presence of hazardous waste only when there are reasonable suspicions on the presence of ecotoxicity. FEAD is concerned that the proposal might lead the authorities to ask for tests for every sample even when nothing indicates the presence of ecotoxic material. Such practice would represent an important additional cost for the companies. Ultimately, we would like to mention that FEAD would be able to provide more feedback if the Commission gives another occasion to stakeholders to react on the proposal, especially once our experts will have had the opportunity to properly analyse the new calculation method proposed. We trust you will give the above-mentioned concerns due consideration and remain at the Commission’s disposal for further information.
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