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Fédération Nationale des Activités de Dépollution et de l'Environnement

FNADE

FNADE represents France's waste management industry, providing recycling, recovery and environmental services across the circular economy value chain.

Lobbying Activity

Meeting with Didier Millerot (Head of Unit Financial Stability, Financial Services and Capital Markets Union)

13 Nov 2025 · Discussion on waste related activities under EU Taxonomy

French waste industry urges strong demand measures for EU recycled materials

6 Nov 2025
Topic — New EU regulation to establish single market for recycled materials and circular economy.
Message — The organization requests mandatory minimum recycled content targets across key sectors, robust mirror clauses for imports, and financial EPR schemes with balanced governance involving waste management companies. They argue current weak demand, particularly for recycled plastics, threatens the viability of European recycling industry.1234
Why — This would stabilize prices, secure treatment volumes, and protect their recycling facilities from bankruptcy.56
Impact — Non-EU material exporters and virgin plastic producers lose market access and competitive advantage.78
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French waste group warns against favoring chemical recycling

19 Aug 2025
Topic — Establishing common rules for calculating recycled content in plastic beverage bottles.
Message — FNADE advocates for the prioritisation of mechanical recycling over chemical recycling in the legislation. They demand a robust mirror clause to safeguard EU recyclers against cheap foreign imports. The group wants a polymer-only methodology to provide greater transparency for the consumer.123
Why — This would help French mechanical recyclers survive the current crisis and unfair competition.45
Impact — Chemical recyclers lose the competitive edge granted by the proposed fuel-use exempt methodology.6
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FNADE demands economic viability in EU raw materials recovery

25 Jul 2025
Topic — Identifying products and waste streams with potential for critical raw materials recovery.
Message — The industry insists that recovery programs prioritize economic viability and avoid mandatory sorting when it is not cost-effective. They also recommend bridging investment gaps by including sewage sludge treatment in the EU Taxonomy.123
Why — This prevents waste management firms from being forced to perform unprofitable material extraction.4
Impact — Environmental groups may see lower recovery rates if extraction is restricted to profitable operations.5
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FNADE demands rigorous impact assessment for waste sector ETS inclusion

7 Jul 2025
Topic — The consultation reviews the EU emissions trading system and market stability reserve by 2026.
Message — FNADE demands any decision on waste incineration follow a rigorously conducted impact assessment. They request that interviews be directed to stakeholders with proven expertise in relevant areas.12
Why — This strategy helps the waste industry delay or avoid expensive carbon pricing costs.3
Impact — Climate advocacy groups lose policy momentum due to calls for further research delays.4
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Meeting with Cristina Dias (Cabinet of Commissioner Maria Luís Albuquerque), Elena Arveras (Cabinet of Commissioner Maria Luís Albuquerque)

5 Mar 2025 · Waste to energy – Taxonomy

FNADE seeks clarity for waste-to-energy carbon capture projects

25 Oct 2024
Topic — Methodology for calculating greenhouse gas emission savings for low-carbon fuels.
Message — FNADE requests clarification that fossil CO2 from waste-to-energy plants qualifies for producing recycled carbon fuels. They believe no sector should be restricted if it offers recovery opportunities.12
Why — This would allow the sector to develop new projects and receive incentives for carbon recovery.34
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Response to Measures to reduce microplastic pollution

15 Jan 2024

FNADE, the French association for recycling and waste management fully supports any initiative aiming to reduce the release of any hazardous substance in the environment. The proposal made by the European Commission for a specific regulation in order to reduce the release of microplastics along the value chain of plastics production, recycling, reprocessing and transporting should enable to reduce, as it is already the case in France, the total amount of losses. Please find attached our main comments on the Commission's proposal.
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French waste industry backs mandatory recycled content for vehicles

29 Nov 2023
Topic — The European Commission is revising rules on vehicle design and recycling.
Message — The group supports mandatory recycled content but asks for a four-year implementation delay. They also oppose a ban on mixing different waste types during the shredding process.123
Why — This proposal would secure a steady supply of raw materials for European recyclers.4
Impact — Vehicle producers could lose exclusive rights to purchase high-quality recycled plastic resins.5
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Meeting with Maria Noichl (Member of the European Parliament, Rapporteur for opinion)

22 Nov 2023 · Soil health

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

14 Nov 2023

FNADE, the French association for recycling and waste management fully supports any initiative that aims both to reduce waste production (in particular through prevention) and to promote recycling and circular economy. Nevertheless, we would like to take the opportunity to make some comments on the Waste Framework Directive revisions proposal. Thus, if we support the principle of the revision of the Waste Framework Directive which objective is to reduce and propose a better management of waste, we would like to draw attention to a number of points that could have perverse effects. Please find them in the attached document.
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French waste industry urges faster EU soil restoration targets

2 Nov 2023
Topic — The proposed directive aims to establish monitoring and resilience frameworks for healthy soils.
Message — FNADE calls for intermediate targets and a methodology to reach 100% healthy soils. They want sustainable management practices defined within two years instead of four. The directive should also emphasize the benefits of using organic fertilizers.12
Why — Stricter soil health requirements would boost demand for the sector's remediation and composting services.34
Impact — Synthetic fertilizer producers would see their market share decline as organic alternatives are prioritized.5
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Response to Ecodesign for Sustainable Products - Product priorities

11 May 2023

FNADE, the French association for waste management and environmental services welcomes the initiative of the Commission to identify categories of new products and measures that need to be addressed as a priority in the revision of the Ecodesign for Sustainable Products Regulation. Indeed, in order to improve the circularity of products, all the stages of a products life and end-of-life must be taken into account. Ecodesign having an important impact on most of these stages, it is necessary to implement new eco-design requirements and to target the relevant products and measures. Please find attached our detailed position.
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French waste industry urges taxonomy to reflect operational reality

3 May 2023
Topic — The EU is establishing a classification for sustainable investments in water, circular economy, and pollution prevention.
Message — FNADE requests that the taxonomy include sorting as a pre-condition for recycling and recognize commingled collection systems. They also urge for the inclusion of sewage sludge spreading and removing specific methane monitoring requirements.123
Why — Broadening the criteria allows more waste facilities to qualify for green financing and lowers compliance costs.45
Impact — Environmental advocates lose oversight if methane monitoring requirements are removed as the industry suggests.6
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French waste association urges industry role in EU packaging rules

19 Apr 2023
Topic — Review of EU requirements for packaging design, recycling, and waste prevention measures.
Message — FNADE requests that the recycling industry helps draft technical delegated acts. They suggest adding mandatory collection targets and minimum recycled content for all materials. The association also seeks clearer definitions to prevent market volatility and uncertainty.123
Why — Greater certainty would protect business plans and prevent disruption of the recycling market.4
Impact — Paper, cardboard, and metal packaging manufacturers would face faster mandatory recycled content requirements.56
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FNADE urges EU to adopt polluter pays wastewater model

20 Feb 2023
Topic — The European Commission is updating the rules for managing and treating urban wastewater.
Message — The association demands that industrial and domestic waste be separated at the source to improve treatment quality. They request European standards for sewage sludge to encourage its use as fertilizer. While supporting the polluter pays principle, they oppose creating new administrative bodies to collect funds.123
Why — It reduces operational expenses and prevents the creation of redundant bureaucratic organizations.4
Impact — Manufacturers of chemicals and microplastics would be forced to fund treatment for their pollutants.5
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Response to Fitness check of how the Polluter Pays Principle is applied to the environment

9 Dec 2022

FNADE fully supports the Polluter Pays Principle. Indeed, the financial repercussions of an activity, an industrial accident, or the production of product (especially at its end-of-life stage) should legitimately be held by the one who caused it, and these costs have not to be supported collectively. Please find attached our detailed position.
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Response to European Critical Raw Materials Act

25 Nov 2022

FNADE, the French association for waste management and environmental services supports the willingness of the European Commission to secure the supply of critical raw materials. European self-sufficiency and autonomy are more than ever needed and dependence on third countries must be drastically reduced. In the current geopolitical situation, waste management has a crucial role to play to improve the supply chain: collecting, sorting, recovering and recycling these materials is a great challenge for European economy and resilience. Please find attached our feedback.
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Response to Evaluation of the 2012 Directive on waste from electrical and electronic equipment

3 Nov 2022

In line with the Green Deal, the Circular Economy Action Plans new Batteries Directive and the future revision of the RoHS Directive, FNADE fully supports the Commission's initiative to revise the Directive to frame WEEE collection and recycling targets. FNADE would like to recall that the current framework given by the WEEE Directive is rather satisfactory and would like the future directive to keep its main principles regarding its use and content. However, certain provisions could be changed to make the directive more effective, to promote the achievement of collection and treatment objectives, and to ensure greater consistency with other European legislation. Please find attached our detailed position.
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FNADE backs EU recycling alerts while seeking industrial incentives

29 Jul 2022
Topic — Evaluation of national progress toward European recycling and landfill reduction targets.
Message — FNADE supports the warning mechanism to identify Member States at risk of missing deadlines. They urge mandatory recycled content and including waste-to-energy within the green taxonomy. They also demand competitive access to recycled raw materials without priority rights.123
Why — Taxonomy inclusion would provide the necessary financial incentives for advanced treatment infrastructure.45
Impact — Large producers who want priority access to recycled materials would lose their advantage.6
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French Waste Industry Urges Precise Reporting and Data Validation

27 Jun 2022
Topic — Revision of the European Pollutant Release and Transfer Register to improve industrial emissions transparency.
Message — FNADE requests clearly defined recovery and disposal operations to prevent mistakes in waste reporting. They recommend using specific waste codes and cross-validating data to correct false information.12
Why — Accurate reporting prevents the waste industry from being unfairly represented by flawed data sets.3
Impact — Companies seeking to keep their emission levels secret will face higher transparency requirements.4
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French waste industry urges flexibility in industrial emission limits

23 Jun 2022
Topic — The consultation seeks to update EU rules for reducing industrial emissions into air, water, and soil.
Message — FNADE advocates for environmental performance levels to remain non-binding benchmarks rather than strict legal requirements. They argue that setting the strictest possible emission limits is a political display rather than a practical approach. The group also prefers publishing environmental indicators online instead of full management systems.123
Why — Maintaining flexible emission ranges allows plants to avoid excessive reagent consumption and associated operational costs.4
Impact — The environment could suffer if strict limit values cause negative impacts across the whole life cycle.5
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Response to Sustainable Products Initiative

22 Jun 2022

Please find FNADE's feedback attached.
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French waste association urges inclusive carbon removal certification framework

29 Apr 2022
Topic — The EU is creating a framework to monitor and verify carbon removal activities.
Message — FNADE recommends extending the certification scope to all operators providing carbon removal. They argue rewards must be shared equally across the value chain to trigger investments.12
Why — Inclusive certification provides waste companies with funding for innovative carbon removal techniques.3
Impact — End-users lose exclusive financial benefits if rewards are shared more broadly among operators.4
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Response to Amendment to the Regulation (EU) No 1025/2012 European standardisation

6 Apr 2022

FNADE, the French waste management private companies association, welcomes the willingness of the European Commission to clarify the functioning of the European standards bodies (CEN, Cenelec and ETSI) and establish a certain balance in the representation of the national standards bodies. More transparency and the inclusion in these bodies of stakeholders directly affected by the standards is clearly a very good initiative. The implementation of new rules should be carefully monitored in order to ensure that consensus is always preserved. Furthermore, FNADE would like to suggest that the European standardisation bodies should take into consideration when working on establishment of new standards the definitions of the “working draft” of ISO standards on circular economy. This would allow for more consistency and would promote a better understanding of the new and revised European standards.
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Response to Soil Health Law – protecting, sustainably managing and restoring EU soils

16 Mar 2022

FNADE, the French association for waste management and environmental services, fully supports the European Commission’s initiative on soils strategy as it is crucial to promote soils in healthy condition. Please find attached FNADE's feedback.
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Response to Review: Restriction of the use of hazardous substances in electronics

14 Mar 2022

FNADE, the French association for waste management and environmental services, fully support this Commission’s initiative in order to promote cleaner material cycles and environmentally sound waste treatment of EEE. Please find attached FNADE's comments.
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Response to Technical amendments to the Fertilising Products Regulation

9 Mar 2022

FNADE, the French private companies waste management and environmental services association welcomes the amending regulation proposal on fertilising products. Nevertheless, FNADE’s members still have a few concerns regarding the proposal and would like to take the opportunity to express them in the paper attached.
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Response to Waste Framework review to reduce waste and the environmental impact of waste management

18 Feb 2022

FNADE, the French private companies’ association for waste management and environmental services, welcomes this new initiative from the European Commission in order to reduce waste production, to improve separate waste collection and high-quality recycling avoiding contaminations and to promote oils regeneration. Please find FNADE's feedback attached.
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Response to Measures to reduce microplastic pollution

18 Jan 2022

FNADE, the French association for waste management and environmental services would like to take the opportunity to give feedback and highlight some points. You may find our feedback attached.
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Response to Update of concentration limit values of persistent organic pollutants in waste

21 Dec 2021

Please find FNADE's (the French association for waste management and environmental services) feedback attached.
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Response to Revision of the Energy Tax Directive

18 Nov 2021

FNADE, the French association for depollution and environmental activities, welcomes the revision of the Energy taxation Directive (ETD). Please see document attached for FNADE's comments.
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Response to Review of Directive 2012/27/EU on energy efficiency

18 Nov 2021

FNADE the French association for waste management and environmental services companies welcomes the Proposal of the European Commission to Review the Directive 2012/27/EU on energy efficiency aligning the energy efficiency targets with the 2030 EU climate ambitions. Please see document attached for FNADE's comments.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Nov 2021

FNADE welcomes the European Commission’s proposal for reviewing the 2018 Renewable Energy Directive (REDII) and adjusting its rules to the latest EU climate ambitions for 2030. Please see document attached to see Fnade's comments.
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Response to Carbon Border Adjustment Mechanism

8 Nov 2021

Please find attached FNADE's contribution
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Response to Updating the EU Emissions Trading System

8 Nov 2021

Please find attached FNADE's contribution.
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Response to Policy framework on biobased, biodegradable and compostable plastics

26 Oct 2021

FNADE, French Private Companies National Association for Waste Management, is the professional organisation representing environmental industries. With 223 private member companies operating in the field of waste management, it represents 47,886 employees in France. 9.1 billion euros in turnover and 768 million euros in investment. It is a member of the European Federation of Waste Management and Environmental Activities (FEAD). FNADE welcomes the opportunity to give the EC a feedback, that you will find attached.
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Response to European Bioeconomy Policy: Stocktaking and future developments

31 Aug 2021

FNADE is the French waste management and environmental services private companies’ association. As an essential stakeholder in environment services, FNADE very welcomes the Bioeconomy Strategy. As a waste management key player FNADE would like to share with the Commission its position on this wide topic. Therefore, you will attached FNADE's position paper.
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Response to Standardisation Strategy

23 Jul 2021

FNADE (French Private Companies Association for Waste Management), strongly supports the Commission's will to improve standardisation criteria. Setting international standards is key to promoting the EU's strategic capacity. This important work on revising standards must be aligned with the objectives of the green deal and Taxonomy in order to promote more eco-design, more recyclability, more recycling, more recycled contents and less hazardous substances in new products. considering the three dimensions of sustainable development (environmental, social and economic). It should also be consistent with the principles and framework of circular economy developed internationally by ISO TC 323 taking into account that new products are commercialized in the world market. It is crucial to ensure that existing standards can be reviewed and updated, especially those limiting or even prohibiting the use of Secondary Raw Materials. On the contrary, it is these secondary materials that should be promoted (an ISO standard is currently in development on this topic – see ISO TC323 work program). However, FNADE would like to remind the European Commission that introducing standards for recycled materials should not be a priority as recyclers have to meet their client’s specifications and technical requirements. The quality of recyclates is directly linked to 1/ the type of product and 2/ sector-specific health and safety requirements. Developing new standards for Secondary Raw Materials would be a lengthy process which might eventually delay the uptake of recycled materials by industry without adding value to the current recycling chain. Indeed, standards would impose costly technical constraints on the recycled materials which do not necessarily meet the quality requirements (higher or lower) imposed by the future use of the product. Thus FNADE would like to suggest that, in line with current practices, recycled materials should only comply with the requirements decided by the client using these materials depending on the use that will be made of the new product. Moreover in a circular economy, the use of the product should be considered for the selection of appropriate raw materials and should not lead to any differentiation criteria between materials of different origins (secondary or primary).
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Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

17 Jun 2021

FNADE: position paper on SUP directive implementing act proposal FNADE, the French Waste Management association would like to take the opportunity to make some comments regarding the European Commission’s proposal on SUP directive guidelines: First, in the draft proposal the word “collection” in article 2, paragraph7 seems misused and seems to correspond more to “recycling”. As a reminder, Directive (EU) 2019/904 only refers to collection target and not to recycling target (article 9). FNADE would like this point to be improved, i.e. there is no certainty whether the calculation method is based on the collection or on the recycling weights (i.e. after sorting and removal of the refusals) which is not the same approach. Indeed, Article 2, paragraph 7. of the delegated act makes the following measurement “The weight of waste single-use bottles collected separately in accordance with paragraph 1, point (b), shall be measured at the output of the sorting operations” which corresponds more to the recycling calculation than to the collection for recycling calculation. That’s why, FNADE proposes to replace this sentence by: “the weight of waste single-use bottles collected separately in accordance with paragraph 1, point (b), shall be measured at the input of the sorting operations”. FNADE would propose, besides the counting electronically made at the container, to use data already collected and to eventually add a ratio of beverage bottle contained in the bales calculated via a characterization campaign which financial and technical burden would not be supported by operators. Indeed, these monitoring data do not bring any additional useful information in the treatment and recovery of the waste and the waste management companies must not be financially responsible for this campaign of sampling as described in the article 4 of the present delegated act.
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Response to Revision of EU legislation on hazard classification, labelling and packaging of chemicals

1 Jun 2021

Please find attached the contribution from FNADE to the Revision of EU legislation on hazard classification, labelling and packaging of chemicals.
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Response to Revision of EU legislation on registration, evaluation, authorisation and restriction of chemicals

1 Jun 2021

Please find attached FNADE's feedback to the revision of REACH Regulation to help achieve a toxic-free environment.
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Response to Thermal oxidation materials and derivates in EU fertilising products

15 Feb 2021

FNADE's feedback to ash-based delegated act FNADE is the french association for waste management, soils remediation and organic recovery. FNADE would like to draw the attention of the Commission to the following point of the draft annex of the draft delegated act on ash-based (paragraph 1, annex I): 1. An EU fertilising product may contain thermal oxidation materials obtained through thermochemical conversion under non-oxygen-limiting conditions exclusively from one or more of the following input materials: (a) living or dead organisms or parts thereof, which are unprocessed or processed only by manual, mechanical or gravitational means, by dissolution in water, by flotation, by extraction with water, by steam distillation or by heating solely to remove water, or which are extracted from air by any means, except (*): – materials originating from mixed municipal waste, – sewage sludge, industrial sludge or dredging sludge, and – animal by-products or derived products within the scope of Regulation (EC) No 1069/2009; (e) sewage sludge from municipal wastewater treatment plants, other than animal by-products or derived products within the scope of Regulation (EC) No 1069/2009; ISSUE: This suggests that food processing industries (slaughterhouses, ready meals industry, ...) likely to contain ABP (Anima by-products) are excluded while urban wastewater treatment plants are included for the production of ashes eligible under CMC 13. FNADE would like this point to be clarified.
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Response to Pyrolysis and gasification materials in EU fertilising products

15 Feb 2021

FNADE's feedback to biochars delegated act FNADE is the french association for waste management, soils remediation and organic recovery. FNADE would like to draw the attention of the Commission to the following points of the draft annex of the draft delegated act on biochars (paragraph 1, annex I): 1. An EU fertilising product may contain pyrolysis or gasification materials obtained through the thermochemical conversion under oxygen-limiting conditions of exclusively one or more of the following input materials: (a) living or dead organisms or parts thereof, which are unprocessed or processed only by manual, mechanical or gravitational means, by dissolution in water, by flotation, extraction with water, by steam distillation or by heating solely to remove water, or which are extracted from air by any means, except (*): – materials originating from mixed municipal waste, – sewage sludge, industrial sludge or dredging sludge, and – animal by-products or derived products within the scope of Regulation (EC) No 1069/2009; Issue: This suggests that food processing industries (slaughterhouses, ready meals industry, ...) likely to contain ABP (Animal by-products) and urban wastewater treatment plants are excluded for the production of biochar eligible as CMC 14 while wastewater treatment plant ashes are eligible as CMC 13. FNADE would like this point to be clarified.
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Response to Precipitated phosphate salts and derivates in EU fertilising products

15 Feb 2021

FNADE's feedback to Struvites delegated act FNADE is the french association for waste management, soils remediation and organic recovery. FNADE would like to draw the attention of the Commission to the following point of the draft annex of the draft delegated act on struvites: 12. The sum of aluminium (Al) and iron (Fe) in precipitated phosphate salts or derivates shall not exceed 10% of the dry matter of the precipitated phosphate salts or the derivates. Issue: The current proposition (due to paragraph 12 of the annex) removes vivianite from the scope of the regulation. Vivianite recovery in WWTP represents a huge potential to increase P-recovery in the EU since it is applicable to WWTP with iron-based P-removal (the great majority in EU), being complementary to struvite as a technology. Proposition: • As vivianite is largely composed of Fe and in order to include Vivianite in the scope of the regulation, remove the Fe limitation in point 12 • Vivianite is a magnetic material. It is recovered in WWTP by magnetic means. "Magnetic separation" must, thus, be included in Point 1 when the allowed processing techniques are described.
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Response to Climate change mitigation and adaptation taxonomy

18 Dec 2020

FNADE feedback on delegated act establishing the list of green activities contributing substantially to climate change mitigation or climate change adaptation FNADE is the french association representing waste management private companies covering the whole value chain. GENERAL CONSIDERATIONS ON TAXONOMY In the context of the current drafting of the first delegated act on taxonomy covering activities “substantially contributing” to climate adaptation and mitigation, FNADE (the French environmental services private companies’ association) would like to highlight the whole waste management sector as being a key player in the circular economy and climate neutrality, especially through recycling and avoiding GHG emissions. In particular, FNADE thinks Waste to Energy, dealing with the non-recyclable sorted waste and recovering its renewable and recovered energy fraction in substitution to fossil fuels, should be part of the taxonomy and considered as a green activity especially due to its key role in green energy autonomy at local level producing heat for buildings and industry. In addition, FNADE would like to stress that the future ambitious objectives of the European Commission for energy efficiency policy would be more easily achieved with the Waste-toEnergy activities. Then, FNADE would like the waste management sector to be further consulted and associated with the European taxonomy implementation policy as it can provide technical and necessary inputs into the formulation of these delegated acts. COMMENTS ON DELEGATED ACT PROPOSAL Concerning the Commission’s proposal, FNADE would like to take the opportunity to highlight several specific issues in Annex 1 concerning the following points: 5.5 on separate collection of waste Under the DNSH point 4, it is important to note that selective collection at source is not necessarily the best option and taxonomy does not consider the fact that the waste can be sorted downstream afterwards. The current wording for Circular Economy “Separately collected waste fractions are not mixed in waste storage and transfer facilities” is not positive as it would undermine the purpose of the sorting facilities. 5.8 on composting of biowaste It is necessary to specify under the DNSH point 5 that plastics are not part of soil improvers but rather cause for pollution. Compostable plastics (which include bio-sourced plastics), 2020/12/18 despite receiving much attention, do not in fact decompose rapidly nor completely in the environment and nor in the timeframe of industrial composting sites. Furthermore, compostable polymers contain on the one hand the plastic molecule itself and on the other hand a number of additives that give special properties (Anti-oxidant, anti UV, demoulding agents, pigments….). Even if the base molecule can degrade, other additives could be released in the soil and in the oceans. 5.10 on landfill gas capture and utilisation « Installation and operation of infrastructure for landfill gas capture and utilisation in permanently closed landfills using new or supplementary dedicated technical facilities and equipment installed during or post landfill closure. » Actually, it is unclear in the document if these provisions shall apply to cells or landfills that are still in operation or already permanently closed. Notwithstanding the screening criteria n°1 “The landfill has not been opened after July 2020”, we would like to insist on the absolute necessity for landfills either in operation or closed, to be equipped with landfill gas capture for the sake of reducing GHG emissions, especially methane. We observe that the situation is very different from one part of the world to another and a necessary condition for improvement of these discrepancies is to encourage strongly investments related to that question. Therefore, we suggest modifying the wording of the activity defined in the draft act.
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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

Please find here attached FNADE's feedback on National emissions reduction targets (Effort Sharing Regulation) – review based on 2030 climate target plan.
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Response to Updating the EU Emissions Trading System

26 Nov 2020

Please find here attached FNADE's feedback on updating the EU emissions trading system (ETS).
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Response to Revision of EU legislation on end-of-life vehicles

18 Nov 2020

The Revision of Directive 2000/53/EC on end-of-life vehicles will lead to update this current legislation to economic reality and to improve coherence with the aims of the Green Deal and the Circular Economy Action Plan. FNADE members, as key players of recycling but also of the waste treatment chain, would like to highlight the most crucial points in order to reach the Green Deal objectives in favour of a more circular economy and a Zero-Pollution ambition. Better design for better dismantling and recycling Eco-design is the first step to improve the recyclability of various parts, as well as ensuring the efficiency of recycling processes. Thus, it is crucial to make dismantling and sorting easier and more thorough before the final shredding step. Once a vehicle is shredded, recovering materials become much more complex and costly any prior step allowing effective separation of valuable spare parts, recoverable materials and contaminated fractions should be preferred. Beyond dismantling operations, the intrinsic recyclability of specific parts should be ensured by working together with waste management companies and potential clients for Secondary Raw Materials: without actual outlets, recyclability remains theoretical even if technically feasible. Phasing out Substances of Concern and decontaminating materials to ensure high-quality recycling To improve recycling performance, FNADE calls for a reduction of additives contained in polymers or other materials. Substances of concerns impair the quality of recyclates and should, therefore, only be used when necessary. Alternatively, a prior decontamination step for specific streams can be required to ensure a safe return back into the loop. Complex products such as vehicles require more than one waste treatment option – Extract hazardous waste When dismantling end-of-life vehicles, different types of liquid and solid waste streams are extracted and should be treated in accordance with the waste treatment hierarchy. While recycling remains the most desirable option for most waste streams, others should be either safely recovered or disposed of to avoid any harm to the environment or human health. The average age of an end-of-life vehicle is around 18 years. So, for vehicles currently in circulation, components containing dangerous substances (dashboards, seats, bumpers, etc.) must be removed as soon as possible, before shredding, in order to be treated separately. It is essential to avoid dispersing hazardous substances in the form of BFR in the secondary raw material. The need for steady, efficient recycling markets FNADE strongly supports the Commission’s proposal to introduce mandatory minimum recycled contents in the current legislation. Creating secondary raw material markets is a crucial lever to reach the ambitious recycling targets and further reduce GHG emissions, particularly through avoided emissions due to recycling. This requirement should apply to the most common material streams such as glass, plastics and metal. In line with the previous paragraph, complex and potentially hazardous items such as batteries or electronic equipment should be carefully assessed so that specific parts or substances could be either recycled or recovered. Another important point would be to clarify who should pay for the dismantling. Taking into account the specificity of hazardous waste FNADE emphasises the need for specific solutions for hazardous or hazardous-containing substances from end-of-life vehicles: FNADE recommends to lower hazardous substances thresholds at the eco-design phase and gradually phase out these substances in order to reduce their potential impact on health and the environment, thereby avoiding the reintroduction of legacy substances into the recycling loop. Getting more information on these substances and components is crucial to improve the environmental sound management and traceability of these items. SCIP database will be a useful tool.
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Response to Sustainable Products Initiative

2 Nov 2020

Feedback to the Sustainable Products Initiative FNADE, the French association of environmental services companies, welcomes the commission's new initiative on sustainable products, which will lead to implement a coherent policy framework both on product environmental footprint and on consumers information. FNADE members, part of the recycling chain, would like to highlight the most crucial points in order to achieve a more circular economy and a high-quality recycling in which consumers can trust: • First of all, Eco-design is the starting point without which it would be difficult to achieve the recycling targets. Indeed, reusable and repairable products wont’ become waste too quickly and as soon as they enter in the waste loop, they will be easier to recycle: easy dismantling, made with recyclable materials easily reincorporated… • Then, sustainable products should incorporate as much recyclates as possible. Secondary raw materials and recycling are the best way to reduce environmental footprint and associated negatives externalities such as virgin raw materials extraction and greenhouse gases emissions (GHG). • Finally, to achieve a zero-pollution ambition, as proposed by the European Commission, sustainable products should not contain substances of concern and these hazardous substances should be progressively phased out. FNADE welcomes the Sustainable Chemicals Strategy and will support any initiative which aims to have better information on hazardous substances contained in products in order to isolate and trace them so that they can be correctly treated and prevent them from contaminating new products through recycling. To achieve the circular economy targets and to support a sustainable product policy, FNADE would recommend some incentives and financial measures: - Mandatory minimum recycled content would be the first step to reduce environmental product footprint. It would also enable to achieve a more sustainable product policy as it would also reduce waste volume and boost recycling and circular economy. This requirement should also apply to imported goods. FNADE would recommend to impose the introduction of this measure, as proposed by the Commission, for packaging, batteries, plastics, vehicles and construction materials. FNADE also wishes that the reincorporation of paper would be considered in order to develop this sector in Europe. - Furthermore, setting up a green tax system such as a reduced VAT on products incorporating recycled materials would be a coherent and pragmatic move towards the ambitions of the Green Deal in order to improve material efficiency. - Green Public Procurement could also be a good tool to encourage sustainable products or services and to give a strong political signal in support of this initiative. Indeed, public actors need to address green public procurement for the major flows which concern public authorities: • Paper, • Automotive, • Buildings, • Packaging, • Textiles. - Environmental product footprint label, as proposed by the Commission, could also empower citizens to choose the better product and less harmful for environment. In the End, if the proposed Carbon Boarder Adjustment Mechanism is not only based on product energy content but also includes avoided emissions linked to its composition (virgin or secondary raw materials) and its transport from other countries to Europe, it could easily become an additional asset in the European Sustainable Products policy.
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

FNADE's feedback to the EU Action Plan “Towards a Zero Pollution Ambition for air, water and soil – building a Healthier Planet for Healthier People” FNADE, the French waste management and environmental services private companies association, welcomes the European Commission’s initiative on a Zero Pollution Ambition. This Action Plan, which is part of the Green Deal and in line with the Commission’s objectives on environment, health and biodiversity will enable to address and decrease pollution by setting up a stricter regulatory framework for specific activity sectors and by tackling historical or legacy pollution. This initiative is also a great opportunity to provide to European citizens a better quality of life and to empower them choosing more environmentally-friendly products in order to reduce resource consumption, hazardous substances and environmental footprint. Generally speaking, as a key player in depollution but also in waste management FNADE members have to deal with all the substances it contains (hazardous or not). Because they have to deal with waste and to ensure it will be correctly separated, sorted, recycled, recovered or treated in the best environmental way, they are at the heart of the implementation of a policy for a zero-pollution ambition. FNADE would like to remind the Commission some foregone conclusions but also some required and needed improvements in order to achieve this great ambition of Zero Pollution it strongly supports: Substances of concern Hazardous substances are everywhere in different types of products and they hinder recycling and waste treatment. FNADE would recommend to speed up the commission's policies to accelerate the phasing out of such molecules (Chemicals strategy, RoHS and POPs regulation review…). Subsequently, improved knowledge on hazardous substances contained in products would allow for better waste treatment, effective decontamination and avoidance of legacy substances in recycling processes. As a matter of fact, implementing and enforcing SCIP database will offer a major advantage to improve recycling. Furthermore, FNADE supports the assessment of substances through "a grouping approach" by family of substances/molecules. This would avoid the too frequent replacement of an assessed substance by another not yet evaluated but whose effects on health and the environment are more or less identical. Controlling emissions Reducing emissions into air and water is a challenge in order to achieve a zero-pollution ambition. FNADE supports E-PRTR and IED revisions which shall improve both data collection and emissions. Soils remediation The industrial heritage from some areas or large facilities are likely to cause serious damage to the environment and health, in particular through release into water and air. The Commission has pointed out the need to remediate these lands and FNADE strongly supports this initiative. Some FNADE members are specialized in soil remediation and treatment and would recommend to the Commission to propose a multi-year plan containing regulatory and financial measures to enhance soils quality within the EU. Quality of products and pollution reduction In order to reduce the environmental footprint of products and their negative effects on the environment, climate and health, FNADE supports the Commission initiative on Eco-design, Sustainable products and on Packaging reducing. Working upstream on the quality (hazardous substances free and durability), the dismantling ability and the recyclability of products is the right strategy in order to consume better and less. Furthermore, improving information on product quality and empowering consumers to decide of the better product is a key step to reduce pollution through individual choice. But according to the positive impact of recycling on resource extraction, waste reduction and GHG emissions avoidance, FNADE is asking for strong measures such as minimum obligatory recycled contents.
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

26 Oct 2020

Feedback to the Revision of the Regulation on the European Pollutant Release and Transfer Register (E-PRTR) FNADE, the French waste management and environmental services private companies’ association, welcomes the revision of the E-PRTR. Even though E-PRTR has given good results since 2007, the assessment studies have shown improvements were possible to tackle some weaknesses areas and this new initiative launched by the commission, which is part of the green deal's Zero Pollution ambition, will help to better address pollution from large industrial installations and to improve traceability of releases into air, water and land. FNADE would support options 2, 3, 4 and 5 in that they propose to first include additional sectors or pollutants, especially those of recent environmental concern and then to lower reporting thresholds. This should certainly permit to improve releases quality but also knowledge on emissions and should lead to enhance traceability in order to extend consumers information. Nevertheless, for any new extension of the scope of E-PRTR, requirements need to be as close and aligned as possible with the BREFs of this sector, especially if the BREFs have been recently revised. Furthermore, before any addition of pollutant, a consultation and an assessment need to be set up to attest the real benefit that can be provided from adding new substances within the scope of the E-PRTR. Aspect 5 proposes to improve, through reporting modalities, information already contained in the current E-PRTR such as waste transfers or releases in products which is one of the ways in which the regulation can be improved and FNADE subscribes to this proposal. But, concerning the possibility this regulation could be enhanced in order to be more consistent with climate, energy and circular economy policies, FNADE wonders and does not understand how E-PRTR could provide more additional data, in conjunction with IED, on resource consumption such as use of energy or raw materials unless the scope and reporting methodology are brought into line with the new standards. FNADE thinks E-PRTR’s data for public and consumers are very consistent and need to maintain this level of reliability and of information but not necessarily become a tool for a more circular economy: data on consumption need to be protected for industrial safety reasons and for the respect due to competition law.
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Response to Review of Directive 2012/27/EU on energy efficiency

21 Sept 2020

FNADE Feedback – Energy efficiency FNADE, the french association for waste management and environmental services, welcomes the European initiative for the Review of the Directive 2012/27/EU on energy efficiency. As a matter of fact, the waste management sector is a key player in the circular economy loop, in particular through its action in recycling, which avoids GHG emissions, reusing resources and recycled materials but also through its ability to produce and recover energy from residual waste (Waste to Energy). That’s why FNADE would like to remind synergies need to be set up and maintained between energy and waste policies. Obtaining more energy efficiency is crucial to achieve the ambitious 2030 european climate targets as the European carbon neutrality, that’s why FNADE would recommend the option 3 from the commission’s proposal aiming to revise the EED. Non regulatory measures and the introduction of non-regulatory alternative policy instruments would also be useful to inform and to help citizens and companies to make the best choice but this will not be sufficient. We need a very strong will and policy promoting energy efficiency but also regulatory and financial measures to address the gap existing between today’s situation and 2030 green deal targets. Low carbon fuels resulting from waste should be positively treated in the EU energy market compared to fossil fuels.It is crucial to financially and regulatorily incentivize waste sector while raising prices of fossil fuels in order to optimize the energy efficiency of the plants, e.g. : • Waste incineration produces energy (heat or steam or electricity), nevertheless, waste heat would need support to be recovered. • SRF (Solid recovered fuels) production and use suffer from a lack of competitiveness compared to fossil fuels • Methane recovery from landfilling, as we have already explained in our contribution to the « methane strategy », represents a high potential of energy production. If the captured and unavoidably produced methane is not recovered, it automatically becomes a harmful source for climate (due to high emissions factor) as it would be a lost energy source. We would recommend to the Commission to include « Waste to Energy » in the green taxonomy. In the end, FNADE would like to suggest that energy efficiency policy should take into consideration the least energy-intensive products and promote recycling, in particular through mandatory minimum contents of recycled materials.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Feedback – Renewable Energy Directive FNADE, the french association for waste management and environmental services welcomes the European initiative for the Revision of Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources. As a matter of fact, waste management sector is a key player in the circular economy loop, in particular through its action in recycling, which avoids GHG emissions, reusing resources and recycled materials but also through its ability to produce and recover energy from residual waste: part of it comes from renewable sources (biogenic fraction and biomass). That’s why FNADE would like to remind synergies need to be set up and maintained between energy and waste policies. Developing energy from renewable sources is crucial to achieve the European climate targets and carbon neutrality. It is now even more necessary to phase out progressively solid fuels. It should also enhance energy supply and reduce European dependency on imported fossil fuels. Raising up the objectives and the targets is necessary in order to achieve the goals contained in the green Deal and the climate target plan, but first of all, we need a genuine support policy including financial and regulatory incentives and aiming to eliminate market barriers for use of alternative fuels. Furthermore, waste industry needs visibility in order to sustainably invest in producing energy from renewable sources. It is particularly true for the biomass sustainability criteria which have already been reviewed during clean energy package revision in 2018. In the waste sector, some regulatory and financial incentives (such as buy-back rates or investment support …), are especially needed in order to develop new renewable energy industries and to more efficiently fight against low fuel prices. This would be necessary in particular for waste heat and methane recovery, as well as for biofuels produced from used edible oils. The Waste to Energy sector is a part of energy supply in Europe and due to the renewable part of energy produced should be included in the taxonomy green list. FNADE would also point out that Solid Recovered Fuels (SRF) or Refuse Derived Fuels (RDF) (produced from residues of non-recyclable, non-hazardous municipal or industrial and commercial waste, such as paper, cardboard, wood, textiles, etc.) are composed from more than 60% of biomass (according to a recent french study). This could be a significant part of the production of renewable energy. This new industry needs to be supported because of the harmful competitiveness of the very cheap fossil fuels. Furthermore, it gives to residues an economic value by recovering the energy content of waste and is an essential complement to material recovery as a useful component of the circular economy loop. FNADE would like to highlight that the articles 25 and 27 referring to recycled carbon fuels, are not sufficiently prescriptive and do not give the necessary framework to correctly and fully implement the related terms and conditions of use. In the annexes, the calculation methods do not take into account the recycled carbon fuels. This clearly prevents from developing this activity. In the end, FNADE would like to point out the great opportunity the hydrogen strategy could provide in the next few years but reminds hydrogen production will be a tremendous asset only if it can be produced from renewable energy.
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Response to Empowering the consumer for the green transition

31 Aug 2020

Feedback on the consumer policy – Empowering the consumer for the green transition FNADE, the french association for waste management welcomes this essential initiative that will invite each consumer to fulfill a role in the implementation of the Green Deal thanks to reliable and environmental sustainable information. For the environmental services sector, whose business is to transform waste into new resources, the most important demand is to support the demand for and use of recyclates. Each consumer has a major rôle to play in the circular loop to put pressure on the product producer. More and more consumers aim to use sustainable product in order to reduce their environmental footprint and to achieve the transition to a circular economy and carbon neutrality. But getting reliable information on product is proving challenging and consumer are getting lost in the amount of the many existing labels. As long as their calculating methodology is not harmonized and not based on identical criteria the information they are supposed to give on the product footprint is not really reliable because of the differences of the elements considered during their elaboration. This, unfortunately leads, as pointed out by the Commission, to misinformation on early failure, lifespan, repairability or recyclability of the products. Having a common and reliable label built with an harmonized method on the basis of PEF/OEF should be a significant improvement. That’s why FNADE supports the European « sustainable product policy » and PEF/OEF methods focusing on the substantiation of environmental claims using product and organization environmental footprint to make products fit for a climate-neutral, resource-efficient and circular economy. This calculating method could include criteria such as mandatory minimum recycled content, energy efficiency, recyclability… which are really GHGs emission reducers. The consumer law, aligned with the European initiative on the product environmental performance should seek to jointly establish a coherent policy framework whereby sustainable goods, services and business models become the norm and consumption patterns are more sustainable. FNADE believes it should significantly reduce the environmental footprint of products consumed in the Union and contribute to the EU’s objective of climate neutrality by 2050. But beyond PEF/OEF, FNADE supports the objectives of the Green Deal and the Circular Economy Action Plan which aim at redeploying industries in Europe and at developing recycling and a strong European market of secondary raw materials. FNADE wishes to recall the interest of producing in short loops with recyclates limiting the emissions associated to the transport of raw materials or final products contributing thus to climatic benefit, especially in terms of avoided emissions. A task that could be also embrace through the carbon border adjustment mechanism. FNADE’s members which are essential actors of the recycling chain, wish to produce high quality secondary raw materials from recycling and to be able to supply a large European market of the circular economy in particular thanks to research, innovation and the quality of their installations. However, FNADE would like to remain that the environmental constraints on European companies which aim to achieve the shared objective of carbon neutrality must also apply on companies outside Europe in order to keep a level playing field. This remark which is relevant for the labelling of a product's performance and carbon footprint is also valid for all regulatory requirements (mandatory minimum recycled content, energy efficiency, recyclability, etc.).
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Response to Environmental claims based on environmental footprint methods

31 Aug 2020

FNADE, the French association of environmental services companies, welcomes the commission's new initiative to improve product performance as well as the information on this performance and thus help consumers make a reliable choice. Calculating the environmental performance of a product and its carbon footprint is quite complicated because of the many different criteria to be taken into account (quantity of raw materials and energy required for its manufacture, repairability, estimated lifespan, recyclability, GHGs emitted during the transport of raw materials and between production and consumption place ...). The European Commission and the JRC have been working with European companies for several years to establish a common and harmonised calculation method (PEF/ OEF) which has been presented last spring. This methodology, is a first step and could undoubtedly enable consumers to base their choices on clearer and, above all, reliable information. The PEF should also position Europe as a leader on issues related to consumer information and should gradually be extended to imported products. Reducing the carbon footprint of a product requires reducing all the externalities linked to its manufacturing. That’s why FNADE wishes to first remind the interest of producing in short loops limiting the raw materials and products transport emissions but also to point out the environmental and climatic benefit of recycling by using secondary raw materials, especially in terms of avoided emissions. This is why FNADE fully supports the implementation of a common methodology that would allow reliable information on the environmental performance of products. But beyond PEF or OEF, FNADE supports the objectives of the Green Deal and the Circular Economy Action Plan which aims at redeploying industries in Europe and at developping recycling and a strong European market of secondary raw materials. FNADE’s members, which are part of the recycling chain, wish to produce high quality raw materials from recycling and to be able to supply a large European market of the circular economy in particular thanks to research, innovation and due to the quality of their plants. However, they recall that the environmental constraints on European companies which aim to achieve the shared objective of carbon neutrality must also apply on companies outside Europe in order to keep a level playing field. This remark which is relevant for the labelling of a product's performance and carbon footprint is also valid for all regulatory requirements (mandatory minimum recycled content, energy efficiency, recyclability, etc.).
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

5 Aug 2020

Feedback on the review of the requirements for packaging and other measures to prevent packaging waste FNADE, the French association for waste management, welcomes the European Commission's initiative to reduce and better recycle packaging waste. First of all, this initiative will have to ensure that the reusability of packaging does not hinder its recyclability at the end of its life. Eco-design As actors in recycling and waste management, FNADE’s members companies play a crucial role in the implementation of a more circular economy and a zero-pollution environment. They must deal with packaging waste which are sometimes difficult to recycle because of their composition or design. They really need packaging made of traceable raw materials and free of substances that interfere with the recycling process. Packaging design obligations are therefore a first necessity. However, the current regulations, do not provide the necessary incentives because they are not fully aligned with the waste hierarchy. Worse, current trends show an increase of type of packaging that is very difficult to recycle (flexible packaging, multilayer composites, biodegradable plastics or biobased plastics made of non-recyclable polymers). The packaging collection is also an important challenge in order to massify the flows, develop a secondary raw materials market and promote the economic balance. To be efficient, the recycling industry needs a secondary raw materials market decoupled from the virgin materials one which currently remains far less expensive for most of them. As long as the environmental benefits (low carbon footprint and fossil resources preservation) of recycled plastics won’t be translated into economic factors or incorporation requirements, there will not be any increase of recycling because plastics industry will not sufficiently integrate these elements in their choices. The necessary investments for the use of recycled materials could be supported by a reduction in extended producer responsibility costs (modulated eco-contributions, via bonus/malus, in particular for non-food grade packaging), by economic support from the Member States to processing companies (investment aid but also operating aid by initiating a "resource saving certificate" mechanism for the materials mostly in competition with virgin materials, in particular plastics) and by better information and incentives to consumers (purchasing preference linked to a display on the environmental footprint of products). For "food grade" packaging, applying financial constraints to avoid recycling disrupters could be an interesting lever for ensuring quality of the final product. Minimum mandatory recycled contents in packaging would be a strong signal for creating the secondary raw material market. Finally, the use of alternative materials (paper or cardboard) could also represent an alternative to fossils in packaging. However, attention must be paid to the overall environmental balance and to the ability to recycle new packaging at the industrial scale, even if it is a reusable packaging. Finally, FNADE wishes to point out that imported products should be concerned by the same rules, in order to preserve a level playing field.
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Response to Update of concentration limit values of persistent organic pollutants in waste

5 Aug 2020

FNADE, the french association for waste management and environmental services, welcomes amendments to the annexes of Regulation 2019/1021 on Persistent Organic Pollutants (POPs) in order to achieve a zero-pollution ambition and a non-toxic environment. In order to develop a safe and high-quality recycling, it is crucial to limit hazardous substances potentially present in products and to reduce authorised concentration limits, especially for POPs which are persistent and stable molecules over time. All these substances of concern must be assessed and FNADE strongly supports "a grouping approach" by family of substances. This would avoid the too many often replacement of an assessed substance by another not yet evaluated but whose effects on health and the environment could at the end be more or less identical. For an optimized waste management, FNADE members would like to draw the Commission’s attention to the required and necessary information relating to the composition of waste. This information, basis of the traceability, is essential to ensure quality recycling and/or safe and appropriate treatment of waste containing hazardous substances. Better evaluate substances as information all along the chain is key to ensure products and waste are safely handled and managed. FNADE considers that the SCIP database elaborated in the meantime by ECHA will constitute a significant step towards this end. This database should play a key role in sharing this information. However, optimise its use will certainly be complex but necessary in order to prevent a zero-pollution environment and to prepare a more circular economy. FNADE will be very careful on its implementation and ensure it will really meet a set of specifications and provide reliable and easily extendable data needed by the recycling and waste treatment industry in order to facilitate high-quality and contamination-free recycling. In a nutshell, FNADE and its members share the same goal than the Commission, i.e. recycling is the objective for turning the economy towards a circular loop. Nevertheless, this circularity must not be achieved at the expense of public health, the environment and the safety of the workers which remain the priority: Europe should promote a high-quality recycling.
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Response to Review of the Construction Products Regulation

5 Aug 2020

FNADE, the french association for waste management and environmental services, welcomes the next review of the Construction Products Regulation and would like to suggest some improvements in order to facilitate the reuse and the recycling of construction materials. First of all, ecodesign is a necessary requirement to facilitate the deconstruction and dismantling of buildings. Eco-designed products will obviously be easier to disassemble because they will include a limited number of parts and materials. As a matter of fact, eco-designed products will be easier to reuse or to recycle. Part of the recycling work for construction begins with a good diagnostic in order to improve sorting on buildings dismantling sites. However, this step, which is not yet enough efficient, is crucial for a successful deconstruction and sorting process and would be easier if the information on products composition was made available and reliable. Regarding the engaged volumes and the huge resources use, construction sector is one of the biggest GHG emitters. That’s why, recycling must be the preferred solution. In addition, minimum mandatory recycled contents in new products would help to make decrease the global GHG emissions part of the sector. In the end, FNADE would like to highlight the risk linked to substances of concern contained in some construction materials such as brominated flame retardants like HBCDD, asbestos, lead… In order to move towards a high-quality recycling and non-toxic environment as part of the zero-pollution ambition of the Green Deal, more traceability is needed. The next SCIP database could be a good tool to provide information to the recycling industry. Thus, it could be possible to choose more easily the best solution for waste and to avoid along the circular loop legacy substances. In a nutshell, having sustainable materials will require more traceability and to avoid as much as possible substances of concern in new products.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

5 Aug 2020

FNADE, the national federation of depollution and environmental activities, welcomes the revision of the SSD. The SSD was a pioneering initiative in the sector when it made it possible to establish safety thresholds that are referenced in other official texts. The attempt to revise the directive in 2010 was a failure, however, the preparatory work can be resumed to serve as a basis for reflection. The evaluation report of 2014 shows that the directive has achieved its objectives, particularly with regard to the use of sludge in agriculture. However, the lack of revision of this Directive, which dates back to 1986, has led to a growing mistrust of the waste and recycling sector. Thus, practices and the desire to ensure food safety, combined with regulatory acts that have not been amended for more than 20 years, are now hindering the return of quality biosolids to the soil. It is now more important to promote performance targets on a scientific basis than to promote methods. Land use criteria must be identical or at least consistent between the different fertilizing materials and crop supports (concerning the safety threshold, agronomic efficiency, dose input, etc.). The Fertiliser Regulation should therefore also be revised to address these issues in a holistic way. Moreover, the choice to add new families of substances to be controlled must be made on a scientific basis, with standardised analytical procedures. The spreading of biosolids on land (directly or after composting) helps to fight against global warming and the constant loss of soil organic matter and also contributes to more independence in the use of synthetic fertilisers. The return of sludge to the soil is a concrete example of the circular economy. Therefore, European regulations in this area need to be regularly reviewed to update thresholds and criteria, preserve good practices and thus reassure the public. Finally, quality controls of biosolids are indeed necessary, but this is even more necessary to control and set up upstream systems to minimize pollutants and contaminants in the environment and in water.
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Response to EU Methane Strategy

5 Aug 2020

FNADE, the French association for waste management and environmental services, welcomes the publication of the EU Methane Strategy roadmap in order to reduce the emissions and contribute to slow down global warming. First of all, FNADE would like to point out the necessity of having reliable data for methane emissions calculation, according to a methodology shared by everyone. Therefore, FNADE supports the European Commission initiative to better identify and quantify methane emissions, especially for the waste management sector. A reliable and unique methodology, approved by all the stakeholders, would be a useful tool for measurement. Most methane emissions come from old, poorly designed or maintained landfill facilities, which have a significant effect on the climate because of their power as "super-emitters". Furthermore, FNADE would like to highlight that methane emissions are directly linked to waste organic composition. In order to reduce landfilling, FNADE promotes reuse, recovery, recycling and separate collection of organic waste. The measures of the circular economy package should help to achieve these objectives. By the end, in spite of the european policy in organic waste separate collection and while waste which is today directed to landfill facilities will produce biogas for at least fifteen years, FNADE encourages any financial support mechanism in order to sustain the capture and the recovery of methane as heat or electricity generation and biomethane injection. The goal is not to encourage landfill, but to use the potential of the current produced biogas, which is an ultimate by-product. The recovery of this biogas fully contributes to reduce emissions by substituting for fossil fuel, having thus a dual beneficial effect. Moreover, methane capture and recovery have been classified as a green activity in the European taxonomy. Furthermore, organic waste methanization could be encouraged and facilitated by flexibility on the mix of incoming waste or on the mix of outcoming gas (mix of landfill biogas and methanization biogas). These accompanying measures and incentives would be a strong signal to improve waste management.
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Response to EU rules on industrial emissions - revision

21 Apr 2020

Recent assessment of IED has shown both environmental benefits and also the need of some improvements. FNADE, representing the french recycling and waste management sector, would like to give some comments on the different options the commission has explored for modernizing IED: ● First of all, FNADE wants to underline IED is an adequate tool to reduce water and air emissions and to tackle the environment and health impacts of industrial activities and IED doesn’t seem to need a global revision. We would rather propose some adjustments to improve the BREFs process, maintaining the weight to technical representation and having a more homogenous implementation for a better level playing field. ● FNADE wishes to remind that the waste sector, whose activities are covered by 2 BREFS (WI and WT BREF), have already significantly reduced its emissions. The Commission should assess the contribution of waste management sector compared to the other industrial sectors, to assess costs/benefits and to identify where it is more relevant to review a BREF. ● FNADE is in favour of circular economy that promotes a safe reuse of materials and waste in the cycle, as recycling and waste management companies are key players. Thus, pertinent criteria should be defined in order to have the same bases for all industrial sectors and to prevent any downward spiral of the implementation of these circular economy concepts. ● Likewise, the European general reflection on carbon issue shouldn’t take place in the framework of IED revision. The inclusion of carbon emissions in IED doesn’t appear as a good idea but FNADE wonders if the directive couldn’t become a useful tool to propose and define some criteria or indicators in way to introduce a border tax and restore a level playing field with companies outside Europe. 1- Baseline scenario IED is a good tool and has provided encouraging benefits reducing industrial emissions. FNADE recommends not to change IED but rather to improve BREFs process. In particular, metrology issues could be better taken into account. BREFs do not enough ensure that the existing measuring devices can technically give reliable measurements to be compatible with the BATs conclusions. 2- Inclusion of new sectors in the scope of the IED The encouraging emissions reductions ever obtained and the very low benefits which could be expected now from sectors already covered by IED, support the extension of the scope of IED in order to achieve further significant results. It might also be relevant to include facilities covered by IED but whose capacities are below the thresholds and highly contributing in emissions to the environment. 3- Implementation issues The different ways BREFs are interpreted in each member state or region represent the most significant problems reported by the implementation of IED. 4- Elaboration of BAT conclusions FNADE would like to remind the dialogue engaged during the BREFs preparation is very constructive and provides a very technical useful discussion. The BREFs process runs smoothly, and FNADE would like the discussion on the BAT conclusions to continue by emphasizing the technical side on the politic one. FNADE would also like to point out this step as a great way to get accurate and operational data to further derive BATAE(P)L. 5- Contribution to the circular economy FNADE is in favour of circular economy that promotes a safe reuse of materials and waste in the cycle. If circular criteria are proposed, they should be shared by all the industrial sectors. 6- Interaction with industry decarbonisation efforts As pointed in the introduction, IED is a real adequate tool fighting for a less polluting environment. But adding Carbon to the IED’s scope does not seem the appropriate way to tackle the CO2 emissions problem. Thus, FNADE believes that a European general reflection on industry decarbonisation issue could be separately set up.
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Response to Climate Law

1 Apr 2020

FNADE, the French association for Depollution and Environmental Activities, welcomes the proposal for a European climate regulation that sets ambitious but necessary targets to achieve the carbon neutrality by 2050 set by the Green Deal. FNADE brings together 223 companies and 48,000 employees. This sector of activity already contributes to the avoidance of greenhouse gases, in particular through recycling and the use of recycled materials and Waste To Energy. Only for France: 20 million tons of CO2 are avoided each year through recycling (source ADEME, 2019) https://www.ademe.fr/sites/default/files/assets/documents/dechets_chiffrescles_essentiel2018_010690.pdf while 4 million tons of CO2 are avoided through Waste To Energy. FNADE, by contributing to mitigate climate change, calls on the Commission to recognize and reward the greenhouse gas emissions avoided by recycling and material recovery channels and to recognize the contribution of energy recovery, which allows the production of heat and electricity as a substitute for fossil fuels. The effort to reduce greenhouse gases and the carbon neutrality objective must be strongly supported by the industry sector. Nevertheless, FNADE considers that local authorities, which are an important driver in public procurement and in the implementation of good practices at the territorial level,should be placed at the heart of the global strategyfor reducing GHG eemissions. FNADE would also like to know what financial or technological support mechanisms the European Commission has planned to introduce to encourage the industrial sector to make this climate transition a success.
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Response to Revision of the Energy Tax Directive

1 Apr 2020

FNADE, the French association for depollution and environmental activities, welcomes the revision of the Energy taxation Directive (ETD). Indeed, the revision of this directive would better align it with the climate Green Deal’s objectives especially for promotion of renewable energies. It also would harmonize the way it is implemented in the different European countries. FNADE would like the European Commission includes the issue of waste heat. Indeed, the current fiscal policies do not encourage enough the recovery of this easily usable energy which could have a significant impact. On the contrary, by taxing the use of waste heat, they encourage the actors not to use it. Thus, in France, while there is still at least 4.4 TWh of unused energy potential (ADEME study of waste heat 2017), 11.6 TWh of heat were recovered in 2019, and this is only for waste treatment sector, even though many other sectors of activity could also recover it. FNADE wishes to highlight the relevance of energy recovery from waste, providing users with renewable or recuperative energy, and its importance in the potential waste heat recovery opportunities but waste operators could face unlevel playing field compared to sectors which benefit from energy tax exemptions. France, by including them in the Multiannual Programming of Energy, has thus underlined the recognition of their contribution to the fulfilment of the country's energy ambitions. Nevertheless, the means implemented to develop this deposit are not sufficient. Furthermore, FNADE wishes to point out, in accordance with article 15, 1. b) of the ETD, the importance of supporting the production of "generated from biomass or from products produced from biomass" electricity However, the biogenic fraction of waste is included in biomass according to the definition of the Renewable Energy Directive (def n°24): ("‘biomass’ means the biodegradable fraction of products, waste and residues from biological origin from agriculture, including vegetal and animal substances, from forestry and related industries, including fisheries and aquaculture, as well as the biodegradable fraction of waste, including industrial and municipal waste of biological origin"). Thus, the support by a tax exemption or by a reduced tax rate to this energy production allows to limit fossil fuels’ use and helps to meet the renewable energies’ objectives. Finally, FNADE wishes to underline the key role the SRF sector could play in contributing to the achievement of the objectives of reduction of landfill and carbon neutrality (due to the biogenic part of the SRF). Unfortunately, its development is hindered, particularly in comparison with other more competitive fossil fuels, although more harmful to the environment.
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Meeting with Daniel Calleja Crespo (Director-General Environment)

15 Jan 2020 · European Green Deal

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

21 Jun 2019 · SUEZ Manifesto on Sustainable Europe and compostable recycling

Meeting with Sebastien Paquot (Cabinet of Vice-President Karmenu Vella) and European Recycling Industries' Confederation

11 Dec 2018 · Single Use Plastics

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

7 Nov 2018 · boosting recycling in the EU

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

7 Nov 2018 · discussion on EU Waste policies

Meeting with Daniel Calleja Crespo (Director-General Environment)

5 Oct 2016 · BREFs process and Circular Economy