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Hazardous Waste Europe

HWE

Hazardous Waste Europe represents over 160 hazardous waste treatment facilities across Europe, promoting high-quality treatment standards and worker safety in legislation.

Lobbying Activity

Meeting with Aurel Ciobanu-Dordea (Director Environment) and

20 Nov 2025 · Meeting on PFAS in Waste

Hazardous Waste Europe Urges Caution Over General Recycling Targets

6 Nov 2025
Topic — The Circular Economy Act aims to boost sustainable production and resource efficiency in Europe.
Message — Hazardous Waste Europe argues it is not possible to include hazardous waste in general recycling targets without impacting human health. They advocate for destroying hazardous substances rather than allowing them to recirculate through unsafe recycling. They also suggest that only financial producer responsibility schemes should be permitted to ensure environmental quality.123
Why — This would protect high-quality treatment facilities from being undercut by cheaper, lower-standard operators.4
Impact — Large waste management organizations would lose their market dominance and ability to choose cheap disposal.5
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

18 Sept 2025 · Discussion on the current issues of waste treatment operators related to PFAS-containing waste and the monitoring and reduction of PFAS emissions from waste treatment operations

Hazardous Waste Europe urges broader raw materials recovery list

25 Jul 2025
Topic — The consultation defines which waste streams have potential for critical raw materials recovery.
Message — The organization suggests adding hazardous waste containing solvents, acids, and bromine to the list. They argue these materials are strategic for European industry and economic sovereignty.12
Why — This would allow hazardous waste operators to grow their businesses through new industrial policies.3
Impact — Dominant global bromine suppliers may see their market share threatened by recycled European alternatives.4
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Response to Shipments of waste - systems interoperation for electronic submission and exchange of information and documents

2 Apr 2025

Hazardous Waste Europe, the trade association representing hazardous waste management in the EU, welcomes the proposal and the work on electronic submission and information exchange. National systems need to be connected and the different information requirements harmonised to make waste shipment procedures more efficient and faster. The proposals in the annex are in line with the most comprehensive systems in Europe.
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Response to Persistent organic pollutants - Polychlorinated biphenyls (PCB)

18 Mar 2025

Please find enclosed our HWE Position paper Proposition of UTC limit value for Polychlorinated Biphenyls under the Annex I of POP Regulation
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Hazardous Waste Europe Urges Clearer Industrial Water Reuse Rules

3 Mar 2025
Topic — A cross-sectoral EU plan to achieve water resilience and scarcity management by 2040.
Message — HWE seeks a clear legal framework defining responsibilities for industrial wastewater reuse. They demand science-based emission limits and standardized measurement methods for emerging pollutants. They call for incentives to foster innovation in decontamination technologies.12
Why — Standardized rules for pollutants provide the visibility and regulatory certainty companies need for future investments.3
Impact — Industrial water users lose protection and access to reused water under the current unclear framework.4
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Response to Digital Product Passport (DPP) service providers

10 Dec 2024

Please find enclosed Hazardous Waste Europe (HWE) feedback to the call for evidence on DPP - rules for service providers.
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Response to Persistent organic pollutants – PFOA limits and exemptions

6 Dec 2024

Please find enclosed our HWE input to the consultation.
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Hazardous Waste Europe seeks new codes for battery solvents

8 Nov 2024
Topic — The Commission is revising the European waste list for battery manufacturing and recycling.
Message — HWE proposes adding four new waste codes for solvents used in battery production. They want these chemicals recycled as raw materials rather than being discarded.12
Why — Specific codes would help the industry direct valuable materials to recovery facilities.3
Impact — Traditional disposal firms lose business as solvents are diverted toward specialized recovery facilities.4
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Hazardous Waste Europe demands mandatory iron and phosphorus recycling

18 Oct 2024
Topic — Establishing methodology for calculating battery recycling efficiency and material recovery rates.
Message — HWE requests making the recycling of iron and phosphorus mandatory to ensure a level playing field. They also suggest expanding the definition of black mass and promoting closed-loop recycling.123
Why — Mandatory rules protect European companies that have already invested in advanced recycling technologies.45
Impact — Overseas producers of LFP batteries gain an unfair advantage if recycling remains optional.6
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Meeting with András Tivadar Kulja (Member of the European Parliament)

7 Oct 2024 · Hazardous waste

Hazardous Waste Europe urges wider scope for carbon capture rules

16 Jul 2024
Topic — The consultation establishes conditions for considering carbon permanently bound in products to exempt emissions.
Message — HWE calls for the framework to include non-ETS sectors and alternative technologies like solid carbon production. They also demand strict toxicity assessments to prevent hazardous waste dilution during carbonation.12
Why — Including non-ETS sectors allows hazardous waste firms to monetize their carbon reduction efforts.3
Impact — Public safety could suffer if firms use carbonation to avoid strict hazardous waste controls.4
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Hazardous Waste Europe Urges Ambitious Taxonomy Standards

19 Apr 2023
Topic — A consultation defining technical screening criteria for environmentally sustainable waste management activities.
Message — HWE supports high environmental ambition and requests that technical screening criteria are not weakened. They advocate for excluding facilities that use dilution to bypass adequate treatment or ignore recycling requirements.123
Why — High standards ensure that only top-tier facilities receive green investment status over cheaper competitors.45
Impact — Low-efficiency operators currently using dilution or mixing practices to meet basic emission limits.67
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Hazardous Waste Europe backs stricter monitoring of water pollutants

5 Jan 2023
Topic — The EU is updating the lists of priority substances and groundwater pollutants.
Message — HWE supports harmonizing water regulations and updating pollutant lists. They advocate for better monitoring and source separation to treat wastewater containing harmful substances.12
Why — Clearer monitoring rules for PFAS would provide treatment plants with legal certainty.3
Impact — Industrial producers would face increased costs for required wastewater source separation.4
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Hazardous Waste Industry Seeks Flexibility in Emission Limits

21 Jun 2022
Topic — Revision of EU Industrial Emissions Directive for zero pollution goals.
Message — The organization supports the directive's zero pollution goals but opposes strict alignment of emission limit values with the lower end of best available technique ranges. They propose keeping flexible limits within ranges and introducing annual mass flow caps per pollutant instead.123
Why — This would preserve operational flexibility and avoid dramatically increased consumption of energy, water, and materials.45
Impact — Environmental and health advocates lose stricter pollution controls that would push facilities to lowest emission levels.67
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Meeting with Anja Hazekamp (Member of the European Parliament, Shadow rapporteur)

19 Apr 2022 · CLP non toxic environments

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

22 Feb 2022

Hazardous Waste Europe (HWE) represents hazardous waste operators present in the whole value chain of hazardous waste management, from collection to final treatment including recycling and regeneration activities in which our members apply the appropriate requirements from the Waste Framework Directive (WFD). Since its creation, Hazardous Waste Europe has endeavoured to implement principles of “Decontamination, non-dilution and traceability”. This commitment, the cornerstone of our advocacy, aims at limiting the dispersion of pollutants, destroying toxicity and ensuring transition towards a toxic-free environment. This first consultation in view of a legislative proposal is consequently of utmost importance for us. The main objectives of this call for evidence intend to favour waste prevention and recycling as a whole. These objectives are, indeed, top priorities for a circular and resilient Europe. HWE is of the opinion that key aspects in order to efficiently meet these objectives when it comes to hazardous waste management consist in assessing how to guarantee clean and safe secondary raw materials, how to reach high quality of recycling and avoid contamination of recyclates with substances of concern. Considering the practical need for EU action raised in the call for evidence and its specificity for hazardous waste management, HWE advocates for a number of proposals in the attachment.
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Response to Evaluation of the Environmental Liability Directive and of its implementation

22 Dec 2021

Dear all, please find attached HWE position.
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Response to Update of concentration limit values of persistent organic pollutants in waste

20 Dec 2021

Hazardous Waste Europe would like to acknowledge the huge and serious work carried out by the EU Commission which supports this proposal for amending annexes IV and V to the POP Regulation. HWE fully endorses the rationale behind the proposal. Lowering the annex IV values for a series of POP substances is a powerful and coherent means to align with the ambition for a zero pollution in a non-toxic environment. Among the policy options presented in table 2, HWE agrees with the shaded ones. For substances where baseline exists, except PCDD/F + PCB-DL, we estimate that the proposed best options (shaded) are a real opportunity to drastically reduce the risk of contamination of non contaminated waste streams with contaminated ones. Indeed, lowering the threshold directly implies that dilution will be more difficult. It shall also incentivize better sorting and decontamination technologies to appear and to become economically viable compared to current practises. Finally, it will automatically lead to high quality recycling and avoid POP substances background levels increasing in materials, even those which should be free from them, via recycling as it has been observed in plastics. For HWE, it shall be clearly stated that no derogation should be granted for certain couple material/POP on the grounds that it would hamper recycling or/and because recycling saves CO2 compared to the production of virgin materials. Health and the Environment cannot be disregarded for the benefit of climate. Reachout optimal balance with all the EU Green Deal’s ambitions is key. Regarding PFOA, PBDEs, SCCPs, PCP and HBCDD which are/were mainly intentionally added to products/ goods/equipment, it might be very useful to gather all known information in a similar database to/or directly in the SCIP database. It will help waste operators to take the right decision in terms of sorting. It will also pressure players whose practises are objectionable. As a member of the Zero Pollution Stakeholders Platform, HWE will propose this initiative to the Platform. This would also answer the recurring objection to lowering thresholds under pretext of the analytical constraints. Regarding PCDD/F + PCB-DL, we would like firstly to get the confirmation that the proposed values are calculated according to the toxic equivalent factors. On another hand, as already stated, HWE agrees with policy option 3. Nevertheless, all stakeholders must be aware that it potentially qualifies many thermal process residues as POP waste subjected to article 7(4)(b) and annex V part 2 requirements. Due to the number of different holders potentially impacted and the wide variability of the PCDD/F + PCB-DL content for a specific residue from a dedicated facility (above or below the low POP value), it would be less burdensome for competent authorities and waste holders, yet with the same level of requirements and protection, to provide one dossier at the national level instead of multiplying demands for the same purpose. Consequently, HWE asks the EU Commission to open the discussion about the possibility to implement national procedure with all stakeholders. It can address an EU-wide issue, avoid bad or illegal practises due to the difficulties for certain holders (mainly SMEs) to draw up this kind of dossier and, over all, it can help keeping the level of ambition of this proposal regarding PCDD/F + PCB-DL targeted value.
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Response to Environmental Implementation Review 2022

18 Oct 2021

Improving implementation of EU environmental law and policy is key to ensure a zero pollution ambition for a toxic-free environment called by the EU Green Deal. As hazardous waste operators we value a clear, strict and effective legal framework for hazardous waste to ensure their adequate management in order not to harm health and the environment. Please find attached our position paper that detailed the following points. -> Importance to both implement and enforce the EU legislation, in an harmonised way within EU Member States. -> Introduce greater provision to handle the issue of substances of concern within the circular economy -> Ensure indirect discharge of industrial wastewaters are adequately treated by clarifying article 15.1of the industrial emission directive -> Improve the legislation spreading sludge from WWTP
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Response to Revision of the Directive on ship-source pollution

16 Jun 2021

Hazardous Waste Europe represents hazardous waste operators present in the whole value chain of hazardous waste management, from collection to final treatment. Our operators are also present on port reception facilities to provide collection, recovery - when possible - and final treatment to all Marpol Waste Annexes. Since its creation, Hazardous Waste Europe has endeavoured to implement principles of “Decontamination, non-dilution and traceability”. This commitment, the cornerstone of our business development, aims at limiting the dispersion of pollutants, destroying toxicity and ensuring transition towards a toxic-free environment. We welcome the opportunity to comment on the revision of the directive on ship-source pollution and on the introduction of penalties, including criminal penalties, for pollution offences. This revision happens concomitant with the objectives described in the zero pollution action plan and Green Deal’s goal of zero pollution ambition for a toxic free environment. Marine pollution has emerged as a growing concern, with maritime transport playing a significant role.Protection of oceans and seas is finally higher on the international political agenda, especially with regards to SDG 14 of the UN. The international community is aware of the urgent need to address conservation and sustainable use of oceans and seas. The scope could be extended to waste, not to target only ‘polluting substances’(Annexes I and II) Circular economy discussions, adoption of the single use plastic directive and port reception facilities directive have shown that challenges pressing oceans and seas are multiple and can also provide from waste, mainly plastics. In this regard Marpol waste annexes should also be targeted, all the more with the implementation of the recently revised directive on port reception facilities. That should give the right incentives to deliver waste in ports and not illegally in seas. Ships discharge should also be considered by the Commission. The Zero pollution action plan targets ships equipped with exhaust gas cleaning systems. Indeed, those systems, when operating open loop, could entail a shift of pollution (including heavy metals) from air to water. If we aim to address pollution globally, we should also assess the potential effects of water discharges from ships. On the contrary, closed loops systems exist and also enable compliance with the new IMO 2020 regulation on sulphur content. Port reception facilities, at least in the EU, are equipped to collect and treat the residues from closed loop scrubbers that should be kept on board to be treated as hazardous waste in final installations.
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Hazardous Waste Europe urges hazard-based classification to prevent toxic recycling

1 Jun 2021
Topic — Revision of EU regulation on classification, labelling and packaging of chemicals.
Message — The organization requests that waste classification remain separate from products and maintain a hazard-based approach rather than risk-based. They argue waste fate is unpredictable and recycled materials should not receive derogations from safety requirements.123
Why — This would maintain their business model of decontamination and ensure traceable hazard management.4
Impact — Recyclers seeking flexibility lose stricter requirements that could increase their compliance costs.56
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Hazardous Waste Industry Urges Strict Chemical Controls in Recycling

1 Jun 2021
Topic — Revision of EU REACH regulation governing chemical safety and environmental protection.
Message — The organization requests stricter requirements for recycled materials to match virgin products. They want extended substance tracking through the SCIP database and no derogations for legacy substances in waste recycling. They emphasize recycling should not reintroduce harmful chemicals into production loops.123
Why — This would protect their decontamination business model and reduce competition from lower-standard recycling operations.45
Impact — Recyclers using cheaper methods would face higher compliance costs and lose competitive advantage.6
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Response to Mercury – review of EU law

2 Apr 2021

Hazardous Waste Europe welcomes the objectives of the Inception Impact Assessment. Regarding the phasing-out of the use of dental amalgam, the timetable must be clear in order to: 1-ensure that each Member States will have time to shape the right solutions in order to take care of the lower-income part of the population who can't access today to alternative solutions to dental amalgam, 2-ensure that there will be no stocks of pills for the preparation of dental amalgam at the date of the phase-out in order to avoid trafficking. Regarding prohibition of the manufacture and export of MAP, in our opinion the current text already frame this. Nevertheless, if there are some remaining manufacture of MAP in Europe (for which alternative solutions exist), it must be stopped as soon as possible. Europe must be a front runner in the fight against anthropogenic sources of mercury and manufacture of MAP is a key element in this fight.
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Response to Modernising the EU’s batteries legislation

1 Mar 2021

HWE welcomes the objectives seeked by the Commission’ s proposal for a regulation concerning batteries and waste batteries to reach competitiveness, circularity and protection of health and the environment. As such, the current proposal is part of the EU Green Deal, by striving to conciliate functioning of the internal market and a zero pollution ambition for a toxic- free environment. The replacement of the current directive by a regulation should improve harmonisation among EU Member States and reduce the problem of interpretation in the implementation of the provisions. Our EU federation, HWE, represents hazardous waste operators involved in the whole value chain of hazardous waste management, from collection to final treatment. We endeavour to implement principles of “decontamination, non-dilution and traceability” to limit dispersion of pollutants in the environment and ensure non toxic material cycles. Our members, present in this activity, develop technological innovations and business partnerships to be at the cutting-edge of treatments to ensure that batteries and waste batteries are sustainably recycled to their maximum to promote circular economy. Please find attached the following points of importance for HWE, that are detailed in the position paper attached: - consider waste batteries as hazardous waste to improve traceability and guarantee safe and appropriate treatment - assess technical, economical and social considerations for the exports of waste batteries - promote high quality recycling rates to boost SRM markets and ensure non toxic cycles. The restriction of use of hazardous substances in batteries is an important point, especially with regards to mercury and cadmium. The proposal should continue to disregard the cadmium and mercury compounds in the recovery/recycling rates. When discussing recycling targets, it is important to consider the whole chain and ensure that use and quality of the SRM is taken into account and that markets exist for the SRM. We grant very much importance to information about substances of concern in batteries including their end-of-life and their traceability throughout the whole value chain. - EPR should keep the existing well functioning systems - LCA should be better taken into account
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Response to Updating Member State emissions reduction targets (Effort Sharing Regulation) in line with the 2030 climate target plan

23 Nov 2020

Hazardous Waste Europe (HWE) is a European wide association whose members operate all the diversity of hazardous waste treatments from recycling to final disposal including dedicated hazardous waste incineration. HWE recognizes and endorses the urgent necessity to bring more efforts for achieving the targets of the Paris agreement and specifically the EU commitment for carbon neutrality in 2050. Consequently, the debate launched for fairly assessing the need for updating ETS directive and the ES Regulation is of utmost importance. Is it worth extending the ETS directive to new activities? HWE would answer, in first approach, yes. Is it worth phase out, keep ESR in parallel to the extension of ETS or maintain ESR for specific sectors? HWE answers that the waste sector must remain in the ESR. This should be evaluated in the light of cost-benefit efficiency for the next period, 2021-2030, (which sector will offer the most efficient decrease of CO2 emissions within the framework of the ETS) and a priority list of the most contributive sectors that are currently out of the scope of the ETS. In our opinion, the decision shall be based on scientific and reliable information like data reported in Annual European greenhouse gas inventory (last update 27/05/2020) and must avoid all political posture. The hazardous waste management sector is not a key category in terms of GHG emissions, consequently, HWE does not see any benefit neither for the climate neutrality objective nor for the sector itself: -recycling, material recovery and other recovery from hazardous waste provide resources to industry with an obvious better footprint including carbon footprint than natural resources or other virgin material inputs, -incineration with or without energy recovery of hazardous waste has an essential role to play in order to eliminate unavoidable, non-recyclable carbon-based waste containing highly hazardous substances where the emission of CO2 is the worth option and to promote hazardous waste recycling and its role is recognised in the Taxonomy process, -hazardous waste landfills are already a zero CO2 emission activity, as they receive inorganic non-biodegradable waste only. HWE estimates that hazardous waste management activities should not be part of the extension of the ETS and that ESR in conjunction with other pieces of legislation (for instance IED) offers a much better and adapted chance of improvement regarding CO2 emissions keeping in mind that our role remains the destruction of toxics that otherwise would have detrimental impacts on health and the environment. Option 3 is the most relevant. See the complete feedback with all justifications attached
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Response to Updating the EU Emissions Trading System

23 Nov 2020

Hazardous Waste Europe (HWE) is a European wide association whose members operate all the diversity of hazardous waste treatments from recycling to final disposal including dedicated hazardous waste incineration. HWE recognizes and endorses the urgent necessity to bring more efforts for achieving the targets of the Paris agreement and specifically the EU commitment for carbon neutrality in 2050. Consequently, the debate launched for fairly assessing the need for updating ETS directive and the ES Regulation is of utmost importance. Is it worth extending the ETS directive to new activities? HWE would answer, in first approach, yes. Nevertheless it should be evaluated in the light of cost-benefit efficiency for the next period, 2021-2030, (which sector will offer the most efficient decrease of CO2 emissions within the framework of the ETS) and a priority list of the most contributive sectors that are currently out of the scope of the ETS. In our opinion, the decision shall be based on scientific and reliable information like data reported in Annual European greenhouse gas inventory (last update 27/05/2020) and must avoid all political posture. The hazardous waste management sector is not a key category in terms of GHG emissions, consequently, HWE does not see any benefit neither for the climate neutrality objective nor for the sector itself: -recycling, material recovery and other recovery from hazardous waste provide resources to industry with an obvious better footprint including carbon footprint than natural resources or other virgin material inputs, -incineration with or without energy recovery of hazardous waste has an essential role to play in order to eliminate unavoidable, non-recyclable carbon-based waste containing highly hazardous substances where the emission of CO2 is the worth option and to promote hazardous waste recycling and its role is recognised in the Taxonomy process, -hazardous waste landfills are already a zero CO2 emission activity, as they receive inorganic non-biodegradable waste only. HWE estimates that hazardous waste management activities should not be part of the extension of the ETS and that ESR in conjunction with other pieces of legislation (for instance IED) offers a much better and adapted chance of improvement regarding CO2 emissions keeping in mind that our role remains the destruction of toxics that otherwise would have detrimental impacts on health and the environment. See the complete feedback with all justifications attached
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Response to Revision of EU legislation on end-of-life vehicles

18 Nov 2020

As a federation representing hazardous waste operators present on the whole chain, from collection to final treatment, ELVs are not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some legitimacy to share our key principles to reach the zero pollution ambition for a toxic-free environment called by the EU Commission in the Green Deal. There are many challenges part of the revision of the ELV Directive, among themselves the need to update with regards to legislative, technical and scientific knowledge. Our contribution will only focus on quality, environmentally sound management and protection of health and the environment. According to national authorities, the average age of end-of-life vehicles is 14 to 20 years. This is much higher than most of the post-consumer goods. It means that the equipment/articles composing this very complex object may contain a lot of substances of concern: -currently acknowledged legacy substances like POP-BFR or PFAS but also not yet acknowledged legacy substances, -currently acknowledged SVHC but also not yet acknowledged SVHC. As ELVs represent an important source of valuable spare parts, high quality recoverable resources but are also a source of highly contaminated fractions, it is of utmost importance to favour and developed, as far as possible, dismantling and sorting operations prior to any other ones including shredding and crushing which have a really detrimental effect on the quality of the outputs. Encouraging more advanced dismantling and sorting will allow increasing: -the value of the reusable and recyclable clean fractions, -the quality of the resources from ELVs and thus potentially would allow upgrading instead of downgrading as it is the case today in most of the cases, -allow the appropriate decontamination of the fractions containing substances of concern in compliance with the Waste Framework Directive, the -POP Regulation, and others, -ensure that uses of recycled materials comply with REACH according to concentrations and uses restrictions and bans for certain substances. ELVs are an important waste stream in order to meet the objective for a more EU circular economy but it should not be at the expense of others in the Green Deal and specifically the ambition for zero pollution in a toxic free environment. There is, at least, a need for better alignment and consistency with other EU pieces of legislation (targeted modification of the ELV Directive) but, potentially, the extension to trucks and motorcycles could render the market more sustainable and cost efficient (overhaul of the ELV Directive).
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Response to Sustainable Products Initiative

30 Oct 2020

Non toxic material cycles are key to ensure a clean and sustainable circular economy to create confidence in secondary raw materials. This happens by implementing safe and sustainable by-design requirements, but also by taking into account a few principles at the recycling phases. As pointed out in the EU Chemicals Strategy for Sustainability, the forthcoming sustainable products initiative has a role to play to reach a zero pollution ambition and minimise the presence of substances of concern. Reaching the Green deal objectives will demand all stakeholders to adopt a comprehensive and global approach in order to integrate their scope of activities within a wider perspective. In this regard, the Sustainable Products Policy Initiative should tackle the whole life cycle of products, from cradle to grave and also address collateral consequences to take care of health and the environment. As federation present on the whole chain of hazardous waste management convinced by principles of decontamination, non dilution and traceability to reach clean material cycles and non toxic environment, we think some easy-to-implement principles are already existing to encourage sustainable production (point 1), and that some tools, like the SCIP database could also be a valuable tool in the products information throughout its whole life cycle (point 3). The few elements underlined by the roadmap need to be addressed in coherence with the new published chemicals strategy. As stressed, “Some of these measures would be of horizontal nature, while others would target specific sectors in particular.” This need for horizontal legislation is key to ensure coherence, efficiency and deliver the objectives of the EU green deal to reach a zero pollution ambition for a toxic free environment. See the attached document to read the full feedback
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Response to EU Action Plan Towards a Zero Pollution Ambition for air, water and soil

29 Oct 2020

“Development without regard to the environment would inevitably result in impairment of human health”. In 1981 already, Simone Veil, Chairperson of the WHO Commission on Health and Environment, warned about our management of the environment that would not take care of health issues. Many years later, the EEA report (Sept. 2020) Healthy environment, healthy lives: how the environment influences health and well-being in Europe points out that “poor quality environments contribute to 13 % (one in every eight) of deaths”. More than ever, we need to move towards a “zero pollution” ambition for a toxic free environment. We should act fast, we should act now, we should acte concrete. There is no more time to launch huge philosophical debates, we need coherent, effective, comprehensive and ambitious measures. See attachment for detailled feedback
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Response to Industrial pollution - revision of the European Pollutant Release and Transfer Register

23 Oct 2020

First of all, HWE would like to underline the usefulness of the E-PRTR. There is a great merit for all parties in having a EU wide system for reporting pollutants emissions and waste generation. Yet, as suggested by the IAA of the Commission, there are areas for improvements, e.g. in the view of having a more accurate picture of the pollution releases and of reporting meaningful parameters as regards climate mitigation, circular economy and non toxic material cycles. More accurate figures are desirable not only to correctly inform the public but also to make more accurate policies. A more accurate picture of the pollution releases to air, water and soil The 50MW threshold for combustion plants (point 1.c in annex) leads to ignoring a significant portion of the pollution and of the CO2 emitted by the energy sector, which even so is reported to be the main source of emissions in the atmosphere of the overall industry. HWE would favor reducing this threshold (e.g. 20MW, a threshold triggering the need for permits in certain member States). The same reasoning advocates for reducing the threshold for urban waste water treatment plants (5f annex I). The UWWT plants from agglomerations of more than 100 000 p.e. represent only 5% of the facilities. As all agglomerations of more than 10 000 p.e. should be equipped with a UWWT plant since 2006 (UWWT Directive), we recommend to lower the threshold to 10 000 p.e. in order to have a better picture of the most contributive sector of discharges of pollutants to water bodies. As regards methane emissions (at least), cattle breeding (beef, mutton, goats) should be added to point 7a, which currently addresses only poultry and pigs rearing. Update the annex II list of chemicals Certain substances of more recent environmental concern should not be ignored in updated reporting processes. Depending on the medium of the environment, it might be relevant to include substances like endocrine disruptors (e.g. PBDE), neurotoxic substances, glyphosate, microplastics etc. to annex II. On the other hand, do pesticides banned since 10 years or more (e.g. DDT) still need to be reported, as stocks are probably exhausted or destroyed (in well managed farms)? Decrease thresholds of the main GHS gases We recommend reducing by 10 the thresholds of the most contributing GHS gases (CO2, CH4, N2O), as the current thresholds fail to capture an important part of the greenhouse gas emissions. Generally, it would be useful to report substances of concern releases in a more comprehensive manner in order to reach more complete mass balances.
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Meeting with Virginijus Sinkevičius (Commissioner) and

8 Oct 2020 · To discuss the implementation of the Waste Framework Directive and the forthcoming Chemicals strategy

Response to Revision of the Renewable Energy Directive (EU) 2018/2001

17 Sept 2020

Hazardous Waste Europe (HWE) welcomes the planned revision of the Directive 2018/2001 and specifically measures aiming to promote a better use of recycled carbon fuel in maritime transport. A significant part of hazardous waste are carbon-based waste and part of it contains fuels that can be separated and purified in order to produce marine fuel. The quality of this fuel is very interesting in regards with the achievement of the new IMO2020 requirements and can contribute to accelerating the shift to sustainable and smart mobility wished by the Green Deal, but also to the sustainable development goal 14 (life below water). The fuel thus produced complies with the definition of the recycled carbon fuel introduced in RED II. Today, very few Member States promote the use of recycled carbon fuels in the transport sector even though, recital (89) of the Directive and articles 25, 27 and 28 give the legal framework to do so. This is probably due to the lack of real obligations to take this into account and also to the fact that there are neither yet appropriate minimum thresholds for greenhouse gas emissions savings nor methodology by which to assess these savings. Consequently HWE would prefer to amend articles 25 and 27 in order to take into account recycled carbon fuels for the calculation of the minimum share. Regarding minimum thresholds and the methodology for assessing greenhouse gas emissions savings that will be adopted by delegated acts by the Commission, irrespectively 1 january 2021 and 31 December 2021, HWE would be able to provide data. HWE is aware and supports the fact that the use of carbon-based products will decrease in the decades to come. Our treatment operations will follow and adapt to this phase down. Nevertheless, in the meantime, all these unavoidable carbon-based hazardous waste including recycled carbon fuel must be safely treated accordingly to the waste hierarchy. Our role is essential in the current economic situation and to accompany the transition to a carbon-neutral economy.
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Response to Revision of the Urban Wastewater Treatment Directive

7 Sept 2020

As a federation representing hazardous waste operators present on the whole chain, from collection to final treatment, urban waste water treatment (UWWT) is not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some legitimacy to share our key principles to reach the zero pollution ambition for a toxic-free environment called by the EU Commission in the EU Green deal. There are many challenges part of the revision of the UWWT Directive, among themselves the need to update with regards to legislative, technical and scientific knowledge as this directive has been drawn up 30 years ago. Our contribution will only focus on quality, environmentally sound management and protection of health and the environment. Even if the quality of water bodies improves according to the latest EEA publications, there are still huge issues regarding pollution of the surface waters. UWWT facilities play an important role as they represent one of the main contributors in terms of quantity of treated waters discharged into water bodies. For instance, based on e-PRTR reports for the year 2017, UWWT facilities still represent the major contributor among all reporting activities in Member States for cadmium, copper, nickel, lead and zinc. They also represent the major contributor for the emissions of priority substances and priority hazardous substances like DEHP, octylphenols and metals already mentioned above. We see at least three main causes to this: -the directive is outdated and specifically there are neither monitoring obligations nor levels of emissions for micropollutants, -due to the fact that the directive is very old, there is no coherence with other important pieces of legislations (for instance Water Framework Directive, Industrial Emission Directive (IED), Sewage Sludge Directive (SSD), Chemicals legislation, …), -the impact of indirect discharges from industrial wastewaters with or without pretreatment containing high concentration of micropollutants including substances of concern like pharmaceuticals, endocrine disruption compounds, microplastics, ... Consequently, the UWWT Directive needs to be deeply reviewed in order to align its objectives with the current and newer EU legislation, and with the EU Green Deal and specifically the ambition for a zero pollution and a toxic free environment. Moreover it would meet the ambitious will of the EU Parliament regarding the need for consideration of all hazardous substances including substances of concern.
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Response to Evaluation of the Sewage Sludge Directive 86/278/EEC

31 Jul 2020

As federation representing hazardous waste operators present on the whole chain, from collection to final treatment, sewage sludge is not directly our core business. Nonetheless, our commitment to ensure non toxic material cycles and limit the dispersion of pollutants in the environment grant us some legitimacy to share our key principles to reach the zero pollution ambition for a toxic-free environment called by the EU Commission in the Green Deal. There are many challenges part of the revision of the Sewage Sludge Directive, among themselves the need of update with regards to legislative, technical and scientific knowledge. Our contribution will only focus on quality, environmentally sound management and protection of health and the environment. Sewage sludge is a good illustration of circular economy by transforming a constraint into opportunity and turning a stream into resources for soil. Particularly, it makes sense in the process of the Commission to find alternatives to chemicals fertilisers, meeting the goals of the EU Biodiversity Strategy for 2030, implementing the farm to fork objectives regarding organic food and asserting the resilience and autonomy of Europe. However, sewage sludges represent a stream that could be contaminated by pollutants, pathogens or chemicals, well known or emerging. If the EU Commission aims to adopt a global and comprehensive vision of circular economy, the quality and innocuity of streams that are brought back to soil should receive adequate management and respect some basic principles to ensure sustainable and safe practices. Numbers of Member States (France, Spain, Italy, Portugal, UK, Ireland, Sweden, Finland, Denmark, Bulgaria, Hungary, Czech Republic, Lithuania, ...) consider back to soil of sewage sludges as a viable and relevant option. Nevertheless, there is an increasing mistrust from some stakeholders (public, farmers, food industry). Other Member States in central eastern Europe who are still landfilling huge amounts of sewage sludges, will fastly face the limit of this solution (new targets of the Landfill Directive) and will have to find viable solutions in regards their economic situation. In order to avoid negative political statement that would dramatically jeopardise back to soil due to a bad societal acceptability of this practice, it is essential to better regulate and ensure consistency between the relevant legislations. Ensuring the quality of sewage sludges demands legislative evolvement all along the chain, from upstream (management of the wastewater and their treatments), to downstream (water bodies quality) via sewage sludges management itself.
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Response to Update of concentration limit values of persistent organic pollutants in waste

27 Jul 2020

POPs are detrimental to health and the environment. They are chemicals that could end up in the recycling loops, once products become waste. Delivering the zero pollution ambition for a toxic-free environment wished by the Commission will require POP (and other substances of concern) identification, tracking and appropriate treatment to ensure non toxic material cycles and avoid dispersion into the environment. Adequate management of POPs in waste could reduce the amounts of waste becoming available to be recycled and generate waste management costs, to quote the presentation of the IIA by the Commission. But when it comes to our health and the environment, we should not have to fear that legislation has been leveled to the bottom to get around higher economic costs. Health and the environment should not be adjustment variable, as inevitably, consequences and inaction will cost more afterwards. The crisis we are currently facing with COVID 19 has pointed out part of our responsibility with regards to unsustainable mode of production and consumption, stressing that our economic ambitions is harming the planet - urging a change of behaviour. “This requires an unprecedented effort and an innovative approach, fostering convergence, resilience and transformation in the European Union” as agreed the European Council, 17-21 July 2020. If we do not want our awareness to prepare the “world after COVID” remaining wishful thinking, we should avoid at any costs that economic interests crush environment and health considerations. We should have the honesty to consider that in some cases protection of health and the environment may require higher costs. But the EU would never pave the way to a sustainable circular economy if substances of concern are going back in the recycling loops. The EU will never ensure confidence in secondary raw materials if recycling could justify the perpetuation of the use of hazardous legacy substances. Having the great ambition to lead the way, the EU legislation should combine health and environmental protection and increase global competitiveness and assure its citizens that saving money will not be detrimental to their well-being. “Ensuring high quality recycling where the use of recycled material does not lead to overall adverse environmental or human health impacts, and developing markets for secondary raw materials are also necessary to achieve resource-efficiency objectives.” General Union Environment Action Programme to 2020 Living well, within the limits of our planet. Ensuring non toxic environment is HWE’s main challenge through traceability, non dilution and decontamination. We very much welcome the provision of the POP regulation to lower the concentration limits set for POP substances in waste. Legislation should indeed reflect scientific and technical progress as well as International Conventions. The real question is not wondering about the impact of lowering the LPCL on recycling but whether the quality of recycled materials can be greatly improved by a strict implementation and enforcement of the requirements. Please find our paper attached for further details.
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Response to EU rules on transboundary waste shipments – update concerning plastic wastes

22 Jul 2020

Hazardous Waste Europe (HWE) welcomes the draft delegated act to implement recent changes to the Basel Convention on the control of the shipment of plastic waste. This version is clear, ensures an environmentally sound management of plastic wastes and correctly implements the changes to the Basel Convention's annexes as expected by HWE.
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Hazardous Waste Europe urges mandatory decontamination for non-toxic recycling

17 Jun 2020
Topic — The European Commission is drafting a strategy for a sustainable, toxic-free environment.
Message — The organization requests a broad definition for substances of concern and a grouping approach for chemical assessments. They advocate for full traceability through the SCIP database and strict enforcement of decontamination principles.123
Why — Stricter decontamination requirements would increase demand for specialized hazardous waste treatment services.45
Impact — Importers and general recyclers face higher costs due to mandatory waste separation.67
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Hazardous Waste Europe Urges Stricter Standards and Border Taxes

20 Apr 2020
Topic — The European Commission is revising rules to reduce industrial pollution from large facilities.
Message — HWE calls for expanding the directive's scope to include extractive industries and lower capacity thresholds. They want stricter monitoring of water discharges to prevent dilution and more upstream waste separation.123
Why — Stricter rules for non-EU competitors would reduce the price pressure on European industrial actors.4
Impact — Extractive industries and non-EU manufacturers would face new compliance costs and competitive disadvantages.56
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Response to Revision of the Energy Tax Directive

1 Apr 2020

Hazardous Waste Europe (HWE) welcomes the planned revision of the ETD and its related roadmap. In the light of the problems the initiative aims to tackle, Hazardous Waste Europe (HWE) would like to emphasize the need for clarifications in ETD in order not to undermine the role of the hazardous waste sector. A significant part of hazardous waste are carbon-based waste containing high concentrations of hazardous substances that implies the destruction of these waste in dedicated hazardous waste incinerators. These waste are produced as unavoidable and unintentional consequences of different industrial production processes. HWE is aware and supports the fact that the use of carbon-based products will decrease in the decades to come. Our treatment operations will follow and adapt to this phase down. Nevertheless, in the meantime, all these unavoidable carbon-based hazardous waste must be safely treated in dedicated hazardous waste incinerators. The first aim of our installations is the destruction of all hazardous substances in waste. Apart from start-up and a few other than normal operating conditions where the temperature of the kiln is not sufficient and thus supply fuel is needed, the energetical mix of waste is sufficient for ensuring adiabatic conditions. The process involves the production of fatal energy and this energy is recovered as efficiently as possible but giving priority to destruction efficiency. Hazardous waste incinerators provide users (cities and/our industries) from recuperative energy (mainly steam but also electricity in order to be self-sufficient). This opportunity should not be undermined but clarified through the revision of the ETD. As it has been pointed out by problems 1 and 2 in the IIA, there is a risk for our activities to face uneven playing field compared to certain business sectors, in particular energy-intensive manufacturing sectors, which benefit from energy tax exemption but also perform, as a secondary permitted activity, the treatment of certain carbon-based hazardous waste whereby fossil energy is recovered for the process. Our role is essential in the current economic situation and to accompany the transition to a carbon-neutral economy. We should not be hostage to the evolution of ETD and consequently HWE calls for clarifications and rules that can ensure a level playing field for the treatment of carbon-based hazardous waste.
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Response to A new Circular Economy Action Plan

15 Jan 2020

Better environment for better health is key to reach a zero pollution ambition for a toxic free environment. As representative of hazardous waste treatment operators on the whole chain, we are convinced that implementation of key principles through an integrative & consistent approach will serve our shared objective to promote non toxic material cycles & preserve high level of protection of health & the environment. We need adequate & harmonised implementation of the legislation. The EU hazardous waste legislation must be properly enforced to guarantee safe management of hazardous waste & level playing fields between MS and waste actors, and to identify breaches that undermine the EU law. MS, competent authorities and stakeholders should always guarantee a strict and regulated framework for hazardous waste to secure the future of industry and avoid dispersion of pollutants. We call for an extensive definition of substances of concern (SoC). Substances that could be harmful for health and the environment are more numerous than the ones currently restricted in REACh. It is urgent to encompass all the substances for which a level has been set in the legislation: CLP, POP or product specific legislation, and to introduce new hazards as the one of endocrine disruptor. It will need one integrated definition across the different pieces of EU legislation. Microplastics & nanomaterials should also be considered. Similar substances are likely to present similar threats, so substances should be assessed by grouping We advocate to keep separate classification between products and & waste. For product, when the scenarii of exposure according to a use can be assessed, the risk based approach is common and sufficient. Challenges are different for waste as one can never be sure of its final destination. Waste should be classified on hazard based approach which only takes into consideration the intrinsic properties of the waste to ensure it will be oriented towards the most appropriate treatment. A classification of waste based on a risk approach would fail to encompass all possible downstream routes & exposure scenarii. In the case of material recovery operation on a waste containing SoC, a risk based assessment could be applied at the level of the management chain of the waste when it happens in a closed/controlled loop ensuring that the recovered material will end up in a permitted use. Thus a waste even hazardous could be treated under conditions proportionate to the risks. We favor traceability & decontamination to reach clean material cycles. Keeping trace of information on the waste on the whole value chain is crucial to guarantee appropriate treatment. The SCIP database will be valuable for waste operators to identify & track SoC. Combined with the principle of decontamination, it will enhance high quality recycling, give trust in the SRM and boost SRM markets. Everything that could be toxic in the material cycles should not come back in the recycling loop. The objective is not to reach zero contaminants, but to ensure prior to recycling or recovery, that SoC contained in both non hazardous and hazardous waste beyond the regulated thresholds are extracted and disposed of in an environmentally sound way, in accordance with the regulation. This will generate non-recyclable residues which need to be environmentally sound disposed of. Keeping the contaminants in the recycled materials is incompatible with a non toxic environment policy. There is no place for low-cost recycling. EU legislator should assess the right balance between quantity & quality of recycling to prevent that some streams, especially if they have been mixed before the recycling, are likely to contain SoC and should not be recycled without a prior decontamination step. Same rules apply between virgin and SRM. Same rules should also apply between the EU article’s system and imported articles’ system. Please find joint a more detailed version.
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Hazardous Waste Europe demands reforms to industrial pollution rules

4 Dec 2018
Topic — Evaluation of EU rules regulating pollution and waste from large industrial facilities.
Message — HWE supports maintaining mandatory permits while improving how key environmental issues are identified. They propose considering cross-media effects to prevent one pollution reduction from causing another. They also want clearer rules on indirect water discharges and measurement uncertainties.123
Why — These reforms would create a fairer market and reduce regulatory confusion.4
Impact — Non-EU competitors lose their advantage of operating under weaker environmental regulations.5
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