Kierrätysteollisuus ry, Återvinningsindustrin rf (The Recycling Industries of Finland)
Kierrätysteollisuus ry on elinkeinopoliittinen vaikuttaja, joka edistää jäsentensä kilpailukykyä ja toimintaedellytyksiä.
ID: 624544817846-49
Lobbying Activity
Meeting with Katri Kulmuni (Member of the European Parliament)
3 Oct 2025 · Ajankohtainen EU-lainsäädäntö
Meeting with Ville Niinistö (Member of the European Parliament)
20 Mar 2024 · Circular economy
Meeting with Silvia Modig (Member of the European Parliament)
26 Jan 2023 · Regulation on packaging and packaging waste
Response to A new Circular Economy Action Plan
20 Jan 2020
Circular economy is a systemic change of the economy. The transition towards a circular economy should be based on the principle of market orientation. The role of EU acquis is to set a suitable framework and steer the markets towards circularity. It is important to understand that the role of authorities is to guide and enable, not to be active economic actors in the circular economy themselves. By letting markets operate in the given framework and adapt to regulation, the transition to circularity is more efficient. The risk that the transition to circularity is approached through the notion of a planned economy is relevant in cases where there seems to be a will to limit the functioning of markets and market actors e.g. by giving or shifting active roles to municipal authorities and municipal companies.
Market orientation and market driven solutions are mainstream in pursuing climate targets in the EU. Same mind set should be applied to the transition towards a circular economy. Also, similarly to climate change mitigation, the uptake of economic instruments should be appraised in the context of circular economy, as so far, most instruments in use for promoting circularity are either bans or targets aimed at the waste management sector.
As mentioned in the road map, recycled materials only meet 12% of EU’s demand for materials. Supply constraints are mentioned as a challenge for the increased use for recycled materials, yet challenges on the demand side are not addressed adequately. From the perspective of the recycling industry, the demand of recycled materials—and rather the lack of demand—is the bottleneck for increased use of recycled materials currently. More emphasis should be put into increasing the intake of recycled materials into manufacturing processes. Many supply side constraints are resolved once the recycling industry has a clear outlook that an EU (and a global) market for secondary raw materials is taking form. Now, lack of demand for secondary raw materials is hindering investments in recycling technologies. A key in shaping the secondary raw materials market is design for circularity that needs to be boosted through different instruments.
According to the road map, insufficient information regarding the presence or not of substances of concern in products and waste often hampers their recycling and uptake. The presence of substances of concern is a question to be tackled in the next package. More emphasis should be put on achieving risk free material cycles instead of putting all emphasis on non-toxicity. Even substances of high concern can be recycled (preferably in closed loops) once there is an adequate link between the manufacturing and waste management stages. Design for circularity and a market driven dialogue between manufacturers and the recycling industry are crucial in achieving risk free cycles.
The road map mentions construction sector as one high impact area. The sector contributes up to 40% of global CO2 emissions and 30% of waste. The construction and demolition waste recycling industry has the potential of being an important supplier of secondary raw materials into the economy. This requires uptake of recycled materials in the construction sector and development of appropriate procedures for transforming waste into new materials—not only practical ones but also judicial. Streamlining End of Waste procedures in EU and leveling the playing field between member states is essential in increasing the attractiveness and profitability of transforming waste into raw materials. Overly laborious or unpredictable procedures do not support the transition. Moreover, differing national regulations (EoW material in one member state and waste in another) create obstacles for exporting/importing secondary raw materials and leveraging fully the single market. Therefore, new EU level End of Waste criteria and mutual recognition of national level criteria are needed to boost the markets.
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