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Samfunnsbedriftene

Employers' and interest organsation for public enterprises providing services of general interest.

Lobbying Activity

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

18 Feb 2022

Response to Environmental impact of waste management – revision of EU waste framework Samfunnsbedriftene - Association of Norwegian Muncipal Enterprises represents municipalities who are responsible for fulfilling EU/EEA legislation on waste in Norway. Summary: • more waste handling is expensive, and producers should pay for the impact of their products • possible conflict with state aid rules and polluter pays principle • Extended producer responsibility (EPR) – when well organised – could reduce waste and support circular value chains • local and regional authorities should be a targeted stakeholder The call for evidence states that waste collection will cost. Samfunnsbedriftene expects the impact for municipalities will be part of the hearing through CEMR – Council of European municipalities and regions. Our response emphasises how EPR may meet the targets in line with the principles of polluter pays. EPR which does not cover all costs will not have the expected impact on less waste and better material flows. More green jobs follow better material flows. Put the costs where waste may be reduced Measures should be taken as early in the value chain as possible. That is where we find the biggest impact. When a product is wasted, collection should ensure a sustainable treatment. Therefore, European Waste initiatives should first and foremost place responsibility on the producers who may avoid products which are likely to be wasted. All the costs should be covered through Extended Producer’s Responsibility schemes. That includes when waste is collected, sorted and treated by municipalities. It is imperative to give producers incentives to avoid waste and apply sustainability to their products. Paying for all costs is an incentive. Conflict with state aid rules Not putting the costs on the EPR schemes could be in conflict with state aid regulations, as some EPR schemes are competing, and some schemes do not cover all costs which instead are covered by municipalities. Those not covering all the costs for «their» products will receive an advantage compared to those who take their full responsibility. Local and regional authorities as targeted stakeholders All waste occurs in a municipality. Local and regional authorities are stakeholders who bring important knowledge to the consultations. This knowledge may not be brought forward from national authorities, as they are unaware of the local effects of the legislation. Nor will private waste collectors know the role of a responsible local authority. Consequently, Samfunnsbedriftene wants local and regional authorities to be a targeted group of stakeholders in the coming consultations on the revised waste framework directive. Samfunnsbedriftene is happy to elaborate on this response and would also contribute to a widespread exchange of experiences and best practices among our members.
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Response to EU strategy for sustainable textiles

29 Jan 2021

Samfunnsbedriftene (Norway) welcomes the initiativ on textiles. Our members are public waste operators who work every day to close the circular gap. EPR We support EPR schemes on textiles, not just for clothing, but also regarding furniture/interior/businesses/accesories and more. EPR on textiles should be developed similarly as other EPR schemes, i.e. with the producer in charge of avoiding unnecessary use of resources, building new business models to keep resources in the loop, designing for repair and recyling – and responsible for waste and littering of their products. Best pratices on collection and reuse Our experience shows regulatory challenges. We would support a system based on the materials. Other waste streams gain from collection and treatment of larger amounts. Both financially and environmentally. Allthough we acknowlegde the important role in a circular economy played by charities, should not develop a system dependent on charitable causes, as we do today. New regulations should take into consideration best practices of collection and treatment. We need enhanced cooperation along the value chains, and a global approach in order not to develop yesterday’s less efficient solutions, but share and develop best practices in order to promote a higher degree of sustainability and economic circularity in the textile industry.
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