Sirk Norge
Sirk Norge (Norwegian Waste Management and Recycling Association) leverages 30 years of industry-specific knowledge to promote and develop socially responsible waste management policies in Norway and Europe.
ID: 755303152597-77
Lobbying Activity
Response to Advanced Materials Act
13 Jan 2026
Sirk Norge represents Norway's waste and recycling industry and its stakeholders. Our 200 members (private and public companies) handle materials across all waste streams. We have over 30 years of industry-specific expertise in promoting and developing responsible waste management and circular economy policies. Sirk Norge welcomes the Commissions commitment to an Advanced Materials Act, insofar as its objective to improve circularity remains. Integrating circularity into the design and deployment of advanced materials is essential to reduce waste and mitigate geopolitical dependencies on raw materials. To ensure the Act effectively promotes a circular economy, we propose the following: 1. Regulatory Consistency and Coherence: The Act must provide a coherent legislative framework that ensures technical and legal alignment with the future Circular Economy Act (CEA) and existing regulations, specifically: Batteries Regulation (EU 2023/1542); Ecodesign for Sustainable Products Regulation (ESPR) (EU 2024/1781); Critical Raw Materials Act (CRMA) (EU 2024/1252); Waste Shipment Regulation (WSR) (EU 2024/1157); and Packaging and Packaging Waste Regulation (PPWR) (EU 2025/40). 2. Economic incentives to bridge the price gap: Secondary materials are too expensive to compete with primary raw materials. The Act should introduce economic drivers to reward the use of secondary materials. 3. Design for Circularity and Chemical Transparency: Advanced materials often have complex compositions. To ensure high-quality recycling the Act must mandate full transparency regarding chemical composition and substance of concern. Content hindering recycling must be restricted at the design stage. We support the use of Digital Product Passports (DPP) to provide recyclers with essential data on material properties and dismantling instructions. 4. Removing Barriers to Optimize Flow of secondary materials: Advanced materials often require specialized recycling infrastructure not available in every Member State. The Act must ensure these materials can be easily transported to the best available treatment facilities within the EEA by utilizing the "green-listing" procedure under the WSR to avoid unnecessary administrative delays. Additionally, we call for the establishment of EU-wide EoW criteria for key advanced material streams. EoW criteria ensure materials can be traded and reused across borders as secondary raw materials without the administrative burden of waste legislation. By prioritizing these measures, the Advanced Materials Act can help ensure that innovation in materials leads to a more resilient, competitive, and circular European industry.
Read full responseResponse to Circular Economy Act
6 Nov 2025
Sirk Norge represents Norway's waste and recycling industry and its stakeholders. Our 200 members (private and public companies) handle materials across all waste streams. We have over 30 years of industry-specific knowledge to promote and develop responsible waste management and circular economy policies. Sirk Norge fully supports the Commissions commitment to develop a robust act to accelerate the circular transition and reinforce the Single Market, simultaneously protecting our remaining natural ecosystems. The Circular Economy Act is crucial for securing Europe's strategic autonomy and competitiveness by securing a resilient supply of secondary raw materials. Despite ambitious political goals, the pace of the transition has been too slow. This stagnation is primarily driven by two market failures: 1) Virgin materials are too cheap - failing to reflect socio-economic costs associated with resource extraction, i.e. environmental damage, greenhouse gas emissions and poor working conditions; and 2) Secondary materials are too expensive to compete - due to the high cost of transforming waste into valuable secondary raw materials. This gives virgin materials a market advantage creating a structural cost disadvantage for the recycling industry. The CEA must address these fundamental issues to stimulate the robust demand necessary to establish a fully functional Single Market for high-quality, circular materials. Sirk Norge proposes: Boosting Demand and Leveling the Playing Field to establish a competitive market: Set a legally binding EU Circular Material Use Rate target of at least 25% by 2035. Implement eco-modulated levies on primary raw materials, firstly in the seven key value chains (via EUs Own Resources or similar national arrangements), earmarking revenue for circular transition. Provide capital incentives/ tax credits for circular infrastructure. Drive and strengthen reuse through reforming Extended Producer Responsibility: Introduce time-bound, specific national sub-targets for reuse. Mandate all EPR schemes to finance repair, and reuse activities. Significantly increase eco-modulation in EPR fees based on harmonized durability/ reparability criteria. Require full cost coverage under EPR, explicitly including costs for unsorted residual waste and clean up of littering/ illegal dumping. Mandatory EPR for mattresses and introduce EPR for construction and demolition waste. Circular Public Procurement (GPP) must create leading markets: Introduce mandatory, concrete obligations using qualitative standards/ weighting (not solely lowest price). Mandate a "Comply or Explain" mechanism for not using green criteria. Establish a best practice register for circular solutions, eg. modelled after the BAT/BREF register, to facilitate knowledge sharing. WEEE and Fire Safety for waste battery management must be addressed: Revise the WEEE Directive to establish stronger targets for qualitative recycling, focusing on high-quality recovery of Critical Raw Materials (CRM). Implement economic frameworks and incentives to ensure profitability of recovery of CRM. Clarify the interface between EPR and the CRMA to ensure WEEE products contribute effectively to CRM recycling targets. Address lithium battery fire risk by establishing a battery fire prevention and recovery fund. The fund should cover investments in fire prevention technology and compensate recycling facilities affected by battery fires. Consider banning certain single-use products with embedded batteries. The CEA must remove regulatory uncertainty, lag and infrastructure barriers: Fast-track the adoption of EU-wide EoW criteria for key value chains. Fast-track and adopt the Implementing Act related to WSR (EU) 2024/1157 Article 11, regarding technically feasible and economically viable treatment. Expand the EU ETS to simultaneously include several waste treatments (incineration, landfilling and waste water treatment and discharge). A general PFAS restriction in the EU.
Read full responseResponse to European Climate Law amendment
15 Sept 2025
Sirk Norge (the Norwegian Recycling and Circular Economy Association) fully supports the proposed Union 2040 climate target. Several EU countries are already lagging behind on the 2030 targets. A stringent 2040 target will help ensure that countries uphold their national efforts to cut emissions, rather than delaying action and postponing transitions in favor of the Effort Sharing Regulation. The waste management sector plays a vital role in reducing greenhouse gas emissions. Waste incineration currently accounts for significant national emissions that are hard to abate. Even in a highly circular economy where materials are reused and recycled more effectively than today there will still be a need to incinerate certain non-recyclable or hazardous wastes. In Norway, the first large-scale direct air carbon capture (DACCS) plant is now under construction at a waste incineration facility. This CCS plant, which is integrated into the EU ETS, is designed to remove emissions from the atmosphere in cooperation with international partners. It is therefore imperative for the waste management industry that the EU establishes binding climate targets between 2030 and 2050. Without such commitments, the motivation and accountability to deliver carbon reductions will weaken at all levels: company; sectoral; and national. This, in turn, will undermine the value chain transitions needed to reduce emissions related to resource extraction, production, use, and end-of-life treatment. A successful climate transition depends on a successful circular transition. And that circular transition must be largely driven by the waste management industry. By supplying secondary raw materials to the European circular economy, the industry can significantly reduce emissions. Increased use of secondary materials will help avoid greenhouse gas emissions associated with the destruction of ecosystems and use of fossil fuels in primary material extraction. However, the waste management industry continues to face challenges in overcoming market failures and achieving profitability for circular solutions that provide secondary materials. Waste markets are highly international and interconnected across borders. As long as the circular transition remains a secondary effect of climate policyrather than a central componenta lack of ambitious climate goals will also mean a failure to scale up the circular economy.
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