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TOMRA Systems ASA

TOMRA

TOMRA is a leading provider of sensor-based collection and sorting solutions that enable the circular economy, optimise resource recovery, and minimise waste in the food, recycling and mining industries.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

TOMRA is a technology leader in the field of resource management, with over 50 years of experience and a strong presence across the Single Market. Our technological solutions promote the circular economy by using advanced collection, sorting and grading systems enabling the reuse and recycling of resources. Executive summary This position paper aims to set out policy recommendations to drive the transition towards a truly circular economy, focusing on three core areas: creating cost-competitive European secondary raw materials, fostering lasting demand for secondary raw materials, and ensuring an abundant supply of quality secondary raw materials. Cost-Competitiveness: Internalise externalities and carbon emissions Ensure a level playing field with third-country imports Strengthen effective and harmonised implementation of EU circular economy legislation Boost Demand: Incentivise the use of recycled materials in products Ensure transparency, a level playing field, and compliance Boost Supply: Improve separate collection and quality of bio-waste Explore potential of DRS for key waste streams Maximise the recovery of materials from end-of-life streams Unlock investments in necessary infrastructure The Circular Economy Act (CEA) should set an enabling, long-term framework for the future of the circular economy. However, the ambitious nature of the CEA is currently overshadowed by immediate industrial crises that require decisive policy intervention today. Issues such as persistently high energy and operating costs and elevated labour costs severely weaken the economic viability of Europe's recycling sector. These immediate competitive pressures, including the price gap with virgin materials and market distortion from low-cost imports, must be urgently addressed to stabilise the sector while the EU builds its essential long-term circular framework.
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Response to Single Market Strategy 2025

31 Jan 2025

TOMRA is a global leader in enabling the circular economy through advanced collection and sorting systems. With over 105,000 installations across more than 100 markets, our solutions are critical to building sustainable societies. As a pivotal stakeholder in the circular economy sector, we would like to highlight several critical barriers and propose concrete solutions to enhance the functioning of the Single Market.
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Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

10 Dec 2024 · Waste Frame Directive

Meeting with Niels Fuglsang (Member of the European Parliament)

6 Sept 2023 · Briefing on reuse solutions in the take-away food industry

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

24 Apr 2023

TOMRA, the leading solutions provider for the collection and sorting of waste for reuse and recycling, welcomes the Packaging and Packaging Waste Regulation proposal by the European Commission, which sets ambitious but achievable goals during a timeframe to enable investment. Harmonisation across the European Single Market is needed to provide the necessary predictability for investors to scale up needed capacities and we support the proposal to replace the Directive with a Regulation with direct effect. In particular, we welcome the following measures: Waste prevention and reusable packaging, as it is essential that we implement measures higher up on the waste hierarchy, as defined under the Waste Framework Directive, in our efforts to reduce waste. Recycled content targets for packaging containing a plastic part, which will not only increase the uptake of secondary raw materials but will provide recycling players with the legal certainty they need to scale up needed infrastructure. Recyclability criteria will help ensure that we meet the objective of packaging that is recyclable both by design and in practice we believe this should be achieved by 2030 as set in the Circular Economy Action Plan. The delegated acts and the methodology to assess recyclability (at scale) should be available in due time to allow the industry to adapt with the new rules. Strengthened separate collection requirement and, in particular, the introduction of well-designed Deposit Return Systems (DRS) for plastic and metal beverage containers which are proven to increase capture rates, reduce littering, and increase circularity of materials. At the same time, given the intention for all packaging to be recyclable by 2030, (energy) recovery and landfilling of recyclable packaging materials should no longer be tolerated. Welcoming the overall direction of this new proposal, we do however note that several significant aspects of the Regulation are left to secondary legislation. Given the strong impact this Regulation will have on stakeholders all across the value chain, it will be of key importance to include a wide variety of stakeholders in the elaboration of said delegated acts. Similarly, despite the complexity of the file, TOMRA insists on the importance of having it finalised in time by mid-2024 to create the legal certainty necessary to kick-start the foreseen changes. Attached is a more detailed summary of our key proposals for further improving the Commissions proposal to achieve the goals of reducing packaging waste and improving packaging circularity.
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Meeting with Patrizia Toia (Member of the European Parliament)

27 Mar 2023 · Packaging and Packaging Waste Regulation (meeting taken by the assistant responsible)

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and Veolia Environnement and

21 Mar 2023 · Packaging Waste

Meeting with João Pimenta Lopes (Member of the European Parliament, Shadow rapporteur)

14 Mar 2023 · Embalagens e resíduos de embalagens, alteração do Regulamento (UE) 2019/1020 e da Diretiva (UE) 2019/904, e revogação da Diretiva 94/62/CE

Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

20 Dec 2022 · ETS

Meeting with Pär Holmgren (Member of the European Parliament, Shadow rapporteur)

15 Dec 2022 · EU Textile Strategy (staff level)

Meeting with Susana Solís Pérez (Member of the European Parliament, Shadow rapporteur)

10 Nov 2022 · Textile Strategy

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

22 Feb 2022

TOMRA, a leading provider of collection and recycling solutions, supports the upcoming revision of the Waste Framework Directive 2008/98/EC (WFD) and its objective of improving waste management in the EU by, among other things, reducing mixed waste and increasing preparation for re-use or recycling of waste to achieve the set targets. We believe that the EU waste hierarchy should be strictly followed with prevention as a priority. For the purpose of this paper we focus on three elements we believe should be carefully considered in the revision process, as they have a key role to play in the achievement of the aforementioned objectives. Firstly, certain definitions and the EU waste hierarchy must be updated to reflect the current circular economy ambitions and ensure the promotion of high-quality recycling over downcycling and other forms of recovery. The waste hierarchy should include additional categorisation to distinguish between closed-loop and open-loop recycling (with priority given to closed-loop recycling), as well as between mechanical and chemical recycling to ensure that proven mechanical recycling processes are prioritised where technically possible. Secondly, in addition to further strengthening separate collections, mandatory mixed waste sorting prior to landfill and incineration should be introduced in order to increase the capture rate of valuable recyclable materials. Introducing mixed waste sorting combined with advanced mechanical recycling processes can ensure that valuable resources are effectively circulated back into the economy, reduces GHG emissions from waste management, and brings EU Member States closer to reaching their municipal waste recycling targets. Thirdly, in line with the upcoming Textiles Strategy, and the overall objectives of the Green Deal and the Circular Economy Action Plan of enhancing the overall circularity of the textile sector, the revision of the WFD should also address certain downstream considerations linked to textile waste, including recycling targets and the introduction of mandatory Extended Producer Responsibility (EPR) to enable the scaling up of collection, sorting and recycling infrastructure. Please find attached our detailed argumentation supporting the three aforementioned points. We remain available to discuss any element addressed in our feedback with the relevant team at the European Commission.
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

TOMRA is the leading technology provider for collection and sorting solutions enabling the circular economy. We strongly support the efforts undertaken by the European Commission to review Regulation 282/2008 and the novel approach to food contact recycled plastics that allows for innovations to emerge and scale up. Since the intended focus of the proposed regulation is the safety of recycled plastics for food contact materials (FCM), we strongly recommend that recycling technologies and processes are foremostly judged on their capability to deliver and demonstrate the (food) safety of their recyclates, and that no undue restrictions are imposed by rigidly prescribed requirements. Strictly regulating the safety/ quality of the final recycled product rather than the exact steps to get there. In this way the new Regulation ensures than any recycling technology/ processes, and different combinations thereof – which can result in plastic materials that meet the requirements of the Food Contact Material Regulation 1935/2004 Art 3 – will be encouraged and possible to authorise. In the attached paper we are providing our input and concrete comments on the draft Regulation.
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Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

15 Jun 2021

TOMRA has, like many other stakeholders who are interested in a high level Circular Economy and the avoidance of litter at source rather than cleaning up afterwards, supported and signed the position paper of Brussels based not-for-profit organization Reloop. Insofar we would like to refer to Reloop´s contribution. In addition, TOMRA would like to remind the Commission of the intention of the 90% separate collection target. Littering of the most relevant plastic items in Europe must be avoided. You only avoid litter by giving waste a value or by trying to educate people to throw waste in a separate bin. If the plastic bottles which are cleaned up from beaches, parks, riverways etc. and which inevitably end up in a mixed residual collection bin and system, can be counted towards the 90% target, the entire approach of the SUPD´s 90% is meaningless. Honestly, the EU would look foolish in such case. The explicit exclusion of mixed residual waste is paramount for the entire credibility of the EU approach here. We are aware that the Commission does not want to allow for the inclusion of mixed residual waste in the 90% target. However, the current wording is foggy, imprecise and provides significant room for massive misinterpretation by those who wish to misunderstand. We therefore urgently request the Commission to make it unambiguously clear by a foreword, recital or specific text passage that any collection of mixed residual waste cannot contribute to the 90% separate collection target of the SUPD. Of equal importance is the inclusion of food quality requirements for output from separate collection. Otherwise, the growing percentage of PET bottle-to-bottle recycling by mechanical recycling processes is endangered by chemical downcycling processes. This would diminish the increasing prime example of a well working Circular Economy.
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