Zero Waste Alliance Ireland
ZWAI
i) finding and recommending environmentally sustainable and practical solutions for domestic, municipal, industrial and agricultural waste (including wastewater) management in Ireland; ii) lobbying Government and local authorities to implement environmentally sustainable waste management practices, including clean production, elimination of toxic substances from products, re-use, recycling, segregation of discarded materials at source, the Circular Economy, and other beneficial practices; iii) lobbying Government to follow the best international practice in other countries, regions and cities ; iv) raising public awareness about the long-term damaging human and animal health and economic consequences of landfilling and of the destruction of materials by incineration; and, v) maintaining contact and exchanging information with similar national networks in other countries, and with international zero waste organisations.
ID: 417362640092-95
Lobbying Activity
Response to Food and Feed Safety Simplification Omnibus
14 Oct 2025
It is our conclusion that the proposed initiative and Regulation will disempower local food systems. Furthermore it risks justifying loosening environmental standards and pushing protectionist trade measures. The newly planned regulations aim to have a rapid effect, ignoring long-term and protective rules for the environment and nature. If nature is damaged a little more in the short term by pesticides for better harvests and profit, then we will not be able to use so-called solutions provided by pesticides and biocides again, as Nature's capital will be exhausted by the loss of biodiversity, and the end result will be an increase in pre-harvesting, post-harvesting, and consumer waste of every type. Overall, the proposed initiative and Regulation runs counter to the EU Nature Restoration Legislation.
Read full responseResponse to Roadmap towards Nature Credits
30 Sept 2025
Zero Waste Alliance Ireland (ZWAI) welcomes the European Commissions initiative to explore innovative finance mechanisms for biodiversity through the Roadmap towards Nature Credits. The ambition to mobilise private investment for nature restoration and conservation is timely, reflecting the urgent need to address biodiversity loss across the EU. However, our analysis in the following sections of this submission identifies significant structural, legal and ecological risks within the Roadmap that could undermine its effectiveness and credibility if left unaddressed. Firstly, the Roadmap suffers from vague definitions and a lack of robust operational and legal safeguards (expanded in sections 3.2 to 3.5 below). Key concepts such as nature credits and nature-positive outcomes remain undefined, with no clear methodology for measurement, verification or enforceable compliance. The framework relies on corporate good faith to deliver outcomes, despite historical evidence that voluntary approaches often fail to produce genuine ecological gains. Moreover, by attempting to impose short-term financial logic on long-term ecological processes, the proposed market risks intergenerational greenwashing, where credits may be sold for benefits that are uncertain, temporary or unmonitored. Secondly, the Roadmap risks operating in isolation from the EUs established nature protection and biodiversity policy system outlined in section 1.4 above. Without explicit integration with the EU Biodiversity Strategy for 2030, the Nature Restoration Law and the Birds and Habitats Directives, the crediting scheme may fragment conservation efforts and inadvertently commodify ecosystems. Nature credits, if treated as tradable units, could be misused to justify ongoing degradation or circumvent legally binding obligations, undermining the EUs commitment to avoid, minimise and restore ecological harm. Thirdly, lessons from nearly three decades of global carbon and biodiversity offset markets demonstrate systemic risks that are highly relevant to the Roadmap. Experiences from the Clean Development Mechanism, voluntary carbon markets and avoided deforestation projects reveal widespread issues with non-additionality, inflated baselines, monitoring failures and fraud. In many cases, these projects have harmed local communities and Indigenous peoples, highlighting the social as well as ecological consequences of poorly designed credit systems. Taken together, these findings underscore that, without precise definitions, legally enforceable standards, integration with EU policy, and mechanisms to prevent fraud and ecological harm, the Roadmap risks replicating the failures of past market-based environmental schemes. ZWAI therefore calls on the European Commission to ensure that any nature credit framework prioritises biodiversity integrity, complements binding EU obligations and safeguards both ecosystems and the communities that depend upon them. In addition to the general observations above, Zero Waste Alliance Ireland would like to make further and more specific observations (in sections 3.2 to 3.10 below) on issues which we consider should become important, or even essential, components of a forthcoming EU policy and operational system of Nature Credits.
Read full responseResponse to Policy agenda for cities
26 May 2025
Urban mobility, biodiversity and the use of sustainable and renewable materials should be the foundation pillars of Europes cities and large town, supported by the new Initiative and proposed New Agenda for cities. This requires a shift away from car-dominated, wasteful systems toward efficient, circular, and people-centred transport networks. The Commission must empower cities with the funding, authority, and regulatory tools to lead this transitionfrom transport infrastructure to behavioural culture, from logistics to biodiversity. A city-centric approach to transport reform will not only help meet emissions targets but create cleaner air, quieter streets, and more connected communities. By putting equity and ecological resilience at the heart of mobility policy, the EU can drive a transportation revolution for future generations. However, achieving the EUs climate and ecological goals requires more than local goodwill, it demands coordinated action across all governance levels. The case of Ireland illustrates how over-reliance on local councils without adequate national frameworks and resources can lead to fragmented implementation, delays, and missed opportunities for meaningful change. To unlock the full potential of sustainable urban transport, nature-based solutions and net-zero carbon cities which would produce near zero waste, the European Commission must drive the standardisation of policies and metrics, develop new metrics where necessary (as proposed in section 3.7.5.2 above), strengthen enforcement through early expert engagement, and provide clear incentives and support structures. Empowering cities and their local authorities with the tools, funding, and regulatory backing needed to act decisively will accelerate the transition to efficient, circular, and biodiverse urban environments. By integrating biodiversity as a mandatory planning requirement and embedding holistic approaches, such as the H-value for building materials and the 15-minute city model, the EU can lead a transformative shift toward healthier, greener, and more resilient cities for all citizens. If these recommendations are implemented, the result will be beneficial for all city residents, for visitors to these healthy cities, and beneficial for the global climate.
Read full responseResponse to Regulation amending the Registry Union Regulation on land use, land use change and forestry matters
5 May 2025
The current and draft regulations for the EU Union Registry represent technical progress but lack alignment with the EU's sustainability ethos. Integrating zero waste principles into the LULUCF framework is not a peripheral issue but a strategic imperative. A reformed Union Registry should reflect not just carbon figures, but the real ecological and social gains from regenerative, circular land use. Only by bridging the gaps between carbon accounting, waste reduction, and ecological restoration can the EU credibly lead the way toward climate neutrality by 2050. The review of the Delegated Regulation (EU) 2019/1122 reveals that, despite considerable technical detail and recent improvements in data management, significant gaps remain when viewed through a zero waste lens. By failing to capture the multi-dimensional contributions of circular land use and waste prevention strategies, the current framework limits the EUs capacity to drive systemic, transformative change. Realigning the Union Registry to incorporate robust, integrated metrics that reward zero waste practices is not merely a technical adjustmentit is a strategic imperative for achieving a resilient, sustainable future. Adopting the recommended measures would: Enhance the accuracy and comprehensiveness of environmental data. Foster innovation by linking incentives to regenerative practices. Encourage inter-sectoral cooperation and harmonise environmental governance across EU policies. In a context where climate change and resource depletion are pressing issues, the transformation of regulatory frameworks to support a zero waste economy is essential. Implementing these recommendations would ensure that the Union Registry not only records compliance but also actively contributes to the EUs broader agenda of circularity and sustainable development.
Read full responseResponse to The European Oceans Pact
17 Feb 2025
In the attached submission we hope we have provided sufficient evidence that the proposed Ocean Pact, while admirable in many places, is also deficient in many respects; and therefore we have made a number of suggestions for its significant improvement, and we hope that these suggestions will be taken up by the European Commission.
Read full responseResponse to Revision of EU legislation on end-of-life vehicles
4 Dec 2023
Vehicle production, use and disposal is associated with negative environmental impacts at every stage, and sometimes with negative social impacts. Tackling the problem of end-of-life vehicle waste is challenging and Zero Waste Alliance Ireland welcomes the effort of the EU Commission to address these issues. However, we advocate that the best way to minimise the impacts of end-of-life vehicle waste is to prevent it in the first place. This can be achieved through investment and development in public transport infrastructure in cities and rural areas, with the added benefit of positive social and human health impacts. Furthermore, ecodesign of vehicle parts and tyres can play a part in minimising the constraints and negative environmental impacts of ELV waste processing. Lastly, the substitution of synthetic fossil fuel derived plastics and rubber in vehicles and tyres can only be sustainably achieved if there is a simultaneous decrease in the demand and production of vehicles. Without a decrease in vehicle production, plant-based materials will compete for land-use with food crops, thereby driving up food costs. Considering all these points, the problem of ELV waste is multi-faceted and requires simultaneous action across several industries including waste management, agriculture, civil infrastructure, private manufacturing companies and the fossil fuel industries. The integration of recycled plastics into the automotive industry demands a holistic approach to verification and traceability. It is our submission that the proposed Directive should mandate the establishment of competent authorities in Member States; and these should be empowered to enforce traceability measures, and to request manufacturers to provide detailed certification. The incorporation of third-party audit checks should also be required by the proposed ELV Directive in order to strengthen the credibility of the entire process, and to ensure that recycled materials used in vehicles comply in all respects with declared EU standards. Our suggested strategy would not only assist the development of the circular economy for vehicles, but would help to improve environmental sustainability, and may also reinforce the commitment of the automotive industry to responsible and transparent practices. Turning to the proposed and currently adopted revised ELV Directive, it is our conclusion that the proposed regulation for ELVs is quite rigorous. The requirement for producers to pay for the cost of collection, dismantling and recycling of the vehicles they sell is welcome. In theory this should incentivise the production of long-lasting durable vehicles that are easy to dismantle and recycle. This requirement should also increase the repairability of vehicles since a vehicle that is continuously repaired will not be scrapped before it has reached the end of its useful life. Crucially, measures to prevent "planned failure" of vehicle parts are not included in the regulation. This is a major missed opportunity to bring the automotive industry closer to the circular economy aimed for in the European Green Deal. It is our submission that the that the proposed directive also fails to discourage the increasing number of vehicles (especially larger cars such as SUVs) placed on the European market, it does not align with the EU policy of reducing dependence on private car use, and fails to ensure that end of life vehicles exported from EU Member States do not become waste in third countries.
Read full responseResponse to Waste Framework review to reduce waste and the environmental impact of waste management
22 Nov 2023
Zero Waste Alliance Ireland (ZWAI) is very pleased to have the opportunity to provide additional feedback to the European Commission at this stage, when the Commission is considering the adoption of a revised targeted Waste Framework Directive, to be presented to the European Parliament and Council. Even though we have some serious reservations about the Commissions currently adopted proposal for a targeted revision of the Waste Framework Directive, we believe that it will be an extremely important legislative component of the overall environmental, resource management and sustainability policies of the EU. Zero Waste Alliance Ireland has examined carefully the Commissions proposed targeted revision of the Waste Framework Directive; and, while there are many useful and environmentally beneficial improvements proposed, the draft Directive still lacks a number of important features. The proposal is narrowed to include only two types of waste: textile waste and food waste, and even these are considered in a way which does not include the entire operations and activities which lead to the generation of wastes as a result of food production, and textile production, from raw materials to final disposal. In our submission, we suggest a number of changes which we hope the Commission would be willing to accept, even though the draft directive is already at the adoption stage. Such changes should include, as a minimum: Extended producer responsibility; Recognition that the current system of extraction, transport, raw material production, processing and disposal has serious widespread effects on the Earths climate; Much tighter controls on the export of waste from one member state to another and from the EU to other countries; Stronger penalties for failure to reach waste production and recycling targets; and, Inclusion of construction and demolition waste in the revised directive. A more detailed submission is in the attached document.
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
3 Nov 2023
Zero Waste Alliance Ireland supports many aspects of the proposed Directive, for example the requirement for soil health monitoring by Member States, the establishment of soil districts and the mention of circularity of agricultural fertilisers. Annex III mentioned crop rotation, crop diversification and reduction of chemical use, which was most welcome. However, some aspects of the Proposed Directive are lacking. For example: the testing of total respiration rate of soil samples will not accurately reflect soil biodiversity. Furthermore, there was a total absence of livestock reduction principles, nor a recommendation for a transition to plant-based diets. Agro- ecological principles were not mentioned; we argue that these principles are crucial to the success of the Directive. Violation penalties are also inadequate. In conclusion, the comprehensive approach in the proposed Soil Directive may result in a more sustainable and resilient agricultural landscape in Europe. The promotion of organic farming practices, encouragement of crop rotation, and the preservation of natural habitats collectively form the cornerstone of this initiative, aimed at safeguarding soil health and nurturing biodiversity. Moreover, through education, innovation, and policy coherence, the Directive will not only support the agricultural community but will also engage citizens in recognizing the critical role of soil health in environmental sustainability. By implementing these multifaceted strategies, the European Commission can endeavour to pave the way for a future where soil health and biodiversity thrive, ensuring sustainable food production and ecological equilibrium for generations to come. The Directive represents a good step towards creating a harmonious balance between agricultural needs and environmental preservation.
Read full responseResponse to Soil Health Law – protecting, sustainably managing and restoring EU soils
16 Mar 2022
Zero Waste Alliance Ireland (ZWAI) is very pleased to have the opportunity to provide feedback to the European Commission on this important topic, and we have undertaken some research to provide the Commission with reasonably detailed and evidence-based comments on the proposed Directive. We trust that the observations in this submission will be considered as a relevant and a positive contribution to EU strategies and measures for the improvement of soil health and for the sustainable use and restoration of soils.
Our feedback is attached as a .pdf file, including two appendices.
Read full response