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Zero Waste Europe

ZWE

Zero Waste Europe is a network of communities working towards waste elimination and resource efficiency.

Lobbying Activity

Zero Waste Europe Urges Exclusion of Waste Incineration Investments

5 Dec 2025
Topic — The initiative reviews the EU taxonomy environmental delegated act to update technical screening criteria.
Message — The organization requests that incineration and landfilling be explicitly excluded from sustainable finance criteria. They demand mandatory door-to-door collection systems and strict impurity limits to ensure high-quality material recovery. They also advocate for weight-based accounting to prevent misleading claims regarding recycled plastic content.123
Why — Stronger criteria would secure more investment for zero-waste communities and high-performing recycling systems.45
Impact — Incineration and landfill operators lose access to green funding due to stricter environmental benchmarks.6
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Meeting with Zala Tomašič (Member of the European Parliament)

19 Nov 2025 · Recycling

Rethink Plastic Alliance urges comprehensive EU Circular Economy Act

6 Nov 2025
Topic — EU Circular Economy Act to enhance economic security, competitiveness, and sustainable production.
Message — The Alliance calls for an EU Circular Economy Act that reflects the waste hierarchy by including strong measures on waste prevention and reuse, while ensuring material loops are toxic-free. They advocate for binding material footprint targets, EPR reform to fund prevention and reuse, and restrictions on substances of concern in plastics.1234
Why — This would advance their mission to eliminate waste and promote safer circular materials.56
Impact — Industries using toxic polymers and single-use packaging lose current low-cost production advantages.789
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Meeting with Jessika Roswall (Commissioner) and

29 Oct 2025 · Roundtable- closing the Loop : Addressing the Plastic Recycling Crisis in Europe

Meeting with Matthieu Moulonguet (Cabinet of Commissioner Wopke Hoekstra), Miguel Jose Garcia Jones (Cabinet of Commissioner Wopke Hoekstra) and

27 Aug 2025 · Carbon Farming and Carbon Removal Certification

Zero Waste Europe warns CO2 infrastructure risks locking in incineration

25 Aug 2025
Topic — This consultation addresses a legislative initiative for developing competitive EU CO2 transportation infrastructure.
Message — ZWE demands a holistic impact assessment prioritizing the circular economy and resource efficiency. They insist CO2 infrastructure should only support incineration if waste prevention and recycling are fully maximized. CCS must not justify expanding capacity or prolonging old plant lifetimes.123
Why — This approach ensures that investments support zero-emission pathways rather than outdated waste treatment.4
Impact — Operators of polluting waste-to-energy plants lose the opportunity to extend their facilities' operational life.5
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Zero Waste Europe urges CBAM expansion to drive circular economy

25 Aug 2025
Topic — EU proposal to extend carbon border adjustment mechanism to downstream products.
Message — The organization requests comprehensive CBAM expansion including downstream products, organic chemicals, polymers, and methane emissions. They want removal of the scrap metal exemption and integration with Digital Product Passports to track embedded emissions.123
Why — This would strengthen circular economy policies and boost EU remanufacturing markets toward €100 billion by 2030.45
Impact — Overseas producers lose advantages from avoiding methane regulations and scrap exemptions under current rules.67
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Response to EU rules for the calculation and reporting of recycled content in single-use plastic bottles

19 Aug 2025

Zero Waste Europe (ZWE) welcomes the opportunity to provide feedback on the Implementing Decision proposal for calculating, verifying, and reporting recycled plastic content in single-use plastic beverage bottles. This proposal will likely serve as a blueprint for future legislation introducing recycled content targets across multiple sectors, including packaging, automotive, and textiles, but also for other materials. Given its broad influence, the methodology must ensure high levels of transparency and traceability, rewards for efficient technologies and strong safeguards against greenwashing. ZWE is very concerned about the Commission's decision to use the mass balance model with fuel-use excluded, including the dual-use concept. This approach contradicts the definition of recycling established under the Waste Framework Directive. In addition, the proposal for mass balance to consider pre-consumer waste as input for recycled content violates the principle of effectiveness established in EU environmental legislation by the Court of Justice of the European Union (CJEU). While the proposal acknowledges the need for different recycling technologies to work together, it fails to provide concrete mechanisms to enable this complementarity in the core of the article. Through the process, the content became very technical, creating a complex framework that contradicts the Better Regulation principles the Commission is currently implementing. This will be difficult for Member States to enforce and creates additional challenges for monitoring imported recyclate from outside the EU. ZWE remains available to support the European Commission in future work on this critical issue. Additional detailed information is provided in the attached document.
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Zero Waste Europe urges strict limits on waste incineration BioCCS

23 Jul 2025
Topic — EU rules for certifying permanent carbon removal technologies like direct air capture.
Message — The group demands the exclusion of waste incinerators from certification unless they implement full separate collection systems for recyclables. They claim that certifying carbon from unsorted waste undermines the circular economy and ignores the waste hierarchy.123
Why — Restricting these certifications prevents incineration from becoming more cost-competitive than recycling and reuse.4
Impact — Incineration facilities would lose potential public funding and certification for their existing waste processing.5
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Meeting with Sara Matthieu (Member of the European Parliament)

17 Jul 2025 · CE Act

Meeting with Bruno Tobback (Member of the European Parliament) and SYSTEMIQ LIMITED

2 Jul 2025 · Fossil-Free Plastic Production in Belgium and Europe

Meeting with Stéphane Séjourné (Executive Vice-President) and

2 Jul 2025 · EU Clean Industrial Dialogue on Circularity

Meeting with Jessika Roswall (Commissioner) and

1 Jul 2025 · Circular and toxic-free plastic

Meeting with Luis Planas Herrera (Cabinet of Commissioner Jessika Roswall) and European Environmental Bureau and

30 Jun 2025 · Simplification agenda, EPR and waste prevention in WEEE

Meeting with Sabine Pelsser (Head of Unit Health and Food Safety)

24 Jun 2025 · Discussion on the FCM Regulation and understanding the importance of the implementation of existing EU rules.

Zero Waste Europe urges EU to prioritize material sufficiency

23 Jun 2025
Topic — The EU initiative aims to develop a circular and climate-neutral bioeconomy strategy.
Message — The group demands the strategy focus on absolute consumption reduction rather than material substitution. They also request that organic waste be prioritized for soil health instead of industrial feedstock.12
Why — Stricter rules would prevent regrettable substitutions and support their long-term resource efficiency goals.3
Impact — Industrial bioplastic and paper producers would lose favorable market access for single-use products.4
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Response to EU emissions trading system for maritime, aviation and stationary installations, and market stability reserve - review

19 Jun 2025

We encourage the Commission to ensure full inclusion of municipal waste incineration under the EU ETS with the following considerations: (1) Both power and heat from MWI should be covered without free allowances, aligning with ETS coverage of the buildings sector in 2027. (2) All CO emissionsfossil and non-fossilshould be reported and priced; biogenic CO has the same climate impact and excluding it creates inconsistencies and loopholes. (3) The cascading principle must be respected: ETS design should reinforce, not undermine, recycling and waste prevention. (4) A 20 MW threshold may allow avoidance; a lower threshold (e.g. 10 MW) aligned with the IED would ensure broader coverage. These points are essential to safeguard the environmental integrity of the EU ETS and promote a circular economy.
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Meeting with Aurel Ciobanu-Dordea (Director Environment)

12 Jun 2025 · Exchange of views on Circular Economy Act and end-of-waste

Meeting with Arthur Corbin (Cabinet of Executive Vice-President Stéphane Séjourné), Laia Pinos Mataro (Cabinet of Executive Vice-President Stéphane Séjourné)

10 Jun 2025 · Circular Economy Act

Meeting with Aurel Ciobanu-Dordea (Director Environment)

20 May 2025 · Exchange of views on Circular Economy Act

Zero Waste Europe urges ban on waste incineration funding

15 May 2025
Topic — The EU is evaluating operating rules for the Modernisation Fund climate initiative.
Message — Zero Waste Europe recommends the Commission explicitly exclude waste incineration from eligible investments. They seek clear guidance to ensure financing is redirected toward truly sustainable projects.12
Why — This prevents misallocation of public funds to infrastructure that undermines zero-waste targets.3
Impact — Waste incineration operators in Eastern Europe lose access to billions in subsidies.4
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Meeting with Sirpa Pietikäinen (Member of the European Parliament) and European Youth Forum and

23 Apr 2025 · Environmental action

Meeting with Aurel Ciobanu-Dordea (Director Environment)

8 Apr 2025 · Exchange of views on the Circular Economy Act

Zero Waste Europe warns against weakening toxic chemical standards

26 Mar 2025
Topic — The initiative proposes amendments to the EU Taxonomy to simplify sustainability reporting.
Message — Zero Waste Europe opposes changes that would allow green investments to include harmful chemicals. Revisions should focus on usability rather than reducing the ambition level of environmental standards.12
Why — Maintaining strict criteria prevents the dilution of standards required for a circular economy.3
Impact — European citizens face health risks from continued exposure to unregulated hazardous chemicals.4
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Response to Persistent organic pollutants - PBDEs

18 Mar 2025

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards a better use of resources and the elimination of waste in our society. We advocate for sustainable systems, for the redesign of our relationship with resources, and for a global shift towards environmental justice. ZWE welcomes the proposal to lower the unintentional trace contaminant (UTC) limit values for harmful PBDEs in mixtures and articles made from both new and recycled materials, and strongly supports the intent to specifically protect children. As already recognised, due to past and current recycling activities PBDEs occur in recovered materials and products made from recycled materials, including many consumer products used by the general public. Furthermore, when plastics with brominated flame retardants are heated and recycled into new plastic products, brominated and chlorinated dioxins are created which further contaminate the recycled materials and pose additional health risks to consumers and workers who come into contact with these products. With the upcoming Circular Economy Act looking to increase market demand for recycled materials and encourage their use, it is imperative that the materials entering the market are free of hazardous substances. The EU must promote value preservation and ensure the strategic use of our resources, while ensuring a safe and toxic-free transition for SMEs, workers and citizens.[1] Therefore, given the urgent need to completely phase out PBDEs to minimise exposure and completely remove these substances from material cycles, it is crucial that this proposal is adopted in a timely manner, with the lowest UTC levels and the shortest transition timelines possible. References: [1] Circular Economy Act policy recommendations: https://zerowasteeurope.eu/library/circular-economy-act-policy-recommendations/
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Meeting with Delara Burkhardt (Member of the European Parliament)

26 Feb 2025 · Kreislaufwirtschaft

Meeting with Delara Burkhardt (Member of the European Parliament)

25 Feb 2025 · Clean Industrial Deal

Meeting with Paul Speight (Head of Unit Environment) and European Environmental Bureau and

16 Jan 2025 · Restrictions under REACH

Meeting with Annalisa Corrado (Member of the European Parliament)

10 Dec 2024 · Circular Economy

Meeting with Lynn Boylan (Member of the European Parliament)

14 Nov 2024 · Chemical recycling, Packaging and Packaging Waste, Food Contact Materials, Single Use Plastics

Meeting with Jeannette Baljeu (Member of the European Parliament, Shadow rapporteur)

30 Sept 2024 · Waste Framework Directive

Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides) and International Air Transport Association and

16 Apr 2024 · On circular economy and improving cabin waste management.

Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and International Air Transport Association and

16 Apr 2024 · Circular economy and improving cabin waste management

Meeting with Rachel Smit (Cabinet of Commissioner Adina Vălean), Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and

16 Apr 2024 · Circular economy and improving cabin waste management

Response to Update of related legislation as a consequence of the new regulation on recycled plastic Food Contact Materials

15 Apr 2024

Zero Waste Europe (ZWE) welcomes the opportunity to provide input into this Commissions initiative and supports a proposed new regulation that will bring necessary updates to Regulation (EU) No 10/2011, aiming to increase safety and quality control regarding plastic FCMs. We recognise that the proposed changes will ensure a higher level of public health protection. We welcome the introduction of requirements for plastic materials and articles intended to come into repeated contact with foods. This way, the proposed regulation has a potential to increase safety of food and beverage packaging covered by the reuse or refill targets in the upcoming Packaging and Packaging Waste Regulation (PPWR). However, to provide clarity and ensure consistency in compliance across the whole regulatory framework governing food packaging materials, we strongly encourage harmonisation of certain terms between this proposed regulation (such as repeated use) and definitions and terms contained in the PPWR (such as re-use and refill). Moreover, as the new paragraph 3 in Article 10 states that Where intended for repeated use in contact with food, the composition of plastic materials and articles shall be such, so as to guarantee that no increase in the migration of constituents of the material or article to the food would occur during their maximum life span when subjected to subsequent use cycles, the migration test(s) should be carried out / required at the point of the maximum number of use cycles (maximum life span) recommended by the manufacturer or other operator responsible for placing articles, intended for repeated use in contact with food, on the market. Also, the migration test(s) should be performed always on the final article as this is the only way to ensure that such reusable / refillable food contact article (which may include both virgin and recycled substances and materials) is comprehensively tested, including for non-intentionally added substances (NIAS). Regarding Labelling of article intended for repeated use under Article 14a (1) and the new requirement on provision of information that includeappropriate instructions designed to slow down deterioration of the material or article, as well as a description of observable changes of the article or material that may indicate the deterioration of the article or material and that it has reached its maximum life span, in our opinion, this would require a proper guideline and clear criteria, defining both acceptable and unacceptable deterioration of the plastic material or article. Its important for both the manufacturers (or other operators responsible for placing reusable/refillable articles on the market) and for the enforcement authorities to understand when and how such articles may endanger human health. Finally, this new regulation creates an opportunity to ensure a higher level of health protection of vulnerable groups, through adding extra requirements regarding labelling (under Article 14a). To enable vulnerable groups of consumers (such as pregnant women, infants and young children) make informed choices, we propose: Plastic materials and articles in contact with food or intended to be brought into contact with food shall provide the user with adequate information on presence of substances of concern (such as substances authorised for use but been identified as having properties hazardous to human health due to their reproductive toxicity and their potential endocrine disrupting properties and listed as such in accordance with Regulation (EC) No 1278/2008 of the European Parliament and of the Council ), in form of notification: "may contain" or "contain" substance xxx.
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Meeting with Helena Braun (Cabinet of Vice-President Maroš Šefčovič) and European Environmental Bureau and

9 Apr 2024 · European Green Deal and sustainable resource management

Response to Evaluation of the National Emission reduction Commitments Directive

13 Mar 2024

Zero Waste Europe welcomes the European Commission's decision to begin revising the National Emission Reduction Commitments Directive. We believe it's crucial to evaluate the current implementation status and effectiveness of this directive, which sets reduction obligations for air pollutant emissions among EU member states. While the objectives outlined in the NEC Directive remain valid, they need updating to reflect new scientific evidence and changes in policy frameworks since 2016. Since then, we've gathered better scientific understanding of how air pollution impacts health, the environment, and the climate. Updated air quality guidelines from the World Health Organization and revisions to European air quality regulations underscore the need for stricter reduction targets, especially for short-lived climate pollutants like methane. To ensure compliance and meet EU climate targets, we propose adding a reduction target for methane. This target should follow a steep, stringent, and linear decreasing path, with additional binding interim targets every five years. Furthermore, we urge for stricter regulations and improved enforcement procedures to ensure timely fulfilment of reduction obligations. This includes better enforcement mechanisms at both national and EU levels, with penalties for non-compliance. We recommend implementing strict deadlines for submitting National Air Pollution Control Programmes, accompanied by automatic prosecution notices for responsible authorities or governments in case of delays.
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Zero Waste Europe demands total ban on harmful bisphenols

8 Mar 2024
Topic — New EU regulation proposal restricting bisphenol A and similar chemicals in food packaging.
Message — The group requests a comprehensive ban on all bisphenols and Category 2 substances to stop hazardous chemical substitutions. They also want the stock sell-off period restricted to twelve months.12
Why — Stricter rules would help the organization achieve its goal of minimizing toxic chemical exposure.3
Impact — Manufacturers would lose the ability to sell old stock indefinitely or use similar chemical substitutes.45
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Meeting with Sirpa Pietikäinen (Member of the European Parliament)

22 Feb 2024 · Relevant Circular Economy Policies

Meeting with Martin Hojsík (Member of the European Parliament)

16 Feb 2024 · circular economy, elections, reuse, recycling

Response to Measures to reduce microplastic pollution

17 Jan 2024

The Rethink Plastic Alliance has consistently brought to the attention of EU institutions the alarming issue of plastic pellet pollution. Over the years, we have diligently reported numerous cases, highlighting the detrimental impact of plastic pellet pollution on ecosystems and communities. We have observed persistent and chronic losses of plastic pellets, ranging from the industrial sites in Tarragona, Spain, to the facility in Ecaussinnes, Belgium. These incidents underscore the widespread and transboundary nature of the problem, emphasizing the urgent need for comprehensive and effective regulatory measures. Furthermore, our concerns extend to catastrophic spills, exemplified by the ongoing crisis in Galicia. This incident serves as a stark reminder of the potential environmental and economic repercussions associated with the mishandling and release of plastic pellets into the environment. It is crucial for EU institutions to recognize the severity of these issues and take decisive action to address and prevent further harm. The proposed regulation must incorporate robust mechanisms for monitoring, enforcement, and accountability to ensure that industrial sites adhere to stringent standards in handling and managing plastic pellets. Our specific recommendations are available in the file attached. By taking decisive action, the EU can set a precedent for responsible environmental stewardship and contribute to the global effort to combat plastic pollution.
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Meeting with Pernille Weiss-Ehler (Member of the European Parliament)

8 Dec 2023 · Proposal for a targeted revision of the Waste Framework Directive

Meeting with Nils Torvalds (Member of the European Parliament) and EDANA AISBL

8 Dec 2023 · Waste Framework Directive

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

21 Nov 2023

Please find our feedback in the document attached.
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Meeting with Pascal Canfin (Member of the European Parliament) and European Environmental Bureau and

16 Nov 2023 · Green Deal

Meeting with Róża Thun Und Hohenstein (Member of the European Parliament, Shadow rapporteur)

29 Sept 2023 · Waste Framework Directive revision

Meeting with Pernille Weiss-Ehler (Member of the European Parliament, Shadow rapporteur)

22 Aug 2023 · Directive on substantiation and communication of explicit environmental claims (Green Claims Directive)

Zero Waste Europe urges continuous CO2 monitoring for waste incinerators

15 Aug 2023
Topic — Revision of EU rules for monitoring and reporting greenhouse gas emissions.
Message — The group calls for continuous measurement of incinerator emissions with annual audits. They advocate for individual biogenic emission assessments and weekly laboratory analysis.123
Why — Stricter monitoring would support their mission to prioritize recycling over waste incineration.45
Impact — Waste incineration facilities would face higher operational costs and stricter reporting requirements.67
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Response to Carbon capture utilisation and storage deployment

29 Jul 2023

We would like to offer our feedback on the consultation regarding Industrial Carbon Management, specifically focusing on the deployment of Carbon Capture, Utilisation, and Storage (CCUS) projects. As we understand, the decision on prioritizing projects should consider the EU Sustainable Finance Taxonomy and relevant sectoral policies, such as waste directives, including the waste hierarchy. After careful consideration, we recommend not financing CCUS projects on non-hazardous (municipal) waste incinerators for the following reasons: - Circular Economy Goals: One of the key objectives of the EU's Circular Economy Action Plan is to minimize waste generation and promote sustainable waste treatment methods. In fact, te CEAP aims to halve residual waste (feedstock for incinerators) by 2030. Introducing CCS on incinerators could inadvertently create a lock-in effect, suggesting that incineration is a low-carbon or carbon-negative approach. This could hinder the implementation of more effective waste prevention measures and impede progress towards achieving circular economy objectives. - Recycling Potential and Circular Economy Objectives: Recent studies conducted by reputable organizations like Eunomia (2023), Reloop (2022), and ZWE have brought to light a concerning aspect of waste incineration. It has been found that a substantial portion of the waste being incinerated is, in fact, recyclable. Emphasizing the potential of recycling in achieving circular economy objectives, these reports have shown that recycling offers significantly higher greenhouse gas (GHG) benefits compared to incineration. In this context, exploring alternative approaches to decarbonization, such as Mixed Waste Sorting (MWS), can effectively extract valuable materials, such as plastics and metals, from the waste stream. This approach contributes to the reduction of greenhouse gas emissions without the need for waste incineration and CCS. - Alignment with Funding Policies: Public support for CCUS on incinerators should be consistent with other funding policies and initiatives. In 2017, the EU communicated its stance on waste-to-energy in the circular economy, recommending a phased-out approach to EU funding for waste incineration projects. Since then, there have been significant changes in the EU's policy towards waste incinerators. Notably, the Regional Fund, Cohesion Fund, and Just Transition Fund have excluded funding for incinerators. Furthermore, incinerators were omitted from the EU's Sustainable Finance Taxonomy, a landmark proposal to finance Environmental, Social, and Governance (ESG) projects. It is worth noting that the EU has already recognized investment in waste incineration as non-compliant with the RRF (Recovery and Resilience Facility) in its technical guidance on "Do No Significant Harm." Considering the above factors, we strongly urge the European Commission to refrain from financing CCUS projects on non-hazardous waste incinerators. Relevant Links: - CCS for incinerators? An expensive distraction to a circular economy: https://zerowasteeurope.eu/library/ccs-for-incinerators-an-expensive-distraction-to-a-circular-economy/ - Carbon capture from biomass and waste incineration: Hype versus reality: https://www.biofuelwatch.org.uk/2022/biomass-and-msw-ccs-report/
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Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur)

3 Jul 2023 · Packaging Waste

Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau and

21 Jun 2023 · Stakeholder meeting on WFD revision

Meeting with Malte Gallée (Member of the European Parliament, Shadow rapporteur for opinion) and Deutsche Umwelthilfe e.V. and

8 Jun 2023 · Definitions, quotas, system requirements – How reuse measures need to be designed within the PPWR?

Zero Waste Europe Urges Strict Recycled Plastic Reporting Rules

30 May 2023
Topic — The initiative establishes rules for calculating and reporting recycled plastic content in beverage bottles.
Message — The organization requests that recycling process losses be excluded from recycled content calculations. They also advocate for mandatory third-party certification and prioritizing models that ensure the highest traceability.12
Why — This would prevent misleading claims and ensure a level playing field for high-quality recycling.3
Impact — Chemical recycling firms using pyrolysis would lose the ability to count process losses.4
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Meeting with João Pimenta Lopes (Member of the European Parliament, Shadow rapporteur)

5 May 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 Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau

2 May 2023 · Circular economy and plastics, in particular proposal for the Packaging and packaging Waste Regulation

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

28 Apr 2023 · Packaging Waste

Zero Waste Europe urges inclusion of textiles in green taxonomy

20 Apr 2023
Topic — The EU initiative establishes investment classifications for circular economy and environmental sustainability.
Message — The organization supports excluding waste incineration but wants the taxonomy to cover textile and food manufacturing. They advocate for door-to-door collection and prioritizing mechanical recycling over higher-emission chemical processes.12
Why — A broader taxonomy directs green finance toward the mechanical recycling and sorting methods they favor.3
Impact — Chemical recycling and incineration businesses lose out on green investment opportunities.4
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

11 Apr 2023

Please find Zero Waste Europe's feedback in the attached document.
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Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

29 Mar 2023 · Packaging Waste

Meeting with Pär Holmgren (Member of the European Parliament)

29 Mar 2023 · Textile Strategy (staff level)

Meeting with Martin Hojsík (Member of the European Parliament)

21 Mar 2023 · Mixed waste sorting, circular economcy

Meeting with Frédérique Ries (Member of the European Parliament, Rapporteur)

9 Feb 2023 · PPWR

Meeting with Martin Hojsík (Member of the European Parliament) and Dow Europe GmbH and

7 Feb 2023 · Chemical recycling

Meeting with Delara Burkhardt (Member of the European Parliament, Shadow rapporteur) and European Environmental Bureau

3 Feb 2023 · packaging waste

Zero Waste Europe backs new chemical hazard categories

18 Oct 2022
Topic — The European Commission is adding new hazard classes to chemical classification rules.
Message — Zero Waste Europe supports adding hazard classes for hormone disruptors and persistent chemicals. They want these classifications to automatically trigger bans on using such chemicals in consumer products.12
Why — Stronger chemical regulations help the group achieve its vision for a toxic-free environment.3
Impact — Chemical manufacturers face market bans for products containing newly classified hazardous substances.4
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Meeting with Frédérique Ries (Member of the European Parliament)

12 Oct 2022 · Remise de pétition contre la pollution plastique au Commissaire Timmermans

Zero Waste Europe Urges Stricter Enforcement of Waste Targets

28 Jul 2022
Topic — The Commission assesses Member States' performance regarding 2025 recycling goals and 2035 landfill targets.
Message — The organization calls for stricter infringement procedures and decisive legal action against countries failing to meet recycling targets. They also advocate for a holistic European waste prevention plan to address insufficient infrastructure investment.123
Why — Stricter rules would help propagate their zero-waste city model across Europe by reducing incineration.4
Impact — The incineration industry and underperforming national governments face legal pressure and lost investment incentives.56
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Zero Waste Europe urges REPowerEU to fund biogas, not incineration

14 Jul 2022
Topic — A consultation on the REPowerEU plan to accelerate the European energy transition.
Message — The organization calls for REPowerEU to support biogas production from separately collected biowaste. It also demands that the initiative explicitly exclude funding for waste-to-energy incineration.12
Why — This would secure significant EU investment for circular economy projects and biogas infrastructure.34
Impact — Waste incineration plants would face exclusion from funding and renewable energy support schemes.56
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Zero Waste Europe demands stricter carbon accounting for recycled fuels

17 Jun 2022
Topic — New rules defining the methodology for calculating greenhouse gas savings from recycled fuels.
Message — ZWE requests removing "avoided emissions" from the methodology for assessing recycled carbon fuels. They argue these practices artificially reshape the real carbon footprint of plastic fuels. They also recommend using actual greenhouse gas intensity for electricity instead of national averages.123
Why — This ensures only fuels with true potential for emission reductions meet the legal requirements.4
Impact — Companies making fuels from plastic waste would lose their competitive advantage from lenient accounting.5
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Meeting with Peter Liese (Member of the European Parliament, Rapporteur) and BUSINESSEUROPE and

23 May 2022 · ETS

Meeting with Sara Matthieu (Member of the European Parliament, Shadow rapporteur) and Human Rights Watch and

12 May 2022 · Waste Shipment Regulation

Meeting with Deirdre Clune (Member of the European Parliament)

3 Mar 2022 · Persistant Organic Pollutants (POPs)

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

22 Feb 2022

The Rethink Plastic alliance welcomes the initiative of the Commission to revise the Waste Framework Directive and the opportunity to provide feedback. The alliance supports the adoption of regulatory measures to reduce waste in absolute terms, and fully apply both the waste hierarchy and the polluter pays principle. While the WFD has led to progress, additional and revised measures are needed to achieve a non-toxic circular economy across Europe. Rethink Plastic notably recommends the EU to : -Set waste prevention targets, including a general target and targets for key sector/products categories -Accompany waste prevention targets with material footprint targets at the same EU and sectoral level -Adopt measures that operationalise the waste hierarchy in a way that really prioritises reduction, reuse and at last resort, recycling : the focus should be on prevention of waste generation rather than on the (best) management of waste -Set reuse targets for products beyond packaging and harmonise the reporting methodologies for reuse, accordingly. -Adopt measures to support the developments of take-back systems, for reuse and repair, including an obligation for all retailers to accept take-back of any product they sell and for online retailers to finance local take-back infrastructures -Set further measures to ensure the non-toxicity of products; all products should be reusable and recyclable and safe for use, reuse and recycling -Strengthen the EPR requirements so as to support product redesign, waste prevention and reuse (e.g. through earmarking of revenues and eco-modulation of fees) -Adopt dedicated measures to tackle waste linked to online sales, including ensuring EPR also applies to e-commerce and establishing an EU 1% levy on all online advertising and trackers for high impact sectors to fund waste prevention measures. - Set a residual waste generation cap, in kg per capita to ensure overall reduction of residual waste produced and take into account low-waste generation countries. We recommend the following targets : 120kgs/cap/year by 2030 and 100kgs/cap/year by 2035. - Ban the destruction of unsold or returned goods - Set harmonised definitions for chemical reprocessing technologies to address the current lack of definition of “chemical recycling” (also often referred to as “feedstock recycling”, or misleadingly as “enhanced recycling”). The revised WFD should also clearly distinguish between recycling operations and recovery techniques. Only processes that yield outputs that are or can be directly converted into polymer materials should be categorised as “recycling”. This means that ‘feedstock recycling’ technologies should be categorised as ‘recovery’ as their outputs cannot be directly converted into plastics but need to be further processed in several steps to yield a polymer again. In addition, chemical recycling should be placed below mechanical recycling in the waste hierarchy. - Revise the Annex II so that municipal waste incineration can no longer be classified as ‘recovery’ (but is always categorised as disposal) - Set a target to strictly limit waste incineration in addition to the landfilling minimisation target, and revise the 10% Landfill target to put emphasis on waste reduction and avoid lock-in in waste incineration (see here: https://zerowasteeurope.eu/wp-content/uploads/2021/10/Rethinking-the-Landfill-Target_OCT2021.pdf). - Mandate mixed waste sorting system of a defined quality at the front of all new incineration plants and landfills, and those which have been operational for less than ten years. Material recovery processes that use mixed waste as a feedstock not only increase the availability of secondary raw material, they also minimise the amount of recyclable material that is incinerated or landfilled, so reducing GHG and making a substantial contribution to the CE objective (https://www.eunomia.co.uk/reports-tools/waste-in-the-net-zero-century-greenhouse-gas-impacts-of-mixed-waste-sorting/).
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Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and European Environmental Bureau and ClientEarth AISBL

9 Feb 2022 · Circular economy and non-toxic plastics

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and European Environmental Bureau and ClientEarth AISBL

9 Feb 2022 · Circular economy and non-toxic plastics

Meeting with Frans Timmermans (Executive Vice-President) and R CUBE NORD

2 Feb 2022 · Delivering on circular economy and moving to reuse solutions

Meeting with Virginijus Sinkevičius (Commissioner) and

26 Jan 2022 · To discuss opportunities for a swift and effective transition to reuse and practical steps to achieve it, as well as EU initiatives on packaging and sustainable products.

Meeting with Ville Niinistö (Member of the European Parliament, Shadow rapporteur)

20 Jan 2022 · RED waste

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

We thank the Commission for the opportunity to provide comments on this draft Regulation. Most plastic food contact materials (FCMs) on the market today (with or without recycled content) can contain several known hazardous chemicals which are authorized by the EU, as well as many chemicals that are unknown, and EU citizens are exposed to these chemicals when they migrate from FCMs into food. Evidence shows that recycled plastics frequently contain higher levels of hazardous chemicals compared to virgin plastics. The most efficient way to improve chemical safety of recycled food packaging is to eliminate hazardous substances in all materials and articles that enter the recycling stream. The main focus of this new draft regulation on recycled plastic for FCMs is on decontamination efficiency of the recycling processes. However, in order for such efficiency to be well assessed, and most importantly to ensure that no harmful chemicals are present in FCMs, not only the technology should be thoroughly characterized, but also the materials used, their properties, contaminants and their sources. Neither the (currently under review) EU legal framework for food contact materials nor the current draft regulation, satisfactorily ensure that all of these conditions are met. While the EU has clearly promised to eliminate in the near future hazardous chemicals legally used in plastic packaging today, this draft new regulation supports rather maintenance of status quo. It brings a risk that technologies, being developed before the anticipated changes in the FCM Framework Regulation are introduced, will not be delivering decontamination expected according to the revised regulation. Moreover, is it not clear how coherent provisions of this draft new regulation will be with a revised in the near future waste legislation. In particular, Packaging &Packaging Waste Directive still has to provide definition of ‘recyclable packaging’, essential criteria for ‘recyclability’ and ‘recycled content’, which seem to be relevant also for recycled plastic for / in food packaging. The most worrying feature of this draft new regulation is that recycled plastic materials and articles produced using novel technologies, would be allowed to be placed on the EU market, prior to any assessment of their efficiency and safety. While the arguments presented can be appreciated to collect data and reduce uncertainty in order to draw conclusions on performance of these individual recycling processes, they still do not justify the potential risk that the scaled-up use of technologies (not yet proven to be suitable) may pose to public health. It is not clear how placing on the market of plastic materials and articles with recycled/secondary plastic content intended for use in contact with food will be controlled when a recycler / developer is located outside the EU. In addition, the draft new regulation does not provide enough specifications regarding “a large and representative number of samples” to be gathered by developers (when such number is large enough to minimise the uncertainty as to the characterisation of the plastic input and of recycled plastic materials and articles?); neither are rules regarding the initiation of the safety and suitability assessment clear enough. A recommended ”level of flexibility” regarding the start and the scope of the assessment of a novel technology can rather delay such an initiation, not accelerate it. The suggested time for the assessment /authorisation of a new technology (up to a maximum of 7 years) should be shortened. Finally, it is not clear what the “evidence or indications showing that recycled plastic materials and articles recycled with a suitable recycling technology or with a novel technology may endanger the health of consumers” could exactly be, and how it will be collected and monitored during enforcement of this regulation. Attached please find a document with more detailed comments.
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Response to Measures to reduce microplastic pollution

17 Jan 2022

The Rethink Plastic alliance welcomes the European Commission’s initiative on microplastics unintentionally released into the environment as microplastics pollution is a widespread issue requiring urgent action. Please find attached our comments and recommendations.
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Meeting with Ralf Kuhne (Cabinet of Commissioner Stella Kyriakides) and European Environmental Bureau and ClientEarth AISBL

10 Dec 2021 · VTC meeting on Circular economy and non-toxic plastics

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

2 Dec 2021 · Circular economy and promotion of reuse

Response to Food waste reduction targets

29 Oct 2021

See document attached.
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Response to Policy framework on biobased, biodegradable and compostable plastics

27 Oct 2021

The Rethink Plastic alliance welcomes the precautionary approach proposed by this new roadmap, and fully supports its view of the problem and basis for the EU to intervene. There is sufficient scientific evidence to suggest that there are significant risks in the current debate on transitioning towards a bioeconomy, in particular if simple substitution is applied that maintains a linear economy. Policy is necessary to guide a reasoned shift towards sustainable material sourcing, resource-efficient consumption patterns and ensure the transition to circularity and material prevention are prioritised. We would like to make the following general comments and more information on our recommendations is attached. - First off, we welcome a clear-cut distinction of bio-based, biodegradable and compostable plastics. The generic, encompassing term “bioplastics” that was commonly used thus far, triggered confusion and does not allow a specific, targeted assessment of two issues that are markedly different (sourcing, on the one hand, and end-of-life behaviour, on the other). We warmly recommend keeping two separate agendas from now on on these two issues. - Bio-based plastics (BBP) cover a broad range of materials and feedstocks, with wide variations in terms of their environmental impacts. They include some potentially innovative and promising processes from an economic and environmental standpoint, for example in the case of BBPs made from biogenic waste. However, the vast majority of BBPs today are produced from virgin raw materials, increasing pressures on land particularly where their production is supported by intensive and fossil-fuelled agriculture, and may not by default perform any better than their fossil-based counterpart from an environmental and circularity perspective. What is more, products claiming to contain BBP can also be mixed with fossil-based plastics, sometimes present in greater shares. -As noted in the roadmap, there exist no EU sustainability criteria for bio-based plastics. Such criteria are also completely absent from standards on bio-based content, which consequently fail to give any qualitative assessment on the raw materials used in the product. In spite of this shortcoming, bio-based content continues to be used as marketing to signify environmental added-value of bio-based plastics. -BBPs cannot be considered as inherently circular and sustainable, and therefore should not be used as a substitute for fossil-based plastics in common single-use applications. The plastic pollution crisis must be solved via an absolute reduction in the global production of plastics, as well as waste prevention, particularly from single-use plastics. BBPs can only contribute to these objectives if they are designed to be circular (long-lasting, reusable and fully recyclable), therefore going beyond sustainable sourcing. -Biodegradable and compostable plastics (BDCP), as other conventional plastics, are often fossil-based and mostly rely on virgin materials, are non-reusable, short-lived and usually not mechanically recycled. As such, they should not be considered a desirable alternative to so-called conventional single-use plastics. Biodegradable and compostable plastics perpetuate a linear model where items are used once and with a short lifetime before being disposed of, contributing to the loss of valuable resources and to externalities associated with their production and end-of-life. -Most often, due to consumer and/or waste operators’ misunderstanding fostered by inadequate or partial information, compostable items and packaging are not composted but end up in incineration or landfills, or risk polluting the marine environment as they are disposed of incorrectly. This is sometimes due to vague terminology and specific expertise needed, to the absence of the right infrastructure or infrastructures refusing BDCP because they are not actually compostable under the conditions of some composting facilities.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

18 Jul 2021

ZWE welcomes the EC proposal for the Renewable Energy Directive (RED) reform. In order to ensure that the RED only supports energy from biogenic wastes, it should only allow energy from separately collected biowaste or biogenic waste that is segregated from fossil waste in case of mixed waste. It should not consider the use of mixed waste for energy as renewable as the evidence shows that this contributes indirectly to the burning of fossil fractions of wastes. As for support schemes for the energy from waste then the REDII should align the support schemes with separate collection requirements., meaning it should only support energy from separately collected biowaste. It should phase out any support for the use of non separately collected wastes as they would undermine the separate collection obligations mandated by the Waste Framework Directive. The evidence shows that much of mixed waste is recyclable. For example, a new global research "Waste in the Net-Zero Century: How Better Waste Management Practices Can Contribute to Reducing Global Carbon Emissions" states that residual waste (incinerators input) sorting will always be necessary to meet the climate mitigation demands. It estimated that mixed waste sorting especially could save 0,73 billion tonnes of CO2 per year globally. https://www.eunomia.co.uk/reports-tools/waste-in-the-net-zero-century-how-better-waste-management-practices-can-contribute-to-reducing-global-carbon-emissions/
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Zero Waste Europe urges including waste incinerators in ETS

17 Jul 2021
Topic — The Commission is reviewing the Emissions Trading System to meet higher climate targets.
Message — The organization recommends including municipal solid waste incinerators in the scope of the Directive. They also urge ending free emission allowances for all sectors by 2023.12
Why — Higher carbon costs would stimulate investment in the recycling sectors the organization represents.3
Impact — Waste incinerators would lose their competitive advantage and face potential facility closures.4
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Response to Calculation, verification and reporting of data on the separate collection of SUP beverage bottles

17 Jun 2021

The Rethink Plastic alliance welcomes the opportunity to provide feedback on the draft implementing act. The alliance would like to highlight that it is critical that the definition of "separate collection" is in line with the Waste Framework Directive and that the implementing act clearly states that waste splitting/post-sorting of bottles after residual waste mixed collection is not separate collection. The implementing act should leave no room for interpretation on that. If single-use plastic bottles are collected together with other recyclables (while separate collection through DRS remains the preferred option), strict requirements need to be in place to ensure the quality of the material and prevent contamination, so that closed-loop bottle-to-bottle recycling is possible and effective. SUP bottles should be collected in a way that allows recycling into foodgrade material. In addition, these requirements should be enforced and controlled by a public authority or an independent body. Finally, the calculation methodology should take into account/be based on units and not only weight.
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and Union of European Beverages Association

8 Jun 2021 · Circular economy, waste management and deposit return schemes

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and Union of European Beverages Association and

8 Jun 2021 · Circular economy, waste management and deposit return schemes

Meeting with Joan Canton (Cabinet of Commissioner Thierry Breton) and Union of European Beverages Association and

8 Jun 2021 · Circular economy, waste management and deposit return schemes

Response to Commission Delegated Regulation on taxonomy-alignment of undertakings reporting non-financial information

2 Jun 2021

The Rethink Plastic alliance welcome the European Commission's draft delegated act and the opportunity to provide feedback. The alliance would like to highlight the following points: - It is critical that the “Do No Significant Harm” criteria is included across all templates for all stakeholders. - SMEs should be able to claim taxonomy alignment much earlier than 2025. SMEs represent roughly 70% of the economy, and it is important for them to have access to green finance earlier than 2025, even more so considering that their potential competitors can as early as 2022. This would not mean that they have to report, only that they can report. - At the moment the reporting is to be made in relative terms (%) rather than in absolute terms (€) and the CapEx and OpEx figures are meant to be aggregated into one percentage. Having disclosure in absolute amounts would be desirable, at the very least for transparency purposes and better understanding of the information reported. This would allow to make visible potential important gaps between investments in taxonomy aligned activities and operations expenses in taxonomy non-aligned activities (especially depending on the aggregation method used).
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Meeting with Rozalina Petrova (Cabinet of Commissioner Virginijus Sinkevičius) and ClientEarth AISBL

23 Feb 2021 · Implementation of the EU Plastics Strategy and single use plastics

Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and ClientEarth AISBL

23 Feb 2021 · Implementation of the EU Plastics Strategy and single use plastics

Response to Revision of EU rules on food contact materials

29 Jan 2021

Zero Waste Europe welcomes the Roadmap on the revision of EU rules on Food Contact Materials and the opportunity to provide feedback. Please find Zero Waste Europe's comments attached.
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Response to Proposal for a legislative act on methane leakage in the energy sector

26 Jan 2021

The Rethink Plastic alliance welcomes the decision of the European Commission to introduce a legislative act to reduce methane emissions in the energy sector, and would like to highlight the need to ensure a comprehensive approach toward addressing methane emission across the supply chain, including in the energy-intensive petrochemical sector. Detailed feedback on the inception Impact Assessment (IIA) can be found in the attached submission.
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Response to Revision of EU Ambient Air Quality legislation

12 Jan 2021

ZWE welcomes the Commission proposal to review the Ambient Air Quality Directives. End of life treatment of waste such as waste incineration release pollutants to ambient air. These pollutants, at certain concentrations, lead to health and environmental issues, as the World Health Organization has acknowledged. Our main source of concern is on the quantitative limit values set by the AQD as compared to the air quality guidelines (AQG) of the World Health Organization on air quality since these guidelines point to lower values than those required by the AQD for several pollutants. More specifically: - The AQG for the annual average concentration of PM10 (20 μg/m3) is half of the concentration required by the AQD (40 μg/m3). The current EU level corresponds to the medium point between the so-called Interim target-2 and target-3 of the WHO. This concentration is associated to a risk of increasing cardiopulmonary and lung cancer mortality. - In the case of PM2.5 the EU annual average limit (25 μg/m3) more than doubles the AQG (10 μg/m3) At the AQD limit value, the WHO states a risk of premature mortality of between 4 and 13%. Recent research indicates that over 90% of the emitted particles are ultrafine particles (ufps). More info on particulate emissions from incinerators can be found here https://ukwin.org.uk/files/particulates/PRG-Particulates-Matter-December-2019.pdf - For SO2, the WHO states “a prudent precautionary approach to a value of 20 ng/m3” for the daily average whereas the EU limit values is set in 125 μg/m3 not to be surpassed more than 3 times in a calendar year. No further indications are given regarding daily averages. Furthermore, the WHO stressed the relevance of shorter exposures (10 minutes) for which no limits are set by the EU. - Ozone concentrations (measured as 8-hour mean concentration) as stated by the AQG should be below 100 μg/m3. The EU standards sets a limit value of 120 μg/m3 during 25 days averaged over three years. Regarding other relevant pollutants such as arsenic, nickel and polycyclic aromatic hydrocarbons, the limit value set by the EU Directives cannot be compared to the AQG value provided by the WHO. In these cases, the risk of exposure to these pollutants is measured as probability of diminished life expectancy. Apart from differences between the AQG and the EU standards, and the lack of reference values in the Directive for some pollutants, the AQD, Annex I, sets the data quality standards for air quality measurements. These quality standards assume an additional range of acceptable uncertainty in the measurements, which in practice might allow higher actual concentrations to occur. The AQD assumes several deviations from the AQG, which in turn implies assuming a certain degree of health risk (e.g. measured as the probability of premature death). Being public health at stake, it would be advisable that they are reviewed in the light of WHO recommendations. furthermore, they should be put in the context of the current local air quality status and available alternatives, in a proper application of the Precautionary Principle. Overall, the current limit values operate between risk and uncertainty for human health and the environment (e.g. immission levels and health risk). In this context, there is a need to consider non-combustion alternatives for both non-hazardous and hazardous waste management. For non-hazardous waste treatment, we recommend Material Recovery and Biological Treatment sites. See for example, https://zerowasteeurope.eu/wp-content/uploads/2020/06/zero_waste_europe_policy_briefing_MRBT_en.pdf For hazardous waste treatment, we recommend technologies listed in the General technical guidelines for the environmentally sound management of wastes consisting of, containing or contaminated with persistent organic pollutants (POPs). Some of those incineration alternatives are highly commercialised. http://www.basel.int/Implementation/POPsWaste
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Response to Climate change mitigation and adaptation taxonomy

14 Dec 2020

Zero Waste Europe welcomes the opportunity to give input to the Delegated Act of the EU Taxonomy on sustainable finance. Please see attached our report 'Sustainable Finance for a Zero Waste Circular Economy' with the following highlights and recommendations to the European Sustainable Finance Platform: Highlights: - The report highlights the importance of Sustainable Finance for a Zero Waste Circular Economy in the post-COVID-19 recovery. - It provides clear criteria on the activities that need to be included, considered eligible, and prioritised in the EU Sustainable Finance Taxonomy under the umbrella of a Zero Waste Circular Economy by looking at the social, economic, climate, and environmental benefits. - It also analyses the proposed role of Waste-to-Energy incineration and other false solutions – such as plastic to fuels and incineration of Refuse-Derived Fuel in cement plants – in the circular economy; and exposes the highly counterproductive effects of this technology on the aims and objectives of sustainable finance, therefore reiterating its exclusion. Recommendations : - Prioritise investment in zero waste businesses and public initiatives that set up systems for waste prevention, reuse, recycling and composting activities. The support to the upper tiers of the waste hierarchy - instead of supporting downstream technologies - is a critical step to build a truly climate-neutral and sustainable circular economy and one that remains critically underfunded. New initiatives in the waste prevention and reuse sector are already delivering groundbreaking results, but will need significant levels of investment to be scaled up and reproduced as needed. Ensuring that these solutions receive the support they deserve can be a game-changer across the sustainable finance world. - Maintain the exclusion of Waste-to-Energy incineration from the Taxonomy and expand it to other forms of incineration in disguise such as incineration of Refuse-Derived-Fuel in cement kilns and plastic-to-fuel. These technologies pose several environmental, economic and social challenges; namely their contribution to climate change, air pollution, and resource exploitation will exacerbate the ecological crisis that has created the conditions for a pandemic to take place in the first place. In economic terms, these technologies generate few jobs and lock cities into an ever increasing spiral of debt (in the case of Waste-to-Energy incineration), syphoning the budgets that are needed now more than ever to build the recovery and resilience agenda. - Establish the EU Taxonomy Regulation for mandatory compliance for all European aid agencies acting at the EU and international level to avoid double standards and ensure that the zero waste circular economy principles are supported, not jeopardised, globally. While the EU is showing positive leadership at the regional level, it is yet to be seen how this positive trend can benefit other regions in the world. The credentials and reputational capital of European sustainable finance will be at risk if double standards are not prevented and avoided. The field of sustainable finance has an opportunity to demonstrate that double standards are not acceptable and that the EU can walk the talk at international level in the same way that it does at home. Ultimately, the EU can play a visionary role in leading the sustainable finance agenda at the international level and encourage other International Financial Institutions and aid agencies to meet Zero Waste Circular Economy standards as a further contribution to this mission.
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Response to Revision of the Energy and Environmental Aid Guidelines (EEAG)

6 Dec 2020

The state aid should be reviewed to ensure the application of article 3 (3) which requires that Member States shall grant no support for renewable energy produced from the incineration of waste if the separate collection obligations laid down in the Waste Framework Directive have not been complied with. To ensure compliance with Art 3(3) of the REDII, the Commission would first need to establish whether the separate collection requirements under Art 11 and 22 of the Waste Framework Directive have been effectively put in place within national legislation and if so, they should consider whether the targets for preparation for reuse and recycling of municipal waste have been achieved. If it is determined that these requirements are not met it becomes necessary to terminate any support scheme for the incineration of waste given the REDII requirement. Currently, no EU Member state meets the 2035 target, and several are lagging behind on the target for 2020 as laid out under Article 11(2). Given that no Member State can prove compliance with Article 11(2) until 2020 where their ability to meet the targets will be examined, - it can therefore be assumed that the above-specified requirements are not met. This suggests that support schemes for the incineration of waste should be cancelled before January 2021 when REDII enters into force, across all EU member states in order to comply with legislation. See the full input attached.
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Zero Waste Europe urges including incineration in EU emissions trading

26 Nov 2020
Topic — The European Commission is reviewing the Emissions Trading System to meet climate goals.
Message — Mandate full auctioning of allowances and include waste incineration in the ETS. Higher reduction factors and strengthened reserves must target zero emissions by 2040. Ensure all auctioning revenues are earmarked for climate and energy purposes.123
Why — This makes burning waste more expensive, promoting material recovery and biological treatment.4
Impact — Waste incineration companies and industrial polluters will face significantly higher compliance costs.5
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans) and ClientEarth AISBL

17 Nov 2020 · circular plastics economy and single-use plastics

Response to Sustainable Products Initiative

16 Nov 2020

The Rethink Plastic alliance welcomes the launch of the Sustainable Products Initiative (SPI) and its overarching objective to make sustainable products and services the norm. In order to achieve its overarching objective and meet the seriousness of current environmental challenges, the proposed product policy framework must be applied across all sectors of the economy in an integrated manner. A set of horizontal requirements should be applied across the board for all products and services on the European market, including : · Minimum information requirements and transparency on key aspects such as bill of materials and full listing of chemical substances, circularity (durability, repairability, reuse and recycling), environmental footprint, and due diligence via the digital product passports initiative; · Monitoring and dedicated targets for absolute reductions in material footprint and consumption footprint; · Toxic-free design of products put on the European market; · Mandatory Extended Producer Responsibility (EPR) requirements for all products and services on the market; · Introduction of generic principles for all products and services, for example as part of a circular economy hierarchy where value retention is prioritised above all. The attached Rethink Plastic position outlines how these principles can be translated to plastics as a material. However, given that plastics have a wide range of possible applications, complementary, sector specific measures should be introduced including: · Credible market based instruments to improve the economic viability of waste prevention; · Ambitious minimum public and private procurement criteria; · Bans and restrictions, for example on single use items in the food services sector or single-serve toiletry items in the hospitality sector · Market restrictions for certain types of packaging; · Mandatory design requirements to phase out plastic materials which degrade into microplastics; and · A legislative framework which effectively tackles misleading advertisements and marketing, as well as greenwashing.
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Response to Revision of the Renewable Energy Directive (EU) 2018/2001

21 Sept 2020

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society and to empower communities to redesign their relationship with resources and to adopt smarter lifestyles and sustainable consumption patterns in line with a circular economy. We welcome the roadmap consultation envisioning the review of the renewable energy directive (REDII) in the light of the European Green Deal. In the upcoming review, ZWE recommends aligning the planned measures with the goals of the Circular Economy Action Plan 2.0, specifically, to: 1. Phase out all renewable energy support schemes for energy recovery from mixed waste in line with point 8 of Annex IVa of Waste Frame Directive (WFD). The separate collection and anaerobic digestion of biowaste is considered ‘recycling’ under the EU waste policy which is higher up in the waste hierarchy in comparison with the energy recovery from mixed waste which is considered as ‘recovery’. The revised WFD requires to collect biowaste separately, latest by Jan 2024. In line with the point 8 of Annex IVa of WFD, Member States should "phase out subsidies which are not consistent with the waste hierarchy" which in this case refers to support schemes that aim to recover energy from mixed wastes. See our briefing: https://zerowasteeurope.eu/wp-content/uploads/2019/10/zero_waste_europe_policy-briefing_REDII_en.pdf 2. Phase out all subsidies that could lead to distortive effects on raw material markets. The updated REDII should ensure that national policies and support schemes promoting bioenergy avoid distortive effects on the raw material markets and respect the waste hierarchy. Member States have to ensure that the production of energy from biomass is not promoted at the expense of uses higher up in the waste hierarchy that has higher GHG savings. See our briefing: - https://zerowasteeurope.eu/wp-content/uploads/2019/06/zero_waste_europe_guidelines-for-the-implementation-of-article-33-of-REDII_en.pdf 3. Exclude waste-based fossil fuels (RCF - Recycled Carbon Fuels) from the scope of the REDII as RCF are not compatible with established EU GHG emissions targets, and potentially undermine the higher tiers of the waste hierarchy by discouraging ‘reduce and reuse’ behaviour. The life cycle of 'recycled carbon fuels' incurs tremendous additional energy expenditure above and beyond baseline scenarios of direct combustion, even with energy recovery, which does not fit with the absolute EU target of attaining carbon neutrality by 2050 and limiting global warming to 1.5 degrees as recommended by the IPCC. See our briefings on RCFs: - https://rethinkplasticalliance.eu/wp-content/uploads/2020/06/rpa_recycled_carbon_fuels_in_the_renewable_energy_directive.pdf - https://zerowasteeurope.eu/wp-content/uploads/2020/07/2020_07_zero_waste_europe_policy_briefing_recycled_carbon_fuels_en.pdf LCA guidance : - https://rethinkplasticalliance.eu/wp-content/uploads/2020/01/rpa_bellona_zwe_counting_carbon.pdf Moreover, the production of RCF could undermine the Commission efforts to halve residual waste by half by 2030 and to make all plastic packaging either reusable or recyclable by 2030.
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Meeting with Helena Braun (Cabinet of Executive Vice-President Frans Timmermans)

26 Aug 2020 · Circular economy, reuse and single-use plastics

Response to Update of concentration limit values of persistent organic pollutants in waste

7 Aug 2020

Please find attach the Rethink Plastic alliance feedback on the Inception Impact Assessment on updated concentration limits for chemical pollutants.
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Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

4 Aug 2020

The Rethink Plastic alliance welcomes the review of the requirements for packaging and measures to prevent packaging waste. Our main comments on the inception document are attached.
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Response to EU Methane Strategy

24 Jul 2020

Zero Waste Europe would like to thank the Commission for the opportunity to comment on the EU methane strategy roadmap. We strongly recommend aligning measures in the waste sector with the requirement for separate collection of biowastes in the EU, mandatory latest by Jan 2024. There is a huge potential for diverting biowaste from landfills or incinerators through separate collection systems. We particularly recommend the use of door-to-door collection systems, which have the best caption rates and the lowest impurities. For best practices see our recent study "Bio-waste generation in the EU: Current capture levels and future potential: - https://zerowasteeurope.eu/wp-content/uploads/2020/07/2020_07_06_bic_zwe_report_bio_waste.pdf The captures biowaste could be used for the development of biogas. For the organic waste still found in the residual waste stream, the best environmental option is to treat it in the Material Recovery and Biological Treatment (MRBT) site. The biological stabilisation in MRBT sites could be linked to the development of biogas, so as to improve the energy balance and retain biogenic carbon, in the form of methane, in order to use it as a renewable replacement for fossil fuels. See our recent report on MRBT sites "Building a bridge strategy for residual waste" - ttps://zerowasteeurope.eu/wp-content/uploads/2020/06/zero_waste_europe_policy_briefing_MRBT_en.pdf Treating the residual organics in MRBT sites would prevent further release of CO2 emissions from inceration of waste in incinerators. The climate benefits of MRBT are detailed here: http://www.ecocycle.org/files/pdfs/best_disposal_option_for_leftovers_on_the_way_to_Zero_Waste.pdf
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Response to Chemicals strategy for sustainability

19 Jun 2020

Please find attached Zero Waste Europe's feedback.
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Meeting with Frans Timmermans (Executive Vice-President) and European Environmental Bureau and

16 Jun 2020 · European Green Deal, new circular economy action plan and the circular plastics economy

Response to Strategy for smart sector integration

15 May 2020

Zero Waste Europe welcomes this opportunity to provide feedback on the roadmap on “An EU Smart Sector Integration Strategy’. To ensure policy coherence with circular economy policies we attach our comments and suggestions. Also summarised below: We recommend to prevent further lock-in to energy generation based on Waste-to-Energy (WtE). Further integration of WtE, for example, via district heating networks would simply perpetuate the lock-in effect of incineration for decades. Integrating WtE with district heating networks makes the lock-in even worse as its very difficult to switch the energy source of district heating. On the other hand, we recommend integrating systems based on biogas from separately collected biowaste (in line with article 22 of the Waste Framework Directive).
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Response to Union renewable Financing mechanism

9 May 2020

Zero Waste Europe welcomes the Commission implementing regulation on the Union renewable energy financing mechanism. We are , however, recommending the amend the wording on Art 2 (3) to ensure policy coherence with art 3 (3) of the recast Renewable Energy Directive as follows: Unless otherwise provided for in this Regulation, the mechanism shall allocate its resources to support renewable energy deployment across the Union in accordance with the rules set out in Art 3 (3) of Directive 2018/2001 and this Regulation without distinction between the two functions referred to in paragraph 2 of this Article. The provision in Art 3(3) requires Member States to terminate subsidies for bioenergy produced from the incineration of waste if the separate collection obligations laid out in Directive 2008/98/EC have not been complied with. See for details in the attached briefing.
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Response to EU rules on industrial emissions - revision

17 Apr 2020

ZWE recommends revising the IED to ensure that waste incineration and co-incineration plants respect the same total emissions levels. Current legislation sets higher emissions ceilings for cement plants co-incinerating waste than those for dedicated waste incinerators. This makes little sense from environmental protection and human health perspective, as the total impact of hazardous substances, odor, noise and dust emissions is not in any way mitigated by the pollution source. Allowing higher emissions for co-incineration puts local residents in those areas at a disadvantage when it comes to the protection of their health and environment. See, for example, case studies: 1. Lafarge-Trbovlje https://zerowasteeurope.eu/library/burning-waste-in-cement-kilns-the-case-of-lafarge-trbovlje/ 2. Calusco d’Adda https://zerowasteeurope.eu/library/burning-waste-in-cement-kilns-the-story-of-calusco-dadda/ 3. Salonit Anhovo https://ekokrog.org/wp-content/uploads/2019/07/Salonit-Anhovo-Primer-FNL.pdf We strongly recommend that plants co-incinerating over 25% of waste as fuel, should respect the same emission limits as incinerators. Germany has already reduced the permitted dust emission limit to 10 mg/Nm3, and NOx emission limit to 200 mg/Nm3. Both emission limits in Germany are therefore already the same as for dedicated waste incinerators. Germany shows that it is possible to respect the same emission value limits at least for the above-mentioned pollutants. https://www.globalcement.com/images/stories/documents/articles/eGC-Mar14-25web.pdf
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Response to FuelEU Maritime

9 Apr 2020

ZWE welcomes the FuelEU Maritime Initiative. In order to further develop the initiative we recommend the following: I. Policy Coherence: any potential support to waste-based fuels should be in line with other environmental and climate policies. This means: - It should avoid promoting subsidies that are inconsistent with the waste hierarchy (in line with point 8 of Annex IVa of Waste Framework Directive) or could distort raw material markets (in line with Article 3 (3) of the REDII). - It should align its actions with the EU Taxonomy for sustainable finance by only promoting biogas/biomethane from separately collected biowaste. II. Exclusion of waste-based fossil fuels: fuels derived from fossil waste will never be low-carbon and are therefore at odds with efforts to bring Europe’s carbon footprint to zero. To ensure that all of the emissions related to these fuels are taken into account, the GHG accounting must include all stages of the lifecycle of the product. This includes the emissions related to the energy inputs, to the production, and to the use or combustion of the fuel.
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Response to ReFuelEU Aviation - Sustainable Aviation Fuels

4 Apr 2020

The ReFuelEU Aviation initiative can only contribute to climate change mitigation in the aviation sector by aligning finances with actions that help move the EU towards the circular economy. I. Policy Coherence - Any potential support to waste-based fuels needs to be fully in line with other environmental and climate policies. This means: - It should avoid promoting subsidies which are not consistent with the waste hierarchy (i.e. undermine waste reduction or recycling by promoting the use of waste for fuels) in line with the point 8 of Annex IVa of Waste Framework Directive - It should also not provide renewable energy support to avoid raw market distortions and in case separate collection obligations are not met in line with Article 3 (3) of the REDII (1 & 2). - Align with the EU taxonomy for sustainable finance (3) by only promoting biogas from separately collected biowass. II. Support separate collection of bio-waste - The initiative should support the development of biomethane from separately collected biowaste. Across the European Union it’s estimated that about 96 million tonnes of municipal bio-waste is generated annually (4). Only about a third (47,5 million tonnes) of this was separately collected. This figure could double in the near future since Member States will have to implement bio-waste separate collection no later than by December 2023 (in line with Article 22 of the Waste Framework Directive). This means that there is a large potential for biogas generation from biowaste feedstock. Delft University, the assessment shows that biogas production in the EU could increase from the current level of 14.9 Mtoe towards 28.8 to 40.2 Mtoe in 2030 (5). By enriching the methane content of biogas it is possible to produce biomethane which is a low carbon renewable fuel used for electricity and heat production, or as a transport fuel (bio-CNG or bio-LNG). III. Exclusion waste based fossil fuels - the initiative should not promote the use of waste-based fossil fuels as the climate impact of these fuels is worse than that of conventional diesel, petrol or kerosene (6). In order to account for all emissions coming from waste-based fossil fuels, the LCA guidelines for the fuels should account for all direct and indirect emissions from cradle to grave (7). This includes the fossil carbon embedded in the inputs for the fuels. References: https://zerowasteeurope.eu/wp-content/uploads/2019/06/Guidelines-for-the-implementation-of-article-33-of-REDII.pdf https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/zero_waste_europe_policy-briefing_REDII_Ocotber2019..pdf https://ec.europa.eu/info/files/200309-sustainable-finance-teg-final-report-taxonomy_en https://www.compostnetwork.info/policy/biowaste-in-europe/ https://cedelft.eu/en/publications/download/2287 https://zerowasteeurope.eu/wp-content/uploads/2019/04/NGO-joint-briefing-RCF.pdf https://rethinkplasticalliance.eu/wp-content/uploads/2020/01/rpa_bellona_zwe_counting_carbon.pdf
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Response to Climate change mitigation and adaptation taxonomy

3 Apr 2020

Zero Waste Europe welcomes the EU Taxonomy for Sustainable Finance. To further improve the initiative we recommend to: 1. Introduce waste prevention and reuse activities under the waste part of the Taxonomy. We are concerned that the Taxonomy does not include waste prevention/reduction activities which have the highest GHG savings potential while they could use extensive investment. Waste prevention/reduction are at the top of the waste hierarchy (reducing the generation of waste, reuse systems, and organics infrastructure - compost and anaerobic digestion) and they provide the most significant climate benefits in the waste management sector (1). 2. The taxonomy should list waste incineration as a significant contributor to climate change. The CO2 emissions from the incineration of municipal solid waste (MSW) have grown by 288%, suggesting the CO2 emissions are intensifying (2). Since burning MSW results in much higher CO2 emissions than burning fossil fuel (3), continued use of incineration is simply delaying a much needed, and urgent, transition to less carbon-intensive power generation infrastructure such as wind and solar renewable energy (4). Promoting the use of waste for energy would make it impossible to facilitate ambitious emissions reduction in the energy sector that would align with the Paris Agreement and genuinely limit the global average temperature increase to below 1.5°C. References: 1. https://zerowasteeurope.eu/downloads/the-potential-contribution-of-waste-management-to-a-low-carbon-economy/ 2. https://www.eea.europa.eu/publications/european-union-greenhouse-gas-inventory-2019/european-union-greenhouse-gas-inventory-2019/viewfile#pdfjs.action=download 3. http://wedocs.unep.org/bitstream/handle/20.500.11822/28413/WTEfull.pdf?sequence=1&isAllowed=y 4. https://zerowasteeurope.eu/wp-content/uploads/edd/2019/09/ZWE_Policy-briefing_The-impact-of-Waste-to-Energy-incineration-on-Climate.pdf
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Response to Farm to Fork Strategy

19 Mar 2020

The Farm to Fork Strategy presents a great opportunity to profoundly reshape our relation to food and design food waste, hazardous chemicals and overpackaging out of our food system. Addressing such issues specifically requires a holistic vision leading to coordinated actions all along the food supply chain. Read Zero Waste Europe’s feedback here : https://zerowasteeurope.eu/wp-content/uploads/2020/03/zero_waste_europe_reaction_farmtoforkstrategy_en.pdf (and attached)
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Zero Waste Europe urges Modernisation Fund to exclude waste incineration

11 Mar 2020
Topic — Rules for the Modernisation Fund supporting energy system investments in certain EU Member States.
Message — Focus the fund on biogas and compost from separately collected biowaste. Exclude all funding for waste-to-energy incineration to prevent adverse climate impacts.12
Why — This shift would direct limited EU funds towards the organization's circular economy priorities.3
Impact — The waste incineration industry would lose financial support for its carbon-intensive energy infrastructure.45
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Response to Fast-track interservice consultation on the 'SEIP including a JTM and the JTF"

14 Feb 2020

Zero Waste Europe would like to highlight the importance of excluding waste (co)incineration from the scope of the fund. Burning waste in coal power plants is sometimes presented as an alternative to burning coal as well as a low-carbon source for the creation of energy. It is also justified as a way to give a new lease of life to old power stations. The evidence, however, suggests that energy from waste can result in greater CO2 emissions than electricity from gas or other fossil fuels (1). A recent report published by UKWIN confirms this. ‘Energy generated through waste incineration has twice the carbon intensity (i.e. CO2 emissions per unit of power) than the same energy produced by the conventional burning of fossil fuels in power stations’ (2). Further, still, waste incineration is a significant source of air pollutants including SO2, NO2, dioxins, and fine particulates. The latter includes nano-particulates which are of great concern because they can pass through the lung lining, causing internal inflammation and penetrating organs (3). This is particularly worrisome as the evidence shows increased heavy metal emissions when waste is used to substitute fossil fuels in co-incineration plants (4). It is clear, therefore, that switching from burning coal to burning waste is not a climate-friendly alternative to burning coal nor is it good for our health. The last Energy Transition Outlook has called for extraordinary action by part of policymakers (5). Promoting waste burning would make it impossible to facilitate ambitious emissions reduction in the energy sector that aligns with the Paris Agreement and genuinely seek to limit the global average temperature increase to below 1.5°C. Due to the progressive decarbonization of the electricity supply the electricity generated by burning waste will have an increasingly negative impact on climate change impacts in the future. Therefore, countries instead of switching from burning coal to burning waste should be looking to genuinely low carbon ways of generating energy, such as wind and solar. At the same time, we should be doing more to support the top tiers of the waste management hierarchy by reducing waste and by reusing – and by designing products to be reused. Moreover, these solutions – including waste reduction, redesign, composting, biogas, producer responsibility, consumption habits transformation, community empowerment, and recycling – could be implemented today, using existing innovations, with immediate results. Over 400 zero-waste municipalities across Europe show that a quick transition is possible when implementing the right set of policy measures (6). List of references: 1. The impact of waste to energy on climate. Available at: https://zerowasteeurope.eu/downloads/the-impact-of-waste-to-energy-incineration-on-climate/ 2. Evaluation of the climate change impacts of waste incineration in the United Kingdom. Available at: https://ukwin.org.uk/files/pdf/UKWIN-2018-Incineration-Climate-Change-Report.pdf 3. Why Oppose Incineration. Available at: https://ukwin.org.uk/oppose-incineration/#1 4. Perspectives and limits for cement kilns as a destination for RDF. Available at https://www.researchgate.net/publication/5603190_Perspectives_and_limits_for_cement_kilns_as_a_destination_for_RDF 5. Energy Transition Outlook 2019. Available at : https://eto.dnvgl.com/2019/index.html 6. Zero Waste Cities. Available at: https://zerowastecities.eu/
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Response to A new Circular Economy Action Plan

20 Jan 2020

Please, find Zero Waste Europe recommendations attached.
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Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans)

6 Nov 2019 · discussion on sustainability and plastics

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Greenpeace European Unit and

18 Oct 2018 · discussion on Plastics Strategy

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Friends of the Earth Europe and Seas At Risk vzw

5 Oct 2018 · discussion on the implementation of the Plastic Strategy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen)

19 Jul 2018 · misalignment between JASPERS-financed projects in some central/eastern Europe MS and COM policy orientations in the waste management

Response to Legislative proposals for ERDF/CF, ETC (Interreg) and ECBC

3 Jul 2018

Zero Waste Europe welcomes the Commission’s proposal to make Circular Economy (CE) one of the key policy objectives of the future Cohesion policy. However, the proposal contains few incoherencies as underlined below: 1) Firstly, although the CE now constitutes a key policy goal of the fund there are no specific intervention fields or related results and output indicators in the respective Annexes. The proposed intervention fields/indicators relate only to the waste management. Zero Waste Europe recommends to include specific intervention fields and related results and output indicators in the areas of 'production and consumption' and ' secondary raw materials' in line with the Commissions communication on a monitoring framework for the circular economy (COM(2018) 29 final). 2) Secondly, although the Commission’s proposal excludes investment to the residual waste facilities from the scope of the Cohesion policy (Article 6) the corresponding intervention fields and indicators include references to residual waste treatment facilities. Specifically, the intervention field 043 (household waste management: mechanical biological treatment, thermal treatment and output indicator RCR 49 (waste recovered) still refer to residual waste treatment facilities. Zero Waste Europe recommends removing the above mentioned codes to ensure the coherence in the overall aims and the related activities and indicators prevails. See the Annex attached for specific references.
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Response to Multiannual Financial Framework-Draft legislative proposal on the InvestEU Programme and EFSI evaluation SWD

2 Jul 2018

Zero Waste Europe welcomes the Commission’s proposal to make Circular Economy one of the priority areas of the future Cohesion Policy. Moreover, we welcome the decision to exclude funding for residual waste treatment facilities from the scope of EU funds. This will ensure that the the Cohesion policy post-2020 will be aligned with the EU’s Circular Economy package and the recommendations of Commission’s communication on role of waste-to-energy in the circular economy. However, there are few inconsistencies in the proposal and the corresponsing annexes. Namely: 1) Table 1 of ANNEX 1: ‘Dimensions and codes for the types of intervention for the ERDF, the ESF+ and the Cohesion Fund’ under the Policy Objective 2 includes INTERVENTION FIELD 043 - Household waste management: mechanical biological treatment, thermal treatment. Inclusion of MBTs and thermal treatment facilities such waste incinerators is a direct contradiction with the overall objective to exclude funding for residual waste treatment facilities. This category should be therefore excluded from the list of intervention fields. 2) Annex 1 ‘Common output and result indicators for the ERDF and the Cohesion Fund - Article 7(1)1’ under the section 2. 'A greener, low-carbon Europe by promoting clean and fair energy transition, green and blue investment, the circular economy, climate adaptation and risk prevention and management' lists an output indicator ‘RCR 49 - Waste recovered’ . We believe this output indicator also refers to residual waste treatment activities and should be therfore excluded from the list of indicators. See the attachment with relevant sections.
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Response to EU implementation of the Aarhus Convention in the area of access to justice in environmental matters

5 Jun 2018

Zero Waste Europe welcomes the opportunity to contribute to the Commission’s EU implementation of the Aarhus Convention in the area of access to justice in environmental matters. Zero Waste Europe is an European network of communities, local leaders, businesses, experts, and change agents working towards the same vision: eliminating waste in our society. We empower communities to redesign their relationship with resources, to adopt smarter lifestyles and sustainable consumption patterns in line with “circular” resource management. GENERAL COMMENTS ZWE is concerned about the fact that the EU is in violation of the Aarhus Convention by failing to provide members of the public with access to the EU courts, as found by the Aarhus Convention Compliance Committee (ACCC) in 2017. In essence, the non-compliance with the Aarhus Convention means that the EU violates international law and primary EU law. As such, both our members and our organisation has seen how the Aarhus Regulation is restrictive in its current form, and that requests for the internal review of different acts of the EU institutions are declared inadmissible for a variety of reasons, from the need that it is of “individual scope”, to “adopted under environmental law” including to “have legally binding and external effects”. We believe that this needs to change and encourage the EU to do so as quickly as possible, so that citizens can have access to justice, as planned in the Convention. ZWE and its members would also like to take this opportunity to highlight some of the challenges faced in EU countries when it comes to having access to justice: • Courts should be able to impose injunctions on ongoing processes until the final decision is made by the appropriate judicial forum; automatic suspension against administrative permits should be applied as a fundamental rule. This is often the case when citizens bring a legal challenge to a waste incineration infrastructure. • Judicial procedures in environmental matters should be finished in an expedited way so that there is a quick reaction to a threat or damage to the environment, which once perpetuated can have lasting effects. • It is important not discriminate those without citizenship, which are often the ones that suffer the most the environmental externalities of waste araisings and unsustainable waste and resources management. • Appropriate financial support mechanisms should be applied to make litigation possible for those (individuals or NGOs) in need. Our members, when losing a case, have had to face the legal fees of the national institutions in addition to their own, which puts organisations and individuals in dire economic situations.
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Response to Towards an EU Product Policy Framework contributing to the Circular Economy

1 Jun 2018

Please find attached ZWE's response to the consultation
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Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and Seas At Risk vzw

15 May 2018 · Plastics Strategy

Meeting with Helena Braun (Cabinet of First Vice-President Frans Timmermans) and Friends of the Earth Europe and

13 Apr 2018 · discussion on single-use plastics legislation

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and

13 Apr 2018 · Single use plastic

Response to Update of the 2012 Bioeconomy Strategy

20 Mar 2018

Zero Waste Europe (ZWE) welcomes the opportunity to comment on the Roadmap on the Communication updating the 2012 European bioeconomy strategy. Our response is divided into two sections: section one on general comments and section two on specific areas. Briefly, our main points are: * In absence of proper evidence of environmental impacts of bioeconomy, the precautionary principle should prevail. * The bioeconomy strategy should enhance EU’s environmental policies and objectives. * The bioeconomy strategy should support the transition towards a circular economy, hence promoting reduced material use over material substitution. * The promotion of the bioeconomy should not distort markets in a way that the consumption and use of certain materials is encouraged. * Bioenergy forms not fitting the circular economy and the waste hierarchy -i.e. Incineration and co-incineration- should be discouraged. SECTION 1: GENERAL COMMENTS The bioeconomy, because of its nature, is very much related to a big number of environmental and social policies, including climate change, land use, agriculture and food security, biodiversity and habitats, waste management, fisheries, product footprint, etc. For that, it is key that any strategy and action plan touching on the bioeconomy contributes to effectively enhance EU’s environmental policies and objectives. Taking into account the potential negative impacts of any measure willing to drive the production and consumption of biomass, and learning from the experiences of biofuels and biomass use for energy extraction, Zero Waste Europe would advocate for the use of the precautionary principle, as described in the Article 191 of the TFEU. In this sense, the roadmap enumerates six different objectives, five of which are meant to increase the importance of this sector, while the last one intends to strengthen the understanding of environmental impacts of bioeconomy and increased biomass production. Zero Waste Europe considers that it is inconsistent to design a roadmap to increase the production of biomass and then acknowledge that there isn’t enough information on the environmental impacts of increased biomass production and use. In this regard, Zero Waste Europe believes that any action to be taken to promote biomass production has to come once the environmental impacts are well assessed and understood. While there is wide evidence of the environmental benefits of preventing energy use, waste generation and material use, one cannot necessarily and systematically say the same for the substitution of non-renewable materials with biomass. In this respect, Zero Waste Europe considers that all EU efforts should be directed to the prevention of energy consumption, waste generation and material use and that any strategy aiming at substituting current mineral-based materials with biomass should be accessory to a significant reduction. (For section 2, see the file attached)
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Meeting with Elżbieta Bieńkowska (Commissioner) and

30 Jan 2018 · Exchange of views regarding strategy on plastics

Meeting with Frans Timmermans (First Vice-President) and European Environmental Bureau and

6 Nov 2017 · Discussion on EU Plastics Strategy

Meeting with Grzegorz Radziejewski (Cabinet of Vice-President Jyrki Katainen) and Friends of the Earth Europe and

26 Oct 2017 · Plastic strategy

Meeting with Daniel Calleja Crespo (Director-General Environment)

27 Jun 2017 · Circular Economy Package, international and european cooperation

Meeting with Aurore Maillet (Cabinet of Vice-President Karmenu Vella) and European Environmental Bureau and Friends of the Earth Europe

10 Mar 2015 · Circular Economy