Commission’s view on recycling will cause problems for all stakeholders and all materials
The waste guidance issued by the European Commission's environment department poses a serious risk to advancing a recycling society in Europe, EU paper industry association CEPI warns. The guidance is linked to a second batch of End-of-Waste (EoW) measures, applied to paper, copper and glass, likely to be adopted by an EU regulatory committee on 9 July.
In the guidance document the Commission says that "the moment when a material or substance reaches End-of-Waste is simultaneous with the completion of the recovery and recycling processes."
CEPI strongly argues that, for paper, the guidance document should not describe compliance with EoW criteria as being equivalent to recycling.
CEPI questions the fact that the Commission is putting efforts into something that is likely to cause unintended problems to all stakeholders of paper recycling, and probably in all industry sectors. CEPI points at problems with previous EoW measures (for steel) adopted by the Commission that have simply been rejected by the market and therefore not been implemented in practice. Thus, serious consequences did not emerge yet, but are bound to, when further EoW measures will be adopted.
For waste management companies and waste traders the scenario will be frightening. With the new interpretation they would become “recyclers”, without receiving any significant benefit. In return, however, they would be legally responsible for the output material as “producers”. This includes liability issues in the quality of waste material and its contamination. The full implications of that change in interpretation are not clear. Requiring such responsibility from waste management companies might just add to the growing list of badly implemented environmental EU measures and would not contribute to smart, green and inclusive growth in Europe.
Considering EoW equal to recycling will also effectively break the information flow for public authorities, which may have serious consequences for environmental inspections and enforceability as well as generations of reliable data and statistics. Later, when much larger volumes are supposed to be managed as “recycled” EoW materials by a significant number of operators, problems are bound to occur. Even today, under the strict waste regime, the authorities have not been able to satisfactorily establish enforcement of legal waste shipments either.
For the industries that reprocess the material – in CEPI’s case paper mills – the Commission’s approach will increase the risk of receiving low quality recyclates from collectors. This runs contrary to the original objective of EoW, which according to the EU's Joint Research Centre, was established to facilitate recycling and not to be a substitute for it.
Allowing all this to happen will inevitably shake the confidence of citizens and risk the integrity of recycling systems.