Industry voices disappointment in CEP
Having waited a year for the European Commission’s (EC) Circular Economy Package to be reworked into a ‘more ambitious’ proposal, members of the waste and resources industry have questioned the final product, which was finally released this morning (2 December).
‘A wasted year’
Among the causes for concern are the reduction of recycling targets from 70 per cent by 2030 to 65 per cent, the lack of a clear target on food waste reduction, and the dropping of binding targets for resource efficiency and biowaste.
Magda Stoczkiewicz, Director of Friends of the Earth Europe (FOEE), said: “This has been a year of unnecessary delay. Under the guise of better regulation, the commission has totally undermined claims of ‘ambition’ by watering down binding measures and giving member states a free pass to shy away from tackling our overconsumption crisis. Compared with the previous one, this package is not better regulation but short-termist bad regulation.”
FOEE added that by lowering the targets included in the package, the EC puts its estimates of creating two million new jobs and saving €600 billion (£422 billion) at risk.
This is a point echoed by Zero Waste Europe (ZWE), which warns that the proposed legislation and action plan will not be enough to achieve such huge benefits. Joan Marc Simon, Executive Director of ZWE, commented: “The new waste legislation has been watered down as compared to 2014’s package, while the action plan is mostly a patchwork of very vague policy proposals, some of them not expected to be implemented until the end of the current commission mandate.”
ZWE is critical of the legislative proposal as it fails to address prevention and reuse, and eliminates food waste and marine litter reduction targets and does little to avoid the ‘lock-in’ effects caused by ‘zero waste to landfill’ strategies.
Simon concluded: “[Examples like] Contarina, Ljubljana and Gipuzkoa showcase how it is possible to achieve 70-plus per cent recycling rates as well as substantial waste reduction in less than 10 years whilst reducing management costs and creating local jobs.”
Stéphane Arditi, Policy Manager for Products and Waste at the European Environmental Bureau, commented: “The commission has failed to deliver on its promise to come with a more ambitious proposal. The addition of some nice initiatives does not offset the fact that the legally-binding core of the package, notably the waste targets, is weaker than in last year’s proposal. We’ve ended up with a wasted year and a proposal that is less ambitious.
“Europe has no choice but to become more efficient with the resources it uses. A growing global population and increased demand for the planet’s materials is forcing this. But for it to happen fast enough, European Parliament and the Council of Ministers will need to inject more life into this proposal, so that the EU can lead globally in this crucial area.”
More action needed to stabilise recycled material markets
Commenting on the proposals, David Palmer-Jones, Chief Executive of the Recycling & Waste Recovery UK division of SUEZ, said: “It is heartening to see the inclusion of the Ecodesign Working Plan for 2015-2017, which will help by setting requirements on durability, reparability and recyclability of products and standardisation of material efficiency – demonstrating that the commission is looking not just at our sector, but the whole chain.
“However, I do feel that the commission has not recognised that market forces and supply side measures alone will not deliver a circular economy and that the omission of robust policies to create a flourishing market for recycled materials is a missed opportunity.
“The current markets are unstable and disincentivise secondary raw material production and uptake by Europe’s industry, yet the commission’s proposals imply that market mechanisms alone will achieve a resilient market for secondary raw materials, which is something we are just not seeing.
“In my view, the package could have, and should have, contained stronger regulatory ‘pull’ measures to create demand for secondary raw materials. Without this, we could quickly find that the collecting and sorting of these materials becomes uneconomic.
“While secondary materials are in direct competition with lower-price virgin materials, we will not deliver a more circular economy in Europe, even when overall demand for raw material is strong, unless the environmental cost of using primary raw materials is better reflected in their price.”
The Resource Association was one of the groups to write to the European Commission last month emphasising the need for pull measures to balance out recycling targets, but Chief Executive Ray Georgeson feels that the omission of such measures will be lost in discussion about the lowered targets: “The argument likely to unfold about the merits or otherwise of a 70 per cent or 65 per cent recycling target misses the point again that Europe would have been better served by a serious reboot of policy, incorporating carbon metrics not weight-based percentage targets and a holistic approach to the circular economy that incorporated real demand-pull measures, stricter approaches to eco-design and recyclability and much greater emphasis on prevention, reuse, repair and remanufacturing. It’s all there at least in part and heading in the right direction - but not deep enough, nor fast enough, nor with a clear enough long-term regulatory framework that will drive investment, increase employment and respond fully to the COP21 agenda."
ACE Director General Bertil Heerink said: “Our industry is firmly committed to contribute to the realization of a Circular Economy and will look with special attention to the proposed review of the Packaging and Packaging Waste Directive. Just increasing the individual recycling targets for key materials like paper, plastics and aluminum will not be sufficient to match innovation. Measures must be taken that strengthen existing recycling solutions, foster innovation in new recyclable materials and recycling techniques, resulting in a further increase in recycling of beverage cartons across Europe.”
Package 'missed a trick' with remanufacturing and reuse
A large part of predicted circular economy benefits are built around the increase of reuse and remanufacture, however industry groups do not feel that these sectors were adequately represented in the package.
Susanne Baker, Head of Environment and Compliance at techUK, commented: “The package has profound implications for those making electrical and electronic products. While there are valuable elements, such as innovation funding and the dismantling of regulatory barriers, we think the Commission has missed a trick.
"There is little to try and get consumers to buy into this vision for a circular economy. And once again we see an overly disproportionate focus on "waste" and prescriptive regulation, rather than creating strong incentives to encourage remanufacturing and service innovation. This is disappointing, as it’s in these tighter circles of the circular economy where the strongest environmental and economic benefits can be found."
Commenting on today's proposals, Michal Len, director of RREUSE, a representative body for national and regional networks of social enterprises with re-use, repair and recycling activities, said: "In recent years, the heavy emphasis on recycling in the EU has meant resource-efficient repair and re-use has been hit hard. The Circular Economy Package was an opportunity to turn the tide, but it's missed the mark. While we welcome some of the encouraging language on opening up access for re-use organisations to waste collection facilities and the aspirations to boost repair by improving availability of spare parts and service manuals, there is precious little in the way of binding measures. Critically, despite a new proposed methodology there is no legally binding separate target for preparation for re-use, only encouragement for member states that want to do this. It's vitally important that preparation for re-use becomes a clear part of the legal framework, not left as an afterthought for voluntary action.
Craig Anderson, CEO of the Furniture Re-Use Network and member of RREUSE board of directors, added: "We do welcome the essence of the overall Circular Economy package and respect that it is breaking silos in the Commission and contributing to broad political priorities by tackling climate change and environment whilst boosting job creation, economic growth and social fairness. However, in this circumstance, the devil is in the detail and part of the package’s proposed amendments will make it very difficult for those in the reuse sector."
"Reuse is not really about waste – it is about products being in service, safe and used by consumers. Although we work with waste infrastructure to get waste products out of waste streams, we cannot be put at risk by unduly burdensome misdirected policy decisions. Nor can we be put at risk by grammatical nuances and misplaced commas. It leaves us alarmed and begging the question ‘how can a ‘non-waste’ product legally be in scope of an EU waste directive?’"
Material bodies welcome resource efficiency measures
The package has not been completely panned by the industry, however, with Confederation of European Paper Industries (CEPI) Director General Marco Mensink saying that it had “correctly identified the synergies needed to find real solutions”.
He said: “The package has reached a level of ambition rarely seen in policymaking. By recognising the contribution of biomass and bio-based products to the circular economy, the European Commission now takes into account that circularity in many cases starts with raw materials from renewable sources. CEPI is looking forward to concrete actions in the field of bio-based product in the future.
“In addition, the European Commission has recognised the importance of ending waste management options that do not create value for Europe. It is great to see that the commission recognises the need for separate collection of paper, providing good-quality raw materials. We also appreciate that further limits to landfilling are being put in place.”
Eurometaux, which represents organisations that make up the European non-ferrous metals industry, has also complimented the package’s stance on resource management. Director General Guy Thiran said: “Provided they are firmly implemented, several commission proposals will help quality recyclers get access to Europe’s metals. In particular, we support requirements to collect waste streams separately; to increase the recyclability of products; and to properly define ‘final recycling’. The commission has also made an important commitment to reduce landfill of municipal waste, and provided ambitious recycling targets for packaging.
“Looking ahead, stronger commitments should still be introduced in key areas, and rules need to be implemented the same way across EU member states. In that respect, today’s proposal can be boosted further through mandatory certification for recyclers of certain waste streams, stronger measures to combat illegal waste shipments, and a reduced burden when trading waste within Europe.”
You can learn more about the Circular Economy Package in Resource’s detailed summary.