Circular Economy Package: “Still A Long Way To Go”

circular-economy-eu-commissionThe European Commission yesterday (2 December) announced the adoption of its long-awaited Circular Economy Package 2.0. With arguably weaker recycling targets than its predecessor and a ban on landfilling separated waste, just what does the resources and waste industry have to say about it? 

A few of the headline measures in the new Package include a common EU target for recycling 65% of municipal waste by 2030 and a target for recycling 75% of packaging waste. It will also see a binding target to reduce landfill to maximum of 10% of all waste by 2030 and a ban on landfilling of separately collected waste.

Targets

On the face of it the recycling targets appear weaker than the first proposed Package, which included a 70% recycling target for municipal waste by 2030 and an 80% recycling target for packaging.

However, the new proposal to reduce municipal waste landfilled to 10% by 2030, combined with the ban to landfill of separated waste sends a clear signal that the “era of large-scale landfill will be over”, according to the Resource Association’s chief executive, Ray Georgeson.

“These recycling targets will be legally binding and in themselves will present a stiff but achievable challenge for some member states,” he said.

“The argument likely to unfold about the merits or otherwise of a 70% or 65% 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.”

Veolia’s technical director, Richard Kirkman said that the new targets are “a big step to delivering a Circular Economy”, but that any percentage target must be supported by the material having a value, which means manufacturers need to start creating products that are truly recyclable and made from recycled materials.

“With recycling rates in the UK plateauing we need to find ways of making it easier to separate these materials and industry needs to take the lead on this,” he said.

Reuse

According to the Reuse and Recycling EU Social Enterprises network (RREUSE), the Package, if left unchanged, will not do enough to develop local re-use centres, create jobs and stem the tide of re-usable goods sent to recycling or landfill every year.

Michal Len, director of RREUSE 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.”

Craig Anderson, FRN – “…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?’”

“While we welcome some of the encouraging language on opening up access for reuse 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 reuse becomes a clear part of the legal framework, not left as an afterthought for voluntary action.”

Len also expressed concerned about some of the language used in the proposals, who said if left unchecked, could have “serious consequences”

“It is possible that proposed changes to the legal definition of preparation for reuse could result in some re-use organisations currently not subjected to complex waste legislation and heavy standards, potentially having to do so. Existing obligations on producer responsibility to support preparation for re-use activities risks also being eroded.”

CEO of Furniture Re-use Network and member of the RReuse Board of Directors, Craig Anderson added to this: “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?’” 

“Demand Side”

The Package also received criticism for its apparent lack of “demand side” measures at a time when markets for secondary raw materials are currently weak, “with little or no sign of recovery,” according to ESA Chairman Peter Gerstrom.

“Without sustainable markets for these materials it will be very difficult to deliver the Commission’s vision of higher recycling rates and a more Circular Economy” he said. 

David Palmer-Jones – “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”

Suez CEO and president of FEAD, David Palmer-Jones, commented that the Commission had not recognised that market forces and supply side measures alone will not deliver a circular economy. He said 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,” he said, “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… that said, there is a lot within the proposals to applaud.”

CIWM Says

CIWM’s chief executive, Steve Lee, said that within the Package much of the work still sits with the waste and resource management industry and some of the critical elements that had been hoped for, particularly on the “demand side”, have been “hived off” into an Action Plan with no clear schedule for delivery.

Steve-Lee-no-cut-out-wide-web
CIWM CEO, Steve Lee

“That is not to say that the package isn’t useful or ambitious,” he said. “A 65% recycling target by 2030 may not challenge those member states and municipalities at the very top of the recycling league table, but it does maintain the direction of travel, and there is more emphasis now further up the waste hierarchy.

“Likewise, some will say there is a softer approach to food waste than was expected but this does not detract from the widespread consensus that food waste is the next ‘big bite’ when it comes to recycling and waste prevention. In the UK, we already have three countries with clear ambitions and policies on food waste, demonstrating that unilateral action in this area is possible. If England wants to follow suit, it doesn’t need to wait to be told to do so by Europe.

Steve Lee, CIWM – “There is still a long way to go on this package. This is just the first leg; if we feel that there are elements that need to be added to or strengthened, like market stimulation and ‘pull’ mechanisms, we are going to have to fight harder for them over the coming months”

“There is, indeed, much in the package that recognises subsidiarity by pushing many areas of action back to Member States, such as financial incentives and extended Producer Responsibility initiatives. That, however, relies on national governments having an appetite for these interventions – and this appetite is not consistent across the UK.

“There is also a question mark over the Commission’s promise to develop quality standards for secondary raw materials. Standards that work across a range of different end markets and applications in different countries are highly challenging to set out and agree, a fact that the Commission should be aware of given the protracted difficulties it experienced in trying to developing EU-wide End of Waste criteria. That said, CIWM welcomes the priority focus on plastics as potentially the most diverse and challenging waste stream.

“On the measurement front, CIWM strongly supports the Commission’s commitment to harmonising definitions of waste and calculation and reporting methods.  More and better data will be essential to drive performance across the full range of Circular Economy indicators and in the formulation of smarter targets and interventions in the future.

“There is still a long way to go on this package. This is just the first leg; if we feel that there are elements that need to be added to or strengthened, like market stimulation and ‘pull’ mechanisms, we are going to have to fight harder for them over the coming months. A circular economy just isn’t going to happen unless there is a clear value chain pulling materials through the market and back into manufacture. The package acknowledges that EU action to support markets for secondary raw materials “is particularly important” but all the real action is deferred. All four UK governments need to push Europe on this and commit to action at home.”


CIWM Resource Conference Cymru 

The CIWM Resource Conference Cymru will be exploring the new EU circular economy package. With a focus on clarifying the package and targets, exploring what these mean in practical terms and revealing real-life solutions and best practice, hear first-hand from EU speakers and join in the discussions with professionals from across the industry. For more information and to book your place click here.

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