Over the last decades, the European recycling industries have drastically evolved by modernizing and constantly innovating to turn more waste streams into new resources. By doing so, the sector has contributed to the development of new technologies and automated equipment made in Europe and exported around the globe. The European regulatory framework has accompanied these changes thanks to ambitious targets and a meaningful waste hierarchy. However, the recycling sector continues to be subject to a complex and ever-growing EU regulatory framework, which affects its activities. To ensure a competitive European recycling sector, which is part of a global industry, EuRIC advocates clear, effective and smart European policies which:
- Incentivise recycling across the value chains;
- Minimise regulatory burdens on recyclers, in particular on SMEs;
- Guarantee an open and fair competition within Europe and with the world to foster a genuine internal recycling market.
EuRIC also advocates positive measures to ensure a consistent implementation of existing legislation across Europe.
EuRIC Updated Position on EPR Schemes for Textiles
In 2020, the volume of separate collected textiles in the EU-27 was estimated to be between 1.6 and 2.5 million tons (MT). What is currently a self-financing system through revenues generated by the preparation for re-use and the marketing of second-hand textiles will drastically change in the future. For example, 87% of German collectors have reported an average decline in quality due to the increased presence of impurities or inferior quality of the textiles they receive. It is therefore much needed to encourage the development of further markets for used textiles but also recycled fibres. One of the policy tools to strengthen the textile re-use and recycling market is an extended producer responsibility scheme (EPR) as introduced by the Waste Framework Directive 2008/98/EC (WFD). Extended producer responsibility schemes are a set of measures taken by Member States to ensure that producers of textiles would bear the financial responsibility for the management of the waste stage of the textile’s life cycle.
 GftZ: Hintergründe und Strategien zum Aufbau eines Systems für eine „Erweiterte Produzentenverantwortung für Textilien“ (2019)
 Bvse Textilstudie (2020)
EuRIC Circular Metals Strategy
Reaching climate neutrality by 2050 will require drastic changes throughout all value chains, in particular for energy-intensive industries such as metal production. Thanks to their intrinsic properties and market value, discarded metals have been recycled for decades and used to produce new ferrous and non-ferrous metals again and again.
Metal recycling is a must to achieve the climate and circular economy targets set by the European Green Deal and the new Circular Economy Action Plan. Metals are essential in both products and systems which are essential to a low-carbon economy and everyday products. Compared to primary production, steel, aluminium or copper recycling save respectively 58%, 92% and 65% of CO2 emissions and spare primary raw materials often extracted outside Europe where much lower standards apply.
Despite enormous environmental benefits, substantial bottlenecks keep hampering metal recycling in Europe.
- The first one has to do with the fact that Europe’s industry remains mostly linear with only 12% of the materials it uses coming from recycling. As a result, in Europe, the supply of metal scrap from recycling meeting industry specifications often exceeds the demand and remain under-utilised in metal production.
- The second one relates to the fact that commodity prices still fail to internalise the massive environmental benefits of metal recycling. There is in EU legislation no incentive that rewards metal recycling lower-carbon and energy footprint when compared with primary raw materials (often extracted outside Europe).
- The third one is rooted in European waste legislation which hinders more circularity. Metal scrap is a valuable commodity, with a positive environmental footprint, which should not be classified as waste but as secondary raw materials. In addition, a number of procedures pertaining to cross-border shipments or to permitting remain far too burdensome to incentivize circular metal value chains.
For Cinzia VEZZOSI, President of EuRIC, “Time has come to lay down a more ambitious strategy to boost metal recycling in Europe and support the entire metal value chain, which is a backbone of any modern economy”.
She stressed in particular the absolute need to set up framework conditions and incentives that steers metal recycling and metal production from secondary raw materials by rewarding their environmental benefits. “This should be one of the priorities of the EU Recovery Plan”. Taking the example of steel, “it is key to support value chains currently striving to migrate from current blast furnaces which use primary iron ore and coal, to electric arc furnaces which use recycled steel and can use power from renewable sources. Low-carbon impact steel and metals in general are not only vital to achieving climate neutrality, it is also instrumental to compete better in a rapidly changing market”, Vezzosi added.
Of equal importance is the need to simplify legislation applicable to circular value chains. “To create a well-functioning EU market for secondary raw materials, metal scrap meeting industry specifications shall no longer be classified as waste. We need to align legislation which hampers the transition towards a more circular economy with overarching EU policy objectives embedded in the Green Deal otherwise circular frontrunners won’t be able to deliver”, she stressed.
Last but not least, guaranteeing free, fair and sustainable trade is more important than ever. We need to refrain from setting any trade restrictions negatively impacting metal scrap processed to industry specifications which operates on an inherently global market. Forthcoming measures shall focus on better pricing carbon-intense imports to level the playing with low-carbon products made of recycled materials.
EuRIC reaction to the IIA of the Designing mobile phones and tablets to be sustainable initiative
Improving the design of products is a pre-condition to transition towards a circular economy. Improving the design of products is a pre-condition to transition towards a circular economy. As it has already been highlighted in the report released by the European RecyclingIndustries’ Confederation (EuRIC) named “Top 5 Priorities of the Recycling Industry for thePeriod 2019 -2024”, 80% of products’ environmental impact are determined at a design stage.
Although the above-mentioned fact is also stated in the Circular Economy Action Plan 2.0 (CEAP), the vast majority of products placed on the EU market – and not only – are still designed without any consideration for their end-of-life stage. Design for circularity is therefore of an outmost importance to move towards a more circular economy and needs to be extended to all products’ categories, including mobile phones and tablets.
EuRIC thus fully supports the necessary Designing Mobile Phones and Tablets to be Sustainable Legislative Initiative to keep the already exploited resources in the market for as long as possible by connecting the dots between the design and end-of-life (EoL) phase of products.
Read the top priorities identified by EuRIC in the linked document below.
EuRIC Annual Report 2020
We are pleased to share with you EuRIC's first annual review featuring its 2020 achievements and future commitments.
In 2020 we expanded, reached new heights and continued pushing ourselves and those listening to our growing voice with one common goal: to get one step nearer to closing the loop.
Our plans for 2021 are just as ambitious as our increased responsibilities. We are confident that with the relentless work of the EuRIC Secretariat and EuRIC Members, our joint efforts will make a lasting and positive impact on the decision making in Europe.
EuRIC Comments on the Industry Voluntary Agreement to improve environmental performance of imaging equipment placed on the European market
Following the publication of a draft Voluntary agreement (VA) v.5 as of 7th October 2020, toFollowing the publication of a draft Voluntary agreement (VA) v.5 as of 7th October 2020, toimprove the environmental performance of imaging equipment placed on the EuropeanMarket, and in addition to the comments made on previous drafts, EuRIC is pleased to sharethe following comments on the new draft VA.
EuRIC Position for a Revision of the Waste Shipment Regulation Supporting the Circular Economy
The Waste Shipment Regulation (WSR) is, as rightly identified in the new CEAP, a pivotal piece of legislation with provisions that need to be aligned with the overarching objectives of transitioning towards a circular economy. Hence, the revision offers the opportunity to make both needed adjustments to fix lasting bottlenecks and radical changes to address long-term obstacles rooted in outdated obligations.
It is time to align the procedures set by the Waste Shipment with the pace of Circular value chains. A paradigm shift requires to treat waste in legislation as a resource enabling the circular economy, stressed Peter FLORMANN, Chair of EuRIC Waste Shipment Task Force.
This paper goes beyond simply identifying lasting problems rooted in waste shipment procedures. It provides detailed solutions to support a revision of the WSR that enables the creation of a well-functioning European market for secondary raw materials. EuRIC calls in particular for
- Simplified waste shipment procedures, be it for green listed waste and waste subject to prior informed consent (PIC) procedure, which make an extensive use of the digitalization (electronic procedures);
- Preserving free and fair trade of secondary raw materials which is vital to the competitiveness of the European recycling industry and to speed up the transition towards a circular economy, while leveling the playing field with primary raw materials;
- Accompanying the revision of the waste shipment regulation by binding requirements to boost the use of secondary raw materials in production processes and reward their well-documented environmental benefits in terms of GHG and energy savings.
For Julia BLEES, Senior Policy Officer at EuRIC, closing boundaries has never brought any benefits except distorting markets. While EuRIC entirely supports avoiding unprocessed waste posing an environmental risk to find its way to countries lacking any infrastructure and makes practical proposals in that respect, it is key to ensure that free and fair trade of secondary raw materials remains unhampered. At a time where Europe’s industry remains mostly linear with only 12% of the materials it uses coming from recycling , truly boosting circular value chains in Europe require decisive measures such as binding recycled content targets and incentives supporting the uptake of recycled materials in manufacturing, not trade barriers, she concluded.
Top 5 Priorities of the Recycling Industry for the Period 2019 -2024
By turning waste into secondary raw materials and reducing Europe’s dependency on primary materials, the recycling industry plays a vital role in the circular economy. In addition, recycling saves a substantial amount of CO2 and energy. Recycling is thus a key sector to make Europe the first climate-neutral continent, a key objective of the European Green Deal highlighted by Ursula von der Leyen, the President of the European Commission. Last but not least, recycling is an inclusive industry providing local jobs which rely on a variety of qualifications and cannot be outsourced. Thus, recycling can significantly contribute to Europe’s re-industrialisation by boosting circular value chains. Hence, EuRIC representing the European Recycling Industry, calls for the completion of a competitive internal market for recycling rewarding circular value chains in Europe and beyond, through a set of 5 key measures.
EuRIC Brochure on Mechanical Tyre Recycling highlighting its contribution towards circular economy and climate neutrality
EuRIC Brochure presents key facts about end-of-life (ELT) mechanical tyre recycling, which is a major enabler of circularity and climate mitigation for the entire tyre value chain.
The Brochure describes the current state of play of ELT management with recommendations to overcome key challenges faced by the European mechanical tyre recycling industry be them embedded in legislation, market failures or eco-design. It features key numbers outlining the economic importance of the ELT recycling sector as well as its benefits for the environment and society.
State of the art mechanical tyre recycling entirely supports the European Green Deal and the new Circular Economy Action Plan stressed Poul Steen Rasmussen, President of EuRIC’s Mechanical Tyre recycling (MTR) Branch and Group CEO Genan. The processing of ELT tyres into rubber is not only the most resource-efficient option; it also the most climate-efficient one since for each tonne of ELT recycled -for example as infill for artificial turf pitches- the climate is spared 700 kg of CO2, he added.
Currently, out of the approx. 3 million tonnes (Mt) of tyres reaching end-of-life stage annually in Europe, there are more than 1 Mt of tyres down-cycled annually in energy recovery, while less than 50% (approx. 1.5 Mt) are mechanically recycled into rubber, steel and textile fibers. Increasing material recovery is essential as natural rubber is a critical raw material in Europe.
A landfill ban for ELT is far from sufficient to boost tyres circularity. The EU needs to consider further measures to closing the loop of the Circular Economy of tyres, in particular:
- Incentives rewarding ELT recycling benefits and recycled content targets to drive the demand for recycled materials from tyres, especially rubber, be it in new tyres, asphalts, moulded products and construction materials.
- EU-wide end-of-waste criteria for ELT which are essential to alleviate obstacles impacting circular uses of materials derived from ELT recycling into a variety of applications benefiting society, the environment and industrial symbiosis. While national end-of-waste criteria as the recently adopted by Italy are strongly supported, harmonization at EU level is key for a well-functioning of internal market for secondary raw materials.
Sustainable design of tyres to boost their recyclability and minimum thresholds of recycled content to stimulate the demand. Product design requirements shall go hand in hand with a better enforcement at European borders of imported new tyres which must comply with European standards to level the playing and protect the environment.
 European Commission (2020). Critical Raw Materials Resilience: Charting a Path towards greater Security and Sustainability
 Regolamento recante disciplina della cessazione della qualifica di rifiuto della gomma vulcanizzata derivante da pneumatici fuori uso, ai sensi dell'articolo 184-ter del decreto legislativo 3 aprile 2006, n. 152. (20G00094) (GU Serie Generale n.182 del 21-07-20)
EuRIC Indicative Specification Sheets for main grades of sorted plastics
EuRIC’s purpose is to propose with these specification sheets an objective, measurable definition of the new B3011 entry of the Basel Convention which will enter into force on January 1st, 2021 (complete definition below). As you know, from this date on, only plastics registered under this B3011 entry will be eligible to the general information procedure. All other plastics will have to be shipped under the prior informed consent procedure under Y48 entry.
The proposed specifications intend to clarify and provide a more harmonized criterion to assess what “almost free from contamination and other types of wastes” means and help devising a sound classification of sorted plastic waste, in particular in case of customs control, and to avoid excessive discrepancies between Member States when implementing these new B3011 / Y48 entries.
Furthermore, these specifications also aim to be applied to plastic waste shipments within the EU (EU3011).
You will find three documents with specification sheets:
- a general plastics from packaging,
- an "all streams" flakes specification- extremely generic and intend to cover for all the small streams waste which are important when put together and are often recycled abroad,
- a stream-specific technical plastics from WEEE & ELVs.
The “All streams – Flakes specification” is intended to apply exclusively to the flakes classified as waste. Currently, the waste / non-waste status of plastics flakes is not homogeneous and varies widely from one state to another, including within the EU. Similar plastic flakes can be classified either as waste or non-waste (product, by-product, product through “end-of-waste” procedure). EuRIC supports the classification as non-waste of flakes that are fit for integration within a manufacturing process.
The proposed standards are not meant to replace, but are meant to be compatible with, contractual agreements on waste quality set between sellers and purchasers, national quality standard, set by national recyclers associations or by EPR schemes (for example DSD specifications or FEDEREC’s waste classification), future Europe-wide quality grades for plastics waste such as those being prepared by CEN, etc.
These specifications have been updated on the 16/02/2021. For a conservative approach, mass should be not expressed as dry matter.
EuRIC Statement in support of the State of the Union 2020
Today, Ursula von der LEYEN, President of the European Commission, delivered a landmark speech on the State of the Union 2020. The European Recycling Industry renews its support to the European Commission in making the European Green Deal, Europe’s strategic priority.
EuRIC strongly welcomes in particular the proposal made by the European Commission to increase the 2030 target for emission reduction to at least 55% which is a necessary step forward in order to make Europe the first climate-neutral continent by 2050. EuRIC equally supports the decision to allocate 37% of NextGenerationEU to European Green Deal targets as massive investments are needed to deliver on these objectives.
The European Recycling Industry is ready to play its part. By turning waste into quality raw materials used to manufacture new products, recycling companies, be them SMEs or market leaders, enable the circular economy and create local, non-outsourceable jobs across Europe. In addition, recycling is not only intrinsically resource-efficient but also climate efficient by saving significant amounts of Greenhouse Gas Emissions (GHG) and energy, well-documented in robust studies for a variety of resource streams.
“To speed up the transition towards a circular economy and meet the ambition set by the European Green Deal, it is instrumental to incentivize the use of secondary raw materials in manufacturing” stressed Cinzia VEZZOSI, President of EuRIC. “Recycled content targets for a variety of products as well as incentives to reward recycling environmental benefits and level the playing field with primary materials are absolutely essential. In addition, time has come to speed up the adaptation of the EU’s regulatory framework to create a well-functioning market for secondary materials and streamline requirements hampering circular value chains, keeping in mind the global nature of commodity markets which are key to balance supply and demand. Last but not least, decisive actions are needed to boost eco-design for re-use and recycling of all product categories. Products which cannot be recycled when they reach end-of-life by using best available techniques should not find their way on the internal market. We have a vested interest in working with producers to ensure that design for circularity becomes the new norm”, she concluded.
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